Just a reminder to broadcast stations in certain states of several upcoming August 1st obligations. Specifically, on Aug. 1, radio stations in certain states must commence pre-filing or post-filing announcements (depending on the state in which they are located) in connection with the license renewal cycle. In addition, Annual EEO Public File Reports must be prepared and placed in the public files by August 1st for stations in certain states. And finally, noncommercial stations in certain states must file a biennial ownership report by August 1st. Further details about these various deadlines — which again are specific to particular states and services — are below.
First up, August 1st is the deadline for Radio Stations in North Carolina and South Carolina to file their FCC Form 303-S license renewal applications seeking a renewal of their broadcast licenses. (See our earlier license renewal advisory here.) Accordingly, radio stations in those two states will also need to commence their License Renewal Post-Filing Announcements on August 1st to inform their communities of the renewal filing. Specific language for the announcements can be found on the Commission’s website here, and the post-filing announcements continue on August 16, Sept. 1, Sept. 16, Oct. 1, and Oct. 16.
Second, the next batch of radio license renewals — which will be filing their renewals on October 3rd — is Florida, Puerto Rico, and the Virgin Islands, which means that Radio Stations licensed to those three states (or rather commonwealths, territories, islands, etc., as the case might be), must begin their License Renewal Pre-Filing Announcements on August 1. The precise language of the pre-filing announcements—which is again dictated by the FCC’s Rules—can be found here. The pre-filing announcements for these stations continue on Aug. 16, Sept. 1, and Sept. 16.
Third, by Aug. 1, Radio and Television Station Employment Units (SEUs) in California, Illinois, North Carolina, South Carolina and Wisconsin must prepare and place in their public inspection file their Annual EEO Public File Report. Stations that have websites must also post the Report on their website. The Annual EEO Public File Report summarizes the station’s or the SEU’s EEO activities during the previous 12 months, and provides information about the recruitment and outreach that the station conducted in the past year. A copy of our recent reminder advisory with more information can be found here. In addition, Radio Stations in North Carolina and South Carolina will also be filing an FCC Form 396 EEO Report by August 1 in connection with their license renewal filing.
Finally, Aug. 1 is the deadline for Noncommercial Radio Stations in California, North Carolina and South Carolina, and Noncommercial Television Stations in Illinois and Wisconsin to prepare and file an FCC Form 323 Biennial Ownership Report with the FCC. Please note, this filing date applies only to noncommercial radio and TV stations in the states noted above. The FCC has revised its rules regarding the reporting of ownership interests for commercial broadcast stations, as well as revised the commercial Ownership Report—Form 323. Accordingly, commercial stations now file biennial ownership reports on one unified filing date, which will be later this year. A copy of our recent reminder to noncommercial stations about the Aug. 1 requirement can be found here.