July has many FCC obligations for broadcasters, both regularly scheduled and unique to 2013. There are the normal obligations, like the Quarterly Issues Programs lists, that need to be in the public file of all broadcast stations, radio and TV, commercial and noncommercial, by July 10. Quarterly Children’s television reports are also due to be submitted by TV stations by that same date. The Quarterly Issues Programs lists have traditionally been a problem area for broadcasters, and the source of numerous fines in connection with FCC inspections and license renewal applications (see, for instance, our article here). Recently, the failure to timely file Children’s Television Reports on Form 398 was the source of significant fines for a number of TV stations in connection with their renewal applications (see our article here). So, obviously, be aware of those dates. But also remember that there are a number of comments due in important FCC proceedings, including those described below, and there is also a July 24 filing deadline for long-form applications by the tentative winners in the recent FM auction and a July 22 deadline for settlement proposals in connection with mutually exclusive applications in the 2003 FM translator filing window.
In connection with comment deadline, the FCC is seeking comment on a study done by MMTC in connection with its multiple ownership proceeding about the effects of cross-ownership of broadcast and newspapers on minority ownership of broadcast stations. Those comments are due on July 22 (see our article here). Also, the reply comments on the FCC’s proceeding to clarify its indecency rules are due on July 18 (see our article here). Comments on stations’ experience with the online political file, and the readiness of smaller TV stations to start uploading documents to that file next year, are due in August, so stations should be preparing their thoughts on this proceeding (see our article here).
As is seemingly the case every month, July has important regulatory deadlines for broadcasters. Don’t overlook those dates that may apply to you!