While we were sidetracked by the government shutdown in posting reminders about regulatory deadlines for broadcasters during the last two months, it’s about time to put that behind us, and to resume our monthly practice. While everyone may be looking forward to the holidays, they need to remember that December does bring a number of regulatory obligations for broadcasters across the country. For instance, license renewals are due on December 2 (as the 1st is a Sunday) for the following station groups: Commercial and Noncommercial Full-Power and Class A Television Stations, TV Translators, and LPTV Stations in Colorado, Minnesota, Montana, North Dakota and South Dakota; Commercial and Noncommercial AM and FM Radio Stations, FM Translators, and LPFM Stations in Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont.
Radio and television stations in all of those states, plus those in Alabama and Georgia, that have 5 or more full-time employees in their station employment groups, also have the obligation to complete their Annual EEO Public Inspection File Report, and to place that report into their public file (for TV stations, that would be their online pubic file). The deadline for those reports to be complete and posted is December 1. Radio stations in these states also need to post the most recent report on their websites, if they have a website.
Noncommercial radio stations in the New England states, and noncommercial television stations in Colorado, Minnesota, Montana, North Dakota and South Dakota, also must prepare and file their Biennial Ownership reports by December 2. All commercial radio and TV stations (including LPTV stations) must prepare and file their Biennial Ownership Reports by December 20. These reports for all commercial stations were originally due on November 1, but that deadline has been extended several times by the FCC (see our articles here and here).
Commercial Television stations also must submit their Annual DTV Ancillary/Supplementary Services Report (FCC Form 317) to the FCC by December 2. That is the report that tells the Commission about the revenues made by digital television operations from non-broadcast sources.
The stations in the states listed above that have license renewals due in December will also need to run, on the 1st and 16th of the month, post-filing announcements about the submission of their renewal applications. Radio stations in New York and New Jersey, and TV stations in in Kansas, Nebraska, and Oklahoma, need to begin their pre-filing renewal announcements, leading up to the filing of their license renewals on February 1. Commercial and Noncommercial Full-Power and Class A Television Stations in Iowa and Missouri; Commercial and Noncommercial AM and FM Radio Stations in Alaska, Hawaii, Oregon, Washington, American Samoa, Guam, the Mariana Islands, and Saipan need to run the last two of their post-filing renewal announcements on these same dates.
Finally, large television stations need to do their first “spot check” on CALM Act compliance by December 13 (see our article on the CALM Act here). Smaller stations operating with CALM Act waivers may also need to think about extensions of those waivers, if they are not yet in compliance. See our article on past waivers, here.
Lots of deadlines for the last month of the year. As always, your station should carefully review its own applications, waivers, and other FCC authorizations to make sure that there are no other deadlines that you need to be aware of. The FCC can be very interested in any issues that arise – so make sure that your regulatory house is in order during this holiday season.