April is one of those months with many routine FCC obligations. Quarterly Issues Programs lists need to be in your public file by the 10th of the month. This is an obligation for all full-power broadcast stations – commercial or noncommercial. Similarly, all TV stations have an obligation to submit their Children’s Television Reports on FCC Form 398 demonstrating compliance with the obligations to provide educational and informational programming directed to children, and at the same time put into their public files documents showing their compliance with the limitations on commercials within programming directed to children.
EEO public file reports are due for stations that are part of an employment unit with 5 or more full-time (30 or more hours per week) employees which is located in any of the following states: Delaware, Indiana, Kentucky, Pennsylvania, Tennessee, and Texas. Noncommercial TV stations in Delaware, Indiana, Kentucky, Pennsylvania, and Tennessee; and noncommercial radio stations in Texas, need to file their Biennial Ownership Reports with the FCC on April 1. Finally, license renewal applications in the last license renewal window for this license renewal cycle are due to be filed on April 1 by TV stations (and TV translators and LPTV stations) in Delaware and Pennsylvania. The next regularly scheduled license renewal will be filed by radio stations in certain states – but not until June 2019!In addition to these routine filings, there are comments due on a number of FCC rulemakings of interest to broadcasters. We have not previously written about the FCC’s proceeding looking to convert analog auxiliary facilities to digital. The FCC issued a Notice of Proposed Rulemaking on that subject, available here. Comments are due on April 3, and replies on April 20.
Other proceedings about which we have written before also have comment dates in April. Reply comments on the proposal for the online public file for radio (and cable and satellite) are due April 14. Comments in the proceeding to determine how to assign FCC Identification Numbers to attributable owners of broadcasters for purposes of the Biennial Ownership Report (summarized here) are actually due at the end of this month (March 30), but reply comments are due April 13. Reply comments on the FCC’s proposal to treat online providers of linear video programming as MVPDs are due on April 1. And comments on the FCC rules for the next FM auction (see our summary here) are also due on April 1. Comments have also been requested on the proposal of certain radio broadcasters to put certain sponsorship information online (see our summary here), due on April 13.
Finally, the FCC continues with its incentive auction seminars for TV stations, at which the FCC will generally update broadcasters as to the process and procedures for the auction and also schedule, on request, private meetings with broadcasters to discuss their particular circumstances. Details about these meetings can be found in the FCC public notice here. These sessions are scheduled as follows:
- April 13-14, 2015: Las Vegas, NV (General sessions to be held April 13, 4:45 pm to 6:00 pm; and April 14, 12:45 pm to 2:00 pm, in conjunction with the NAB Show)
- April 21, 2015: Richmond, VA
- April 22, 2015: Baltimore, MD
- April 27, 2015: Seattle, WA
- April 29, 2015: Denver, CO
Many proceedings with many deadlines, so be prepared. For a list of other upcoming regulatory deadlines, see our Broadcasters Calendar, here.