March is one of those rare months on the broadcast calendar when there are few routine regulatory deadlines for broadcasters. As we are winding down in the television license renewal cycle, the month’s only license renewal obligations for TV broadcasters are the pre-filing license renewal announcements on the 1st and 16th of the month for stations in Delaware and Pennsylvania, whose renewals are due on April 1, and the post-filing announcements for TV stations in New York and New Jersey. But there are still dates of interest to broadcasters in the month ahead. Here are some of those dates.
March also brings the obligation, by March 16 for TV stations to be in compliance with the Closed Captioning Quality Standards, which require that broadcasts assess and work to perfect the quality of the closed captioning carried on their stations. While the FCC is looking at bringing television program suppliers under these rules, as of now, the obligation for compliance with the rules is on the television broadcaster. We wrote about the captioning quality rules and the FCC’s recent proceeding to shift some of the burden to program suppliers here.
Comments are also due this month in several FCC proceedings that affect broadcasters. Tomorrow, March 3, brings the extended date for comments on whether to bring providers of online “linear” video programming under FCC rules for MVPDs like cable and satellite TV. We wrote about that proceeding here. On March 16, comments are due on the FCC’s proposal to extend the online public inspection file obligations to radio, cable and satellite radio and TV operators. Our summary of that proceeding can be found here.
Comments are also due today on the FCC proceeding looking at “Last In First Out” preemption practices for advertising sales, and how those practices relate to the purchase of advertising time by political candidates. See our summary of the issues, here. Reply comments are due March 17. And, finally, the FCC has just announced that comments are due on March 30 in its proceeding to create special-use FCC Registration Numbers (“FRNs”) to be used by a broadcaster in Biennial Ownership Reports to identify attributable owners who are unwilling to provide their Social Security Numbers to the FCC (a proceeding which we summarized here).
April 1 brings Quarterly Issues Programs Lists as well as a host of Annual EEO Public File Report obligations (and, for those stations hit by the recent EEO Audit, see our article here, remember your responses are due on March 24). So, while March is a somewhat light month on regulatory obligations for broadcasters, don’t relax as there are always plenty of FCC actions for which you need to be ready. See our Regulatory Calendar for Broadcasters for a look ahead at future obligations.