Another month has started – and it is one with regulatory dates for broadcasters. All broadcasters, commercial and noncommercial, have an obligation to complete their Quarterly Issues Programs lists and place them into their public inspection filed by October 10. For TV stations and large-market commercial radio, that means that these lists need to be in the online public file by that date (see our article here about the online public file for radio). For TV stations, the 10th also brings the obligation to submit Quarterly Children’s Television Reports on Form 398 to the FCC (as the 10th falls on a Federal holiday, you may be able to file on the 11th, but consult your legal advisor for details on that deadline).

For stations in Alaska, Florida, Hawaii, Iowa, Missouri, Oregon, Washington, American Samoa, Guam, the Mariana Islands, Puerto Rico, Saipan, and the Virgin Islands that are part of employment units with 5 or more full-time employees (30 hours a week or more), EEO public inspection file reports should have been included in their public inspection file by October 1. For Radio Station Employment Units with 11 or more full-time employees in Iowa and Missouri and Television Employment Units with five or more full-time employees in Florida, Puerto Rico, and the Virgin Islands, Mid-Term EEO Reports on FCC Form 397 should also have been filed at the FCC by October 1. See our article here on the obligation to submit Mid-Term EEO Reports.

Noncommercial Television Stations in Alaska, Florida, Hawaii, Oregon, Washington, American Samoa, Guam, the Mariana Islands, Puerto Rico, Saipan, and the Virgin Islands and Noncommercial AM and FM Radio Stations in Iowa and Missouri should have filed their Biennial Ownership Reports on FCC Form 323-E by October 1. As we have written before, while noncommercial stations by next year are expected to have Biennial Ownership Report filing deadlines at the same time as those for commercial stations (on December 1 of odd-numbered years), that order has not yet gone into effect so the old obligations remain.

Probably the most meaningful comment deadline for broadcasters is the October 31 deadline for comments on the proposed Post-Incentive Auction Repacking plan for TV stations, released by the FCC last Friday.  Comments are due on October 31 on the FCC’s proposal for conducting the repacking in geographic stages over 39 months.  Reply comments on this proposal are due on November 15.  The FCC also released a public notice asking for beta testing of its post-auction system to be used by TV stations applying for reimbursements of expenses they incur after being repacked following the incentive auction.  Comments are due on that system by November 4.  The Phase 2 Reverse Auction, where TV stations accept bids presented by the FCC to vacate their channels so that the TV band can be compacted and parts of it repurposed for wireless communications uses, will likely be concluded this month.  The Phase 2 Forward Auction, where wireless companies bid on the spectrum proposed to be vacated by broadcasters, will begin soon after the Reverse Auction is complete.

As in any month, there may be other deadlines that are faced by any broadcaster – so be aware of those that apply to you. And, as always, be aware of all your compliance deadlines to avoid any FCC issues.