July is a big month on the Washington regulatory scene for broadcasters. There are, of course, the routine quarterly regulatory obligations. For all stations, commercial and noncommercial, Quarterly Issues Programs Lists, summarizing the most important issues facing a broadcaster’s community, and the programs that were broadcast in the prior quarter to address those issues, must be in a station’s public file (the online public file for all TV stations and for radio stations that have already converted to the online file) by July 10. These are the only required records documenting a station’s service to its community, so do not forget to complete these reports and to timely place them in your public file.
Children’s Television Reports documenting the educational and informational programing broadcast by TV stations to meet their obligation to program at least three hours a week of such programming for each program stream are due to be filed at the FCC by July 10. Also, TV stations must place into their public file documentation showing that they have met the advertising limits imposed on commercials during children’s programming.
Beyond these routine FCC obligations, TV broadcasters must also start, as of July 1, captioning clips of live or near-live TV programming used on their websites or mobile apps. This is a continuation of the obligation of TV stations to caption over-the-air programming repurposed to a station’s website or mobile application. See our article here for more on this obligation.
Comment dates in two important broadcast proceedings are also due in early July. Broadcasters can file comments on the FCC proposal to eliminate the main studio rule by July 3 (see our articles here and here). Also, the FCC is looking for comments in its Modernization of Media Regulation Proceeding, which are due on July 5. In this proceeding, the FCC has invited broadcasters to submit their comments proposing the elimination or modification of any broadcast rule (other than ownership limits) that the broadcaster no longer thinks is necessary or in the public interest. See our ideas on some of the rules that could be changed here. This is a once-in-a-lifetime chance to effect real change in broadcast regulations – so file comments now.
For TV stations involved in the repacking of the TV band, construction permit applications and summaries of the expenses that they expect to incur in the transition to their new channels are due on July 12. If TV stations want to get promptly reimbursed for their expenses in changing channels, or if they have problems with the channels assigned by the FCC for the repacking, July 12 is the date by which they need to file their paperwork with the FCC. See our article here.
Finally, in this very busy month, AM radio stations that want a new FM translator, and did not file for one last year using the 250-mile waiver provision of the AM Revitalization Proceeding, have the opportunity to file for a new translator in the upcoming window that runs from July 26 to August 2. See our summary of the rules for that window here and here.
These are but some of the regulatory highlights of the upcoming month. Every station should insure that they meet these and other obligations that may apply to them in this month, and in every other month during the year, to stay out of trouble with the FCC and other regulatory agencies that govern their conduct.