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  • FCC Chairman Carr sent a letter to NPR and PBS announcing that he has asked the FCC’s Enforcement Bureau to
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While the new Republican-led FCC will no doubt tackle many policy issues in the upcoming months (see our article looking at some of the issues that we expect the FCC will address this year), there are also standard dates and deadlines in February to which broadcasters still need to pay attention. Here are some of those dates:

February 3 (as February 1 is a Saturday) is the deadline for radio and television station employment units in Arkansas, Kansas, Louisiana, Mississippi, Nebraska, New Jersey, New York, and Oklahoma with five or more full-time employees to upload their Annual EEO Public File Report to their stations’ online public inspection files (OPIFs).  A station employment unit is a station or cluster of commonly controlled stations serving the same general geographic area having at least one common employee.  For employment units with five or more full-time employees, the annual report covers hiring and employment outreach activities for the prior year.  A link to the uploaded report must also be included on the home page of each station’s website, if the station has a website.  At this time, these reports appear unaffected by any actions by the new FCC.  While Chairman Carr last week issued a statement suspending all DEI efforts by the FCC, that statement did not specifically mention routine broadcast EEO filings so, until they hear otherwise, broadcasters should continue to observe these deadlines. 

The filing of the Annual EEO Public File Reports by radio station employment units with eleven or more full-time employees or TV stations with five or more employees triggers a Mid-Term EEO Review that analyzes the last two Annual Reports for compliance with the FCC’s EEO requirements.  The Mid-Term EEO Review begins February 3 for these larger radio station employment units in Kansas, Nebraska, and Oklahoma.  Television station employment units in Arkansas, Louisiana, and Mississippi are also subject to this review.  Radio stations located in Kansas, Nebraska, and Oklahoma that are part of station employment units with five or more full-time employees must also indicate in their OPIFs whether their employment unit has eleven or more full-time employees, using a checkbox now included in the OPIF’s EEO folder.  This allows the FCC to determine which station groups need a Mid-Term EEO Review.  See our articles here and here for more on the Mid-Term EEO Review.Continue Reading February 2025 Regulatory Dates for Broadcasters – EEO, Comment Deadlines, FM Duplication Rule, Political Windows, and More

  • President Trump issued several Executive Orders that could affect FCC decision-making, including an Executive Order suspending government diversity, equity, and
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With much of everyone’s focus on the outcome of the November 5 general election, broadcasters can’t forget the regulatory dates and deadlines in November and early December.  While the dates and deadlines in November are lighter than in many other months, many routine deadlines do fall in early December, and even the upcoming month does have dates worthy of note. 

The one broadly applicable deadline for AM stations that does fall early in the upcoming month is November 3, when Daylight Savings Time ends.  AM daytime-only radio stations, Am stations with different daytime and nighttime patterns, and those operating with pre-sunrise and/or post-sunset authority should check their sign-on and sign-off times on their current FCC authorizations to ensure continued compliance with the FCC’s rules.  Broadcasters need to note that all times listed in FCC licenses are stated in standard time, not daylight savings time even if it is in effect.

For television stations, there is a deadline later in the month. November 26 is the deadline for television stations to provide an aural description of visual but non-textual emergency information, such as maps or other graphic displays, conveyed outside of station newscasts.  This would include maps showing severe weather and other graphic depictions of emergency information during non-news programming.  Since 2013, stations must make textual information about emergency conditions that occur during non-newscast video programming (such as textual crawls about emergency conditions) audibly accessible to individuals who are blind or visually impaired through having the textual information presented aurally on the station’s SAP channel – the secondary audio channel.  The 2013 rules required that visual maps and other non-textual information also be described on SAP channels but, as we discussed in articles here, here, and here, the FCC has extended this deadline numerous times because of the unavailability of workable technology that can automatically perform the functions required by the rule.  By the November 26 deadline, stations will either need to provide aural information about non-textual emergency information that runs outside of a newscast, or avoid airing such graphical alerts during non-news programming, or hope that there are new requests for FCC relief before the looming deadline.Continue Reading November 2024 Regulatory Dates for Broadcasters: AM Stations Need to Adjust to the End of Daylight Savings Time, Deadline for Aural Description of Visual Emergency Alerts for TV, Final Rules for FM Zonecasting, and More

  • The National Association of Broadcasters denounced recent threats to revoke broadcast station licenses for political reasons, stating: “The threat from
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  • The FCC released its Second Report and Order setting the annual regulatory fees that broadcasters must pay for 2024. 
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For the first time since October, we can say that the federal government is funded for the rest of the fiscal year (through the end of September) so we do not expect to have to report on any threats of a government shutdown for many months. With that worry off our plate, we can look at the dates that broadcasters do need to pay attention to in the month of April.

First, we’ll look at the most significant routine filing deadlines coming up in April.  April 1 is the deadline for radio and television station employment units in Delaware, Indiana, Kentucky, Pennsylvania, Tennessee, and Texas with five or more full-time employees to upload their Annual EEO Public File Report to their stations’ online public inspection files.  A station employment unit is a station or cluster of commonly controlled stations serving the same general geographic area having at least one common employee.  For employment units with five or more full-time employees, the annual report covers hiring and employment outreach activities for the prior year.  A link to the uploaded report must also be included on the home page of each station’s website, if the station has a website.  Be timely getting these reports into your public file, as even a single late report can lead to FCC fines (see our article here about a recent $26,000 fine for a single late EEO report).

The filing of the Annual EEO Public File Reports for radio station employment units in Indiana, Kentucky, and Tennessee with eleven or more full-time employees triggers a Mid-Term EEO Review, where the FCC will analyze the last two Annual Reports for compliance with FCC requirements.  There is no form to file to initiate this review but, when radio stations located in those states with five or more full-time employees are required to upload to their public file their annual EEO Public File Report, they must also indicate in the online public file whether their employment unit has eleven or more full-time employees, using a checkbox now included in the public file’s EEO folder.  This allows the FCC to determine which station groups need a Mid-Term Review.  See our articles here and here on Mid-Term EEO Review reporting requirements for radio stations.Continue Reading April Regulatory Dates for Broadcasters – EEO Reports, Quarterly Issues/Programs Lists, LUC Windows, Rulemaking Comments, and More

  • Congress passed, and the President signed, a continuing resolution to extend funding for the Federal government, including the FCC, averting
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While there are a number of regulatory deadlines scheduled for broadcasters in the month of March, there is also the potential for some of those to shift if we have a federal government shutdown.  As of the date of the publication of this article, we do not know if a federal government shutdown will occur this month, with the FCC and FTC currently being funded only through March 8.  As we recently discussed here, the FCC and other government agencies may have to cease all but critical functions if they do not have any residual funds to continue operations during a shutdown.  Therefore, if Congress fails to extend funding of the FCC and other government agencies past March 8, many of the regulatory deadlines discussed below will likely be postponed. If there is a shutdown, and any of the deadlines below apply to you, be sure to research how the shutdown affects your operations.

There are certain technical deadlines likely not affected by any shutdown.  Those include the requirement that, by March 11, broadcasters using Sage EAS equipment implement the requirement that, when a station receives an over-the-air EAS alert, it must wait at least 10 seconds to determine if a CAP alert has been sent through the IPAWS system and, if it has, the station should rebroadcast that internet-delivered CAP alert rather than the one received over the air.  We wrote more about that requirement on our Broadcast Law Blog, here. For stations using other EAS equipment, the deadline was December 12, 2023 to implement this requirement but as Sage was delayed in pushing out its equipment update, users of that equipment were given until March 11 to comply with this requirement. Continue Reading March Regulatory Dates for Broadcasters – Sage EAS Compliance Deadline, Effective Dates of New FCC Rules, Comment Deadlines, Daylight Savings Time, Political Windows, and More