Discussion of FCC, copyright, advertising and other legal issues of importance to radio and television broadcasters and other media companies
Here are some of the regulatory developments of significance to broadcasters from the past week, with links to where you can go to find more information as to how these actions may affect your operations.
Yesterday, in our article about the recent FCC random audit of the EEO performance of over 200 radio and TV stations, we noted that the FCC also reviews the EEO performance of broadcasters in connection with complaints, license renewal applications, and at the midpoint of the license period of most TV stations and larger radio operations. The FCC’s Enforcement Bureau, in a Public Notice released yesterday, reminded us that this Mid-Term Review process is about to begin. The FCC will be reviewing the performance of larger radio clusters in Maryland, DC, Virginia, and West Virginia, who are required to upload their Annual EEO Public Inspection File reports to their online public file by June 1. While it is sometimes hard to believe how quickly time has passed, stations in these states are now at the mid-point of their licenses, as their last license renewal applications were filed on or before June 1, 2019.
The FCC’s Mid-Term EEO review in the past was conducted through the filing of a Form 397 Report. That report required that a licensee attach the last two years of EEO Public Inspection file reports and provide a contact person for EEO compliance at the station “employment unit” (a cluster of commonly controlled stations serving the same geographic area sharing at least one employee). In 2019, the FCC did away with that report, finding that the employment reports were already available in station online public inspection files (and that the person responsible for EEO was already identified in the materials submitted with the station’s last renewal application)(see our article here). So instead of filing a form, the FCC will simply review what is already in the public file. But the Mid-Term review is only required for larger radio groups, which required the FCC to implement a settings update in their online public files.…
Here are some of the regulatory developments of significance to broadcasters from the past week, with links to where you can go to find more information as to how these actions may affect your operations.
Here are some of the regulatory developments of significance to broadcasters from the past week, with links to where you can go to find more information as to how these actions may affect your operations.
Here are some of the regulatory developments of significance to broadcasters from the past week, with links to where you can go to find more information as to how these actions may affect your operations.
April brings to an end the four-year license renewal cycle that began in 2019 with the filing of renewals by radio stations in the Washington DC area. Our monthly updates, like this one, will thus not be highlighting license renewal dates again until mid-2027. But there are always other regulatory dates which broadcasters need to note. There are EEO Public File reports due in April for certain states (as they are every other month), the requirement for all full-power broadcast stations to upload to their public file their Quarterly Issues Programs Lists, and there are a number of rulemaking comment deadlines of interest to broadcasters. So, let’s look at some of the important regulatory dates for broadcasters in April.
As April 1 is a Saturday, April 3 is the deadline by which television stations, LPTV stations, TV translators and Class A stations in Delaware and Pennsylvania must file their license renewal applications, bringing to a close the current TV license renewal cycle. Renewal applications must be accompanied by FCC Form 2100, Schedule 396 Broadcast EEO Program Report (except for LPFMs and TV translators). Stations filing for renewal of their license should make sure that all documents required to be uploaded to the station’s online public file are complete and were uploaded on time. Be sure to read the instructions for the license renewal application and consult with your advisors if you have questions, especially if you have noticed any discrepancies in your online public file or political file. Issues with the public file have repeatedly led to fines imposed on broadcasters during renewal cycles.…
Here are some of the regulatory developments of significance to broadcasters from the past week, with links to where you can go to find more information as to how these actions may affect your operations.
Here are some of the regulatory developments of significance to broadcasters from the past week, with links to where you can go to find more information as to how these actions may affect your operations.
Here are some of the regulatory developments of significance to broadcasters from the past week, with links to where you can go to find more information as to how these actions may affect your operations.
March may not have any of the regular FCC filing deadlines, but there are still plenty of regulatory activities going on this month that should grab the attention of any broadcast or media company. Initially, there are several FCC proceedings in which there are dates in March worth noting.
Initially, there are comments in the 2022 Quadrennial Review of the FCC’s ownership rules. As we wrote in our summary of the issues on which comments are requested when it was released in late December, the proceeding is to look at rules including the local radio ownership rules, the dual network rule (prohibiting the combination of two of the big four TV networks), and other rules not yet resolved. The FCC is charged with determining every four years whether these rules continue to be in the public interest. Even though the FCC has never finished the 2018 Quadrennial Review examining these same issues, the FCC nevertheless asks for comments on how these rules affect FCC policies including competition, localism, and diversity. Comments in this proceeding are due March 3, with reply comments due March 20. …
