When providing briefings on FCC issues at a number of broadcast conventions in the past few months, I find that broadcasters are most often surprised by the relatively new FCC rule that requires that they verify that any buyer of programming time on their station is not an agent of a foreign government.  This week, the burden that this rule (about which we wrote here) imposed on broadcasters was eased, when a Court overturned one aspect of the obligations imposed by the FCC.

The FCC rule, Section73.1212(j), is designed to ensure that all broadcast programming that is paid for or sponsored by a foreign government or one of its agents is specifically identified on the air as having foreign government backing.  The FCC required specific wording for on-air identifications for this programming paid for or produced by foreign governments or those that they finance.  In addition, broadcast stations are required to get assurances in writing from all parties who pay for programming on their stations that the programmer is not a foreign government or an agent of any such government.  The FCC rule went further, requiring that each station verify by checking FCC and DOJ databases that any programmer who certified that they were not a foreign government agent was in fact not a government agent.  It was that last requirement – the requirement to check DOJ and FCC databases – that the Court rejected this week. Continue Reading Court Overturns Part of FCC Requirement that Broadcasters Confirm that Programmers are Not Foreign Government Agents

The FCC in recent years has been upgrading their technical systems (even though, as many broadcasters and their attorneys know, the upgrades are often not without their own problems).  The old CDBS database, in which broadcasters for years filed their applications, is shut down for all new filings as almost all broadcast applications have migrated to the new Licensing and Management System (“LMS”) database system.  Another transition date is almost upon broadcasters as the FCC announced months ago that it will be decommissioning its legacy Commission Registration System (“CORES”) at 6 pm EST on July 15.  We’ve written about that deadline in several weekly updates and in our post looking ahead at July regulatory dates for broadcasters.  But with the date almost upon us, it is important to remind broadcasters to register in the new system by the July 15 deadline. By that deadline, each person associated with your licensee’s FCC Registration Number (“FRN”), including those who prepare or submit your FCC filings or submit your annual FCC regulatory fees, should register in its new CORES2 database by setting up an account and then associating their account with the relevant FRN.  Once legacy CORES is retired, you will only be able to access FCC filing and payment systems using a CORES2 user account. See the FCC webpage with information about the transition here.

The new CORES2 system contains the same FRN information as the legacy system (found here ). The change to CORES2 will impact how individuals, licensees and other entities doing business before the FCC obtain and manage their FRNs, and will also affect access to various FCC databases, including the LMS used for preparing and filing routine FCC applications and reports.   To maintain access to the information in CORES, all licensees need to register in the new system.  Tutorial videos on navigating CORES2 can found here. Continue Reading FCC Database Transitions – Are You Ready for the New CORES on July 15? Did You Know Call Sign Reservation Has Moved?

In recent months, lawsuits have been filed against streaming audio service Pandora by comedian Lewis Black, the estate of Robin Williams, and representatives of other comedians seeking public performance royalties for the underlying comedic work – not the recording of the comedy bit for which a royalty is already paid, but instead for the script of that comedic performance.  Reportedly, Spotify has pulled comedy recordings from its service to avoid such threats.  What is the issue here?  The claim in the lawsuits is that the authors of the script of any comedy bit have the right to control the performance of their works in the same way that composers of a song control the rights to use that song.  The argument is that, if these services are playing these comedy bits through a digital audio performance, not only do the comedians who are recorded performing such bits deserve a royalty, but a separate royalty should also be paid to those who wrote it.

In these lawsuits, the analogy is made to the copyrights for the performance of a song.  For music streamed by any digital audio company, there are two royalties that must be paid.  The composers of the music are paid for the performance of their work (both in the digital and analog worlds).  These payments are usually made through a performing rights organization (a “PRO”) which represents thousands (or sometimes millions) of composers and their publishing companies.  ASCAP, BMI and SESAC are the traditional PROs who, for radio and television, all have their rates reviewed for fairness under antitrust laws.  As we have written (see for instance our articles here and here), a new PRO for musical works, GMR, has recently settled litigation with the Radio Music License Committee and is assessing most commercial radio stations a royalty for the performance of music by the composers that it represents.  For digital performances, a royalty is also owned for the performance of the sound recording – the composition as recorded by a singer or band.  Through an act of Congress, all noninteractive digital performances (see our article here on the difference between interactive and noninteractive services) can be played by a digital music service by paying a “collective” that acts like a PRO by collecting royalties from those services that transmit the music to their listeners and distributing those royalties  to the performers and their record labels (as the labels usually own the copyright in the recording).  Since the sound recording digital performance royalty was first collected about two decades ago, SoundExchange has served as the “collective.”  The lawsuits by the comedians seek to collect these dual royalties from digital services that transmit comedy recordings to their listeners.  Why is this not covered by the royalties that services already pay? Continue Reading Public Performance Royalties for Comedy Recordings? – New PROs Claim that Additional Royalties Are Due

Here are some of the regulatory developments of significance to broadcasters from the past two weeks, with links to where you can go to find more information as to how these actions may affect your operations.

  • The FCC has issued a Public Notice confirming the comment and reply comment dates for its Third Further Notice of Proposed Rulemaking on the adoption of ATSC 3.0. Comments are due August 8, 2022, and reply comments are due September 6, 2022.  As we reported in our last weekly update, the Third Further Notice seeks comment on the status of the Next Gen TV rollout and on certain specific issues including (1) the scheduled 2023 sunset of the requirement that a Next Gen TV station’s ATSC 1.0 simulcast primary video programming stream be “substantially similar” to its 3.0 primary programming stream, (2) the scheduled 2023 sunset of the requirement that a Next Gen TV station comply with the current ATSC A/322 technical standard, and (3) whether the FCC needs to take any action to insure that the patent rights in ATSC 3.0 technologies are being fairly licensed.
  • The FCC’s Public Safety and Homeland Security Bureau issued a Public Notice offering assistance to any State Emergency Communications Committee that had not filed an updated State EAS Plan with the FCC. These updated EAS plans were due to be filed on July 5.  Broadcasters should insure they understand how any changes to their state’s plan affect their EAS obligations, including whether any changes have been made to the stations that they are to monitor to receive EAS alerts in their area.
  • The FCC issued its final agenda for next week’s monthly open meeting on July 14, 2022. As we have previously reported, the FCC is scheduled to consider whether to adopt a Notice of Proposed Rulemaking seeking comment on whether to update its rules to identify a new Nielson publication for determining a television station’s designated market area (“DMA”) for satellite and cable carriage purposes, and an Order and Sixth Notice of Proposed Rulemaking on the TV digital conversion. The Order and Sixth Notice of Proposed Rulemaking would update the FCC’s rules to eliminate analog rules to reflect the recent termination of analog operations by LPTV and television translator stations.
  • July 18, 2022 is the reply comment deadline for the FCC’s Notice of Proposed Rulemaking on the FCC’s proposed regulatory fees for fiscal year 2022. In initial comments filed this week, the NAB argued that the FCC’s methodology for imposing the fees on broadcasters was inexplicable as it raised fees on broadcasters by 13% while the FCC budget which the fees are to reimburse only increased by 2.1%.  The NAB made specific arguments as to where it believes the FCC misallocated its costs to broadcasters when computing the fees.  The state broadcast associations jointly filed comments expressing many of the same concerns.  The fees that the FCC is proposing for television and radio stations are set forth in Appendix C and Appendix G of the NPRM.  In the NPRM, the FCC specifically sought comments on the mechanism it uses to calculate the regulatory fees for television stations based on the population-based methodology it adopted several years ago.  While no specific issues on radio fees were teed up for comment by the NPRM, the broadcasters’ comments, as noted above, complain that the fees as proposed are too high.
  • The FCC issued a Public Notice with its quarterly summary of the number of broadcast stations in the country. This notice shows that the number of full-power and Class A TV stations is almost identical to that shown in the pre-pandemic June 2019 Public Notice.  There are about 135 fewer full-power radio stations, principally due to there being over 200 fewer AM stations.
  • The FCC’s Media Bureau entered into five consent decrees with radio licensees to resolve investigations into their online political files. In all five cases (available here, here, here, here and here), the licensees admitted that they had failed to timely place records of all requests for the purchase of political broadcast time in their political files in a timely manner, in violation of section 315(e)(3) of the Communications Act and Section 73.1943(c) of the FCC’s rules.  Noting, however, the licensees’ disclosures in their license renewal applications and the financial stress suffered by the radio industry due to the COVID pandemic, the Bureau did not impose financial penalties on the licensees, opting to only require them to implement a comprehensive compliance plan.  The continuing issuance of these consent decrees and their paperwork obligations reminds broadcasters of the importance that the FCC places on orders for political time being uploaded immediately (within one business day) into the political broadcasting section of a station’s online public inspection file.

The lazy days of summer continue to provide little respite from the regulatory actions of importance to broadcasters.  The good news is that there are no license renewal or EEO  deadlines during the month of July.  Nonetheless, there will be a number of July deadlines that require attention.

On July 1, comments are due on the FCC’s Office of Economics and Analytics annual call for comments on the State of Competition in the Communications Marketplace (see the Public Notice calling for these comments). The comments are used to prepare a report to Congress on communications competition issues and are sometimes referenced by the FCC itself in proceedings dealing with competition issues.  The FCC seeks comments on a list of questions about competition in both the Video and Audio marketplaces, including the impact of digital competitors on traditional providers and the role that regulation plays in the competitive landscape.  Reply comments are due August 1.

July 5 and July 18 are the comment and reply comment deadlines, respectively, for the FCC’s Notice of Proposed Rulemaking on the FCC’s proposed regulatory fees for fiscal year 2022.  The fees that the FCC is proposing for television (full power and otherwise) and radio stations are set forth in Appendix C and Appendix G of the document.  The FCC is proposing an increase of approximately 13% for radio broadcasters.  Among other things, the FCC proposes to continue to assess fees for full-power broadcast television stations based on the population covered by a full-service broadcast television station’s contour, and it seeks comment on its mechanism for calculating the regulatory fee based on the this population-based methodology.  These fees will be set by the end of August or very early September, to be paid before the October 1 start of the government’s new fiscal year. Continue Reading July Regulatory Dates for Broadcasters:  Quarterly Issues/Programs Lists and Other Public File Obligations, Lowest Unit Charge Periods, License Renewal, Copyright Filings and More

Here are some of the regulatory developments of significance to broadcasters from the last week, with links to where you can go to find more information as to how these actions may affect your operations.

  • The FCC has released a draft Notice of Proposed Rulemaking that, if adopted at the FCC’s July 14, 2022 regular monthly open meeting, would seek comment on whether to update its rules to identify a new publication for determining a television station’s designated market area (“DMA”) for satellite and cable carriage purposes. Current FCC rules direct commercial TV stations to use Nielsen’s annual Station Index Directory and Household Estimates to determine their DMA, and stations rely on these determinations when they seek carriage on cable and satellite systems.  The proposed rule changes would remove references to the now defunct annual Station Index and Household Estimates and instead direct broadcasters to Nielsen’s Local TV Report.
  • The FCC released a Third Further Notice of Proposed Rulemaking in which it seeks comment on the state of the Next Generation Television, or ATSC 3.0, transition and on the scheduled sunsets of two rules adopted in 2017. First, the FCC seeks comment on the progress of broadcasters’ voluntary, market-driven deployment of ATSC 3.0 service and the current state of the ATSC 3.0 marketplace. The first rule on which the FCC seeks comment is the scheduled 2023 sunset of the requirement that a Next Gen TV station’s ATSC 1.0 simulcast primary video programming stream be “substantially similar” to its 3.0 primary programming stream. The FCC also seeks comment on the scheduled 2023 sunset of the requirement that a Next Gen TV station comply with the current ATSC A/322 technical standard.  Additionally, the FCC seeks comments on whether the technology for ATSC 3.0 has been made available on fair terms by the patent holders for that required technology.  Comments and reply comments will be due 30 and 60 days, respectively, after publication of the Third Further Notice of Proposed Rulemaking in the Federal Register.
  • In an Order released on June 22, 2022, the FCC restores clarifying language that was inadvertently eliminated almost 40 years ago from section 73.3527 of the FCC’s rules. The clarification relates to applicants, permittees, or licensees whose existing or prospective facilities are Class D FM stations or other educational stations that are wholly “instructional” in their programming.  Class D stations are noncommercial stations that operate with 10 watts on commercial channels.  Instructional stations are those used by schools wholly for student instruction or teacher training. This clarification makes clear that Class D and Instructional stations are exempt from the obligation to complete Quarterly Issues Programs Lists.
  • The FCC has released a draft Order and Sixth Notice of Proposed Rulemaking, which, if adopted at the FCC’s July 14, 2022 open meeting, would update the FCC’s rules to reflect the recent termination of analog operations by LPTV and television translator stations. The Order would (i) delete or revise rules that no longer have any practical effect given the completion of the LPTV/translator digital transition, or that are otherwise obsolete or irrelevant, and (ii) make certain ministerial changes, for example, to delete analog rules that were found in Part 74, and to add definitions and other information previously adopted in prior rulemaking proceedings. The Sixth Notice of Proposed Rulemaking would seek comment on updates to rules which reflect the digital transition, current technology, and/or Commission practices.
  • In a Memorandum Opinion and Order, the FCC’s Media Bureau entered into a Consent Decree, which included a $1500 monetary penalty, with a licensee who admitted that it had transferred control of its station to a time broker during the course of a time brokerage agreement. The licensee admitted in FCC filings that there were times when it was unfamiliar with the programming and operations of the station.  FCC rules require that a licensee maintain ultimate control of all aspects of a station’s operations, even if another entity is providing programming and sales services.
  • The FCC announced the winners of the auction of construction permits for 18 new full-power television stations. The highest winning bid was just over $6.4 million for a new station at Grand Forks, ND. Winning bids of over $4 million were received for construction permits authorizing new stations at Freeport, IL; Alexandria, MN; and Flagstaff, AZ.  The full list of winning bids is available here, and the FCC public notice setting out the post-auction proceedings that are required before permits are issued is available here.

Here are some of the regulatory developments of significance to broadcasters from the last week, with links to where you can go to find more information as to how these actions may affect your operations.

  • Comment dates have been announced in the Federal Register for the FCC’s Notice of Proposed Rulemaking proposing to authorize LPTV stations operating on TV channel 6 to continue to provide an analog audio stream that can be received on FM radios at 87.7. Comments are due July 18, 2022; reply comments are due August 1, 2022.  The proposal would limit that authorization in many ways, including suggesting that the authority would be restricted to those LPTV Channel 6 stations already providing such an audio service.  The Notice also asks for comments as to whether Channel 6, in geographic areas where it is not currently used for TV services, should be repurposed for FM use (a proposal that has previously been advanced by the FCC, see our Broadcast Law Blog article here on previous FCC requests for comment on this issue).
  • The Radio Music License Committee has asked a single court to decide what a reasonable license fee would be for royalties owed by commercial broadcasters to both ASCAP and BMI. Both the ASCAP and BMI licenses with the radio industry expired at the end of 2021.  As both ASCAP and BMI routinely argue in license proceedings that they have the largest share of the music played by radio stations, RMLC suggests that a combined case, arguably permitted for the first time by the Music Modernization Act, would allow for this issue to be decided in a uniform way by a single judge.  See the RMLC press release for more information.
  • The FCC’s Video Division proposed to fine a television translator permittee $6500 for filing an application for a license to cover its displacement construction permit over three years after completing construction and nearly six months after its permit expired. As no license had been filed before the permit expired, this fine also covered the unauthorized operation of the station during the six months after the permit expired. The mere fact that the FCC’s database did not reflect the cancellation of the permit after its expiration did not excuse the late filing.  When completing construction of new facilities authorized by a construction permit, a broadcaster must file a license application demonstrating that construction was completed as authorized by the permit.
  • Issues with a license application resulted in the FCC’s Audio Division rescinding the license of an FM translator. The FCC found that the licensee had falsely stated in its license application that it had completed construction at its authorized location.  The licensee had instead constructed its facilities in a recreational vehicle (“RV”) park approximately 30 yards away from its authorized site, receiving power through a permanent electric outlet shared with an RV.  The FCC emphasized that “[c]onstruction permits expire automatically and are forfeited if the facilities authorized therein are not completed by the established deadline; use of an alternate site or construction of temporary facilities does not prevent such forfeiture.” As an alternate basis for rescission, the FCC also found that the licensee had failed to comply with a condition in its license requiring continuous operation for the first year and establishing that station silence within that period evidenced unlicensable, temporary construction (the Media Bureau has placed this condition on all new radio broadcast licenses since 2015 to address perceived abusive practices in the industry).  As evidence of the temporary construction, the FCC cited, among other things, the fact that RVs are inherently mobile and also noted the absence of any written lease with the RV owner or any agreement with the landowner of the RV park.
  • The FCC’s Video Division also proposed to fine a full power television licensee $6,000 for failing to timely file its quarterly issues/programs lists and failing to report these violations in its license renewal application. Specifically, the licensee uploaded one list to its online public inspection file more than one year late, and seven lists between one month and one year late. The FCC also found, however, that the licensee’s violations did not constitute a “serious violation” warranting designation of the license renewal application for hearing, it would grant the license renewal application at the conclusion of the forfeiture proceeding if there were no other issues with the application.
  • The FCC’s Enforcement Bureau issued Notices of Illegal Pirate Radio Broadcasting to two property owners for allegedly hosting unlicensed FM broadcast stations in Queens, New York and Newark, New Jersey, respectively. The Notices each included the following language: “[Y]ou are hereby notified and warned that the FCC may issue a fine of up to $2,000,000 if, following the response period set forth below, we determine that you have continued to permit any individual or entity to engage in pirate radio broadcasting from the property that you own or manage.”

 

Here are some of the regulatory developments of significance to broadcasters from the last week, with links to where you can go to find more information as to how these actions may affect your operations.

  • The FCC this week announced that in-person meetings at its new headquarters building will now be allowed – though only when scheduled in advance and subject to COVID protocols. (Public Notice of Reopening and Public Notice on COVID Protocols).  The FCC had been closed to outside visitors since March 12, 2020.  In the interim, it moved to a new building.  The FCC plans its first in-person meeting open to the public in July.
  • The FCC announced that requests for changes in the call letters of broadcast stations, previously requested in a stand-alone database, will be requested through the LMS database as of June 22, 2022. The old call letter reservation system will be decommissioned.  Procedures for using LMS to request call letter changes are set out in the FCC’s Public Notice released this week (Public Notice).
  • The FCC adopted the Notice of Proposed Rulemaking asking for public comment on a proposal to authorize LPTV stations operating on TV channel 6 to continue to provide an analog audio stream that can be received on FM radios at 87.7. Its proposal would limit that authorization in many ways, including suggesting that the authority would be restricted to those LPTV Channel 6 stations already providing such an audio service.  The Notice also asks for comments as to whether Channel 6, in geographic areas where it is not currently used for TV services, should be repurposed for FM use (a proposal that has previously been advanced by the FCC, see our Broadcast Law Blog article hereon previous FCC requests for comment on this issue).  Comment dates will be announced by a Federal Register publication (Notice of Proposed Rulemaking).
  • The FCC issued a reminder that all invoices for amounts that can be reimbursed from the TV Broadcaster Relocation Fund for costs incurred because of the incentive auction must be filed by September 6. These remaining requests are due from LPTV stations, MVPDs, and FM stations affected by the repacking of the television band following the incentive auction (FCC Reminder).
  • The FCC’s new rules authorizing computer modeling for FM directional antennas was published in the Federal Register. Those rules go into effect on July 11, 2020.
  • EAS rules adopted last year, providing for the regular filing of updated state EAS plans and their approval by the FCC, became effective earlier this week after approval of their paperwork collection requirements. State EAS committees should review and update their plans as required by these new rules (Public Notice).
  • In a decision released this week in a dispute between two radio companies over the appropriate compensation due to a broadcaster who was forced to change channels on its FM station to accommodate the upgrade in the facilities of another broadcaster’s FM station, the FCC clarified what expenses were appropriately the subject of a reimbursement request. The FCC allows one FM broadcaster who wants to upgrade its facilities to obtain an FCC order changing the channel of another broadcaster (at its same site and power) as long the upgrading broadcaster pays the reasonable costs of the broadcaster being forced to change channels.  This decision helps to clarify what expenses are considered reasonable.  (Decision)
  • The FCC proposed to fine a public broadcasting company for incomplete public inspection files at four of its television stations. These deficiencies were discovered by the FCC during the license renewal process.  They had not been reported by the broadcaster even though the renewal application asks for a certification as to whether the broadcaster was timely in uploading materials to its public file.  Two of the broadcaster’s stations are proposed to receive fines of $6000 for the violations, and two would receive $9000 fines.  The deficiencies that were identified by the FCC included instances where a station had three Quarterly Issues Programs lists that were uploaded over a year late and four lists uploaded between one month and one year late ($9000 fine, $6000 fine).  These decisions demonstrate that the Video Division is fining stations for violations of its public file rules, where the Audio Division, for the most part dealt with such violations discovered during the license renewal process through consent decrees.
  • The Federal Trade Commission initiated a proceeding to update its guidelines on preventing digital deception. The proceeding looks at issues including online sponsorship identification and other disclosures in advertising, with the FTC fearing that disclosures often were not evident to consumers when available only though multiple hyperlinks or otherwise did not provide clear information to consumers.  Comments are due by August 2, 2022. (Press Release, Request for Comments)

 

Here are some of the regulatory developments of significance to broadcasters from the last week, with links to where you can go to find more information as to how these actions may affect your operations.

  • The FCC issued its Notice of Proposed Rulemaking proposing the annual regulatory fees to be paid by September 30, the end of the government’s fiscal year, by broadcasters and others regulated by the FCC. Public comment on the FCC’s proposal is due July 5, 2022, with replies due by July 18 (Notice of Proposed Rulemaking). The NAB issued a statement attacking the proposed 13% increase in the fees to be paid by radio stations as “an unjustified increase” that would be “devasting” to local radio services (NAB Statement).  A decision on the final amount of the proposed fees is routinely released in late August or very early September so that fees can be paid before the October 1 start of the new fiscal year.
  • In connection with the proposed acquisition of the Tegna TV stations by Standard General, L.P., the FCC issued a letter request asking for significant additional information about the pending application – including documents submitted to the Department of Justice in connection with the Hart-Scott-Rodino filing that seeks antitrust approval for the deal. The HSR documents include internal memos and documents submitted to funding sources that outline the competitive impact of the proposed transaction. The FCC request also asks for a description of the public interest benefits of the proposed transaction, and the impact it would have on employment at the stations to be acquired (FCC Request).  This is information not routinely sought by the FCC in the assessment of a broadcast acquisition.
  • The FCC’s Enforcement Bureau issued another letter to a landowner in Baltimore whose property was believed to be home to a pirate radio operation. The letter gives the property owner 10 days to respond, and notes that hosting a pirate radio station can lead to a $2,000,000 fine (Letter).  We recently wrote on our Broadcast Law Blog, here, about other landowners who received similar letters when they were identified as hosting pirate radio operations.
  • Following Federal Register publication, new FCC rules became effective, making it clear that broadcasters and cable companies have obligations to post information to their online public file about advertising that runs on their stations addressing federal issues (Public Notice). As we wrote here when these rule changes were initially announced, they have little practical effect as their requirements were already spelled out in the Communications Act, and the FCC already enforced the Act’s requirements.  The changes just made the FCC’s rules conform to the language of the Act.
  • The FCC’s Further Notice of Proposed Rulemaking on unlicensed “white spaces” devices that operate in the TV Band was published in the Federal Register, setting the deadline for public comment as July 1, with reply comments due August 1 (Federal Register). The FCC earlier this year adopted new rules that require fixed and certain personal/portable white space devices to check white space databases at least once per hour for other spectrum users to be protected from interference, replacing a prior rule that had not been enforced requiring the databases to push information to white spaces devices whenever there was a new wireless microphone or other protected use in the area in which the white space device was operating.  This Further Notice seeks comments on whether “unlicensed narrowband white space devices” should be subject to the same hourly requirement to check white space databases as other users or whether some other monitoring obligation should apply.

With the traditional beginning of summer upon us, there is no vacation from the regulatory actions of importance to broadcasters.  Let’s start with the routine actions for the upcoming month.  With the radio license renewal cycle having ended with the filing of the last set of renewal applications in April, we enter the last year of the cycle for television.  Renewals applications for Full-Power Television, Class A, LPTV and TV Translator Stations in Arizona, Idaho, Nevada, New Mexico, Utah and Wyoming are due on June 1.  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.  Note that your Broadcast EEO Program Report must include two years of annual EEO public file reports for FCC review, unless your employment unit employs fewer than five full-time employees.  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 already led to fines imposed on TV broadcasters during this cycle.

Also, on or before June 1, all radio and TV station employment units (a station employment unit is a station or stations that are under common control, share at least one full-time employee, and are in the same geographic area) with five or more full-time employees licensed to communities in Arizona, District of Columbia, Idaho, Maryland, Michigan, Nevada, New Mexico, Ohio, Utah, Virginia, West Virginia, and Wyoming must upload to their online public inspection file an Annual EEO Public File report.  This report covers hiring and employment outreach activities for June 1, 2021 through May 31, 2022.  These licensees must also post on the homepage of their station website (if they have one) a link to the most recent report. Continue Reading June Regulatory Dates for Broadcasters:  TV Renewals, EEO Public File Reports, Comments on Zonecasting, Start of Channel 6 FM Rulemaking and More