November is a month where there are no regularly scheduled regulatory deadlines. But the big question for broadcasters may be whether the FCC will continue to function throughout the month. The last-minute continuing resolution passed by Congress on September 30 extended federal government funding through November 17 – which again raises the possibility of a federal government shutdown beginning in late November if Congress does not approve new funding measures for Fiscal Year 2024 by that date. As we discussed in our previous article regarding October Regulatory Dates for Broadcasters, if a government shutdown does occur, 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. In late September, the FCC announced that it had sufficient leftover funds to keep operating for about two weeks after a shutdown. We do not know if those funds are still available, so we need to be watching to see what happens between now and November 17.
Assuming that there is no shutdown, there are a number of other dates that broadcasters should be watching. All broadcasters need to remember that November 20 is the deadline to file their ETRS Form Three to provide more detailed information regarding their stations’ performance during the October 4 Nationwide EAS Test. See our article here regarding this year’s EAS test and broadcasters’ reporting obligations. This deadline is important for many reasons – not just to avoid potential penalties for missing the filing deadline, but also to demonstrate broadcasters’ commitment to the emergency communications system as broadcasters’ role in that system is the principal reason for Congress to be presently considering the bill to require AM radio in every car. See our article here for more on the importance of accurate reporting. Continue Reading November Regulatory Dates for Broadcasters – EAS ETRS Form 3, 12.5 GHz Registrations, C-Band Transition Comment Deadline, a Possible Government Shutdown, and More