March is one of those unusual months in the broadcast regulatory cycle, where there are no routine EEO public file obligations, and no quarterly filing obligations or other regularly scheduled regulatory deadlines. That means that my tardiness in publishing this article before the start of the month did not miss anything important. But, starting next month, there will be a whole new set of deadlines about which broadcasters need to be concerned, as April 1 is when the first pre-filing announcements for broadcast license renewals will begin, signaling the start of the 3-year long radio renewal cycle. The 3-year TV license renewal cycle will begin at the same time next year.
Radio broadcasters in Maryland, Virginia, West Virginia and the District of Columbia will be the first to file their renewal applications – and they will need to start running their “pre-filing” notices on their radio stations beginning on April 1, in anticipation of a June renewal filing (renewal applications to be filed no later than June 3, as June 1 is a Saturday). The FCC has posted a helpful guide to the times that these notices need to run, and a model for the text of these notices, here (although the model text is now outdated, in that it does not acknowledge that stations now have online public files; the FCC has a pending proceeding to modify these public notices that one would hope would be resolved soon – see our articles here and here for details). Stations in the Carolinas begin their pre-filing announcements two months later, with stations in other states to follow at 2-month intervals after that. The schedule for renewals is on the FCC website here, and the pre-filing announcements begin two months before the renewal-filing deadline.