While May is one of those months that does not have any routine, scheduled FCC filing deadlines, there are still a number of regulatory dates and deadlines that are worthy of note for broadcasters.  As detailed below, this includes comment deadlines in several FCC rulemaking proceedings, the effective date of the FCC’s application fee increases (including fees for broadcast station applications), the deadline for LPTV to Class A conversion applications, and the tentative deadline for TV stations to begin complying with the FCC’s audible crawl rule if it is not extended again.  As always, remember to keep in touch with your legal and regulatory advisors to make sure that you don’t overlook any other regulatory deadlines we may have missed here or ones that are specific to your station.

One May date with potential broad interest is May 23 – the effective date of the FCC’s January Order increasing its application fees by an average of more than 17%, including those for broadcast station applications, to reflect changes in the Consumer Price Index.  We previously provided more details on our Broadcast Law Blog on the increases and suggested that, where possible (e.g., in connection with internal company reorganizations or for planned technical changes), broadcasters file applications as soon as possible to beat the implementation of these increased fees.Continue Reading May 2025 Regulatory Dates for Broadcasters – Comment Deadlines on ATSC 3.0 and EAS, Application Fee Increases, Audible Crawl Rule, Political File Windows, and More

In odd years like 2017, most broadcasting stations don’t think about the FCC’s political broadcasting rules. But they should – both for special elections to fill open seats in Congress, and for state and local political offices.  Recently, I have received a number of calls about elections to fill seats in Congress that were vacated by Congressmen appointed to positions in the Trump administration. For instance, the race in Georgia to fill HHS Secretary Tom Price’s seat has received much national attention. But there is also a race being fought now to fill Interior Secretary Ryan Zinke’s seat in Montana. Obviously, for Federal elections like these, broadcast stations serving these districts need to offer candidates the full panoply of candidate rights – including reasonable access, lowest unit rates, and equal opportunities. But in other parts of the country where there are no special Congressional elections, there are all sorts of political races taking place in this off year and, as we have written before, most of the political rules apply to these state and local electoral races as well as to the few Federal elections that are taking place to fill open Congressional seats.

Some of these races will be high-profile, like the governor’s elections in Virginia and New Jersey and several big-city mayoral races. Some races may be much more locally focused on elections to school boards or town councils. Stations need to be prepared. Candidates for state and local elections are entitled to virtually all of the political broadcasting rights of Federal candidates – with one exception, the right of reasonable access which is reserved solely for Federal candidates. That means that only Federal candidates have the right to demand access to all classes and dayparts of advertising time that a broadcast station has to sell. As we wrote in our summary of reasonable access, here, that does not mean that Federal candidates can demand as much time as they want, only that stations must sell them a reasonable amount of advertising during the various classes of advertising time sold on the station. For state and local candidates, on the other hand, stations don’t need to sell the candidates any advertising time at all. But, if they do, the other political rules apply
Continue Reading Reminder – FCC Political Rules Apply to Off-Year Elections for Vacant Congressional Seats, and for State and Local Offices

2009 – a new year, and a whole new cycle of regulatory requirements.  We wrote last week about the potential for changes in regulations that may be forthcoming but, like death and taxes, there are certain regulatory dates each year that broadcasters need to note and certain deadlines that must be met.  Those dates