October is another busy month of regulatory dates and deadlines for broadcasters.  Unlike previous years, there is no threat of a federal government shutdown on its October 1 start of the new fiscal year, so the dates and deadlines discussed below should not move on broadcasters.  As we detail below, all stations will need to observe EAS reporting requirements for the filing of ETRS Form One in anticipation of the upcoming Nationwide EAS Test, and all full-power stations need to remember the Quarterly Issues Programs list filing deadline.  While there always can be an October surprise, we take a look below at these and other significant dates and deadlines in the coming month. 

October 1 is the deadline for radio and television station employment units in Alaska, American Samoa, Florida, Guam, Hawaii, Iowa, Missouri, Northern Mariana Islands, Oregon, Puerto Rico, the U.S. Virgin Islands, and Washington with five or more full-time employees to upload their Annual EEO Public File Report to their stations’ Online Public Inspection Files (OPIFs).  A station employment unit is a station or cluster of commonly controlled stations serving the same general geographic area having at least one common employee.  For employment units with five or more full-time employees, the annual report covers hiring and employment outreach activities for the prior year.  A link to the uploaded report must also be included on the home page of each station’s website, if the station has a website.  Be timely getting these reports into your station’s OPIF, as even a single late report has in the past led to significant FCC fines (see our article here about a $26,000 fine for a single late EEO report).

The filing of the Annual EEO Public File Reports triggers the Mid-Term EEO Review beginning October 1 for TV station employment units with five or more employees in Alaska, American Samoa, Guam, Hawaii, Northern Mariana Islands, Oregon, and Washington.  The Mid-Term EEO Review that analyzes the last two Annual EEO Public File Reports for compliance with the FCC’s EEO requirements.  See our articles here and here on stations’ Mid-Term EEO Review reporting requirements.