May is one of the few months on the calendar where there are not routine FCC regulatory deadlines.  Yet there are still a number of important dates and deadlines this month (and early next) that broadcasters should note.  Some of those dates and deadlines are below.

On March 17, the migration of applications and forms from the FCC’s legacy filing portal CDBS to its newer portal LMS will continue. The FCC has announced the transition of many of the forms that had been filed in CDBS, but are now filed by email, to LMS.  Perhaps most significantly, this includes filings for Special Temporary Authority (and extensions to such authority and notices of the resumption of authorized operations.  See the FCC’s Public Notice on the transition for a complete list of the transitioning forms, notes on the procedures to be used for extensions of applications previously filed in CDBS, and other details.

Throughout May, broadcasters in several states should be aware of the opening of political windows tied to June and early July primary elections.  As a refresher, in the forty-five days before a primary election, broadcasters must extend to legally qualified candidates their lowest unit rate and continue to follow all other applicable political broadcasting rules.  So the lowest unit rate period will be in effect at some point this month for stations serving states that have primary elections in June and early July (and is already open for states with May primaries).  For a deeper dive on how to prepare for the political primary election season, see our post, here, which also includes a link to our comprehensive Political Broadcasting Guide.  Take a look at our 2022 Broadcasters’ Calendar to see if your state has an upcoming primary election (though confirm these dates locally as some dates have changed since the calendar was prepared – for instance, just this week, a court ordered the congressional primaries in New York state be postponed from June until August).
Continue Reading May Regulatory Dates for Broadcasters: LMS Migration of FCC Forms, Lowest Unit Rate Windows, EEO Audits, TV Auction, FM Antenna Rulemaking, and More