For radio and television stations with 5 or more full-time employees located in Arizona, Idaho, Maryland, Michigan, Nevada, NewMexico, Ohio, Utah, Virginia, WestVirginia, Wyoming, and the District of Columbia, June 1 brings the requirement that you upload to your online inspection file your Annual EEO Public Inspection File Report detailing your employment outreach efforts for job openings filled in the last year, as well as the supplemental efforts you have made to educate the community about broadcast employment or the training efforts undertaken to advance your employees skills. For TV stations that are part of Employment Units with five or more full-time employees and located in Arizona, Idaho, Nevada, New Mexico, Utah, and Wyoming, you also need to submit your EEO Form 397 Mid-Term Report. See our article here on the Mid-Term Report, and another here on an FCC proposal that could lead to the elimination of the filing of the form.
June 1 should also serve as a reminder to radio stations in Maryland, Virginia, West Virginia and the District of Columbia that your license renewal will be filed a year from now, on or before June 1, 2019. So, if you have not done so already, you should be reviewing your online public inspection file to make sure that it is complete, and otherwise review your station operations in anticipation of that filing. We wrote about some of the issues of concern for the upcoming license renewal cycle in our article here. TV stations in those same states will start the TV renewal cycle two years from now.This month also brings to the end a number of filing windows. LPTV and TV translator stations displaced by the incentive auction have until June 1 to complete and file displacement applications, specifying a new channel for their post-repacking operations. See our articles here and here. AM stations that filed for a FM translator in the most recent window who ended up mutually exclusive with other applicants have until June 14 to file amendments to their applications to resolve the mutual exclusivity or otherwise reach a settlement, or they will end up in an auction at some point in the future. For more information, see this article. Such an auction will be held for translator applicants from the 2003 translator window that were not able to resolve their mutual exclusivity in a long-ago translator window – that auction to be held starting June 21. See this article.
June will also bring a hearing at the Federal Election Commission on the required sponsorship identification for online political ads. See our article here for more information on this FEC hearing and other activity to regulate online political advertising.
And broadcast stations using C Band earth stations to receive programming or for other uses should consider registering these dishes with the FCC, as the FCC is considering repurposing the band for other uses or allowing other wireless uses in the band used by these dishes. The FCC needs to know what users need protection or other accommodation in that band. While there is no requirement that receive-only dishes be registered, no protection will be afforded to those that do not register by July 18. See the FCC public notice on that issue here.
As always, there are plenty of other legal and regulatory issues that may affect broadcast stations – including political lowest unit rate windows in many states in anticipation of primary elections. So stay alert for those dates, watch alerts from broadcast associations, and consult your attorney to make sure that you stay on top of all of your regulatory obligations.
