A new year, and a new set of regulatory obligations and deadlines for broadcasters and others. To help track many of the important deadlines for broadcasters in the new year, we have put together a Broadcaster’s Calendar of important regulatory dates for 2015, available here, which highlights many of the dates for the regulatory obligations of broadcasters in 2015. While not exhaustive, and subject to change, the calendar sets out the regular regulatory dates for broadcasters (e.g. Quarterly Issues Programs lists, Children’s Television Reports, EEO public inspection file reports, reg fee obligations, etc.). It also highlights dates that don’t necessarily occur every year – like this year’s obligation for commercial broadcasters to file Biennial Ownership Reports. While the license renewal cycle for TV concludes this year, Mid-Term EEO report obligations (FCC Form 397) for radio stations in the states that were the first to file their renewals in the last radio license renewal cycle (those in the DC area and in the southeast) kick in mid-year for radio employment units with more than 10 full-time employees. The calendar also lists January dates for webcasters to file various elections (including elections to be treated as a “small broadcaster” which, for broadcasters who stream their stations online but have a very small audience, can lessen payment and reporting obligations). There are even a few lowest unit rate windows listed for states that have announced state and local elections (and are many other states holding such elections that we were not able to determine dates – so check those locally.

Some of the important January regulatory dates include the obligation of all broadcasters, by the 10th of the month, to have their Quarterly Issues Programs lists in their public file. TV stations should also place their certifications as to compliance with children’s television commercial limits in their files by that date. By the 12th (as the 10th is a weekend day), television stations must also submit to the FCC their Form 398 Children’s Television Programming Reports that report on educational and informational programming directed to children. 

For radio stations streaming their signals on the Internet, January also brings dates for elections of “small broadcaster” status, declaring that a broadcaster has a very small audience (in essence less than approximately 3 average listeners). Such status allows the broadcaster to pay only $500 for the year, and lessens paperwork obligations in submitting reports of use of sound recordings to SoundExchange. 

There are a number of comment deadlines this month in proceedings affecting broadcasters. Comments are due on January 30 on the FCC’s 68 page Public Notice outlining the proposed procedures for the incentive auction (with another 100 pages of appendices and separate statements from individual Commissioners) by which the FCC hopes to clear a number of television channels so that the spectrum can be repurposed and resold to wireless broadband users. Comments on the FCC’s proposal to extend the digital build-out date for LPTV stations and TV translators in light of the incentive auction (which we wrote about here) are due on January 12 (with replies due on January 26). And comments on changes to the procedures for assessing the quality of the closed captioning provided by TV broadcasters (which we wrote about here) are due on January 20. Watch for additional comments dates on issues including the FCC’s proposal to treat online video providers as MVPDs and on the potential for online public inspection files for radio stations and satellite television systems which should be set soon. Comments in the FCC’s proceeding on the broadcast contest rules are due in early February. 

So, as with every year and every month, there are plenty of regulatory obligations and deadlines for broadcasters. These are some of those deadlines, but always be on the alert for others that we have not highlighted or which may arise in the coming days. Plenty to keep any broadcaster busy!