April is one of those months in which many FCC obligations are triggered for broadcasters. There are the normal obligations, like the Quarterly Issues Programs lists, that need to be in the public file of all broadcast stations, radio and TV, commercial and noncommercial, by April 10. Quarterly Children's television reports are due to be submitted by TV stations. And there are renewal obligations for stations in many states, as well as EEO Public File Reports that are due to be placed in station's public files and on their websites. The end of March also brings the obligation for television broadcasters to start captioning live and near-live programming that is captioned on air, and then rebroadcast on the Internet. Finally, there are comment deadlines on the FCC's proposal to relax the foreign ownership limits, and an FM auction and continuing FM translator filing requirements.
Radio stations in Texas and television stations in Tennessee, Kentucky and Indiana have renewal applications due on April 1. The license renewal pre-filing broadcast announcements for radio stations in Arizona, Idaho, Nevada, New Mexico, Utah and Wyoming, and for TV stations in Michigan and Illinois, must begin on April 1. All of these stations will be filing their renewals by June 1. EEO Annual Public file reports for all stations (radio and TV) with five or more full-time employees, which are located in Texas, Tennessee, Kentucky, Delaware, Pennsylvania or Indiana, must be placed in their public files (which are now online for TV broadcasters) by April 1. Noncommercial radio stations in Texas, and noncommercial TV stations in Tennessee, Indiana Delaware, Pennsylvania, and Kentucky must also file their Biennial Ownership Reports by April 1.
Live or near live television programming, that is captioned on the air, and then transmitted on the Internet or through some sort of mobile app, must be captioned in its digital format by March 30. As with the obligation for pre-recorded programs that kicked in on September 30 of 2012, the rule currently applies only to programs that are streamed substantially in their entirety by digital means.
There is also a comment deadline in an important FCC proceeding coming up this month. The FCC has asked for comments on a potential relaxation of the rules limiting foreign ownership of broadcast stations. These comments are due on April 15. See our summary of this important proceeding here.
The auction for new FM channels also begins this coming month, and the processing of FM translator applications from the 2003 window continues with the deadline for filing preclusion studies for proposed new translators in or near spectrum-limited markets (see our summary here). Clearly, April is one of those busy regulatory months for broadcasters. Don't overlook those dates that may apply to you!