June brings some of the normal regulatory deadlines for stations in certain states. EEO Public Inspection File Reports need to be placed in the public file (or uploaded to the FCC-hosted public file for TV and large-market radio stations) by Full-Power and Class A Television Stations and AM and FM Radio Stations in Arizona, Idaho, Maryland, Michigan, Nevada, New Mexico, Ohio, Utah, Virginia, West Virginia, Wyoming, and the District of Columbia that are part of an Employment Unit4 with 5 or more full-time employees. EEO Mid-Term Reports for Radio Station Employment Units must be filed by radio station employment units with 11 or more full-time employees located in Arizona, Idaho, Nevada, New Mexico, Utah, and Wyoming and Television Employment Units with five or more full-time employees in Michigan and Ohio.
There are few broadcast proceedings with comment dates in June. As we wrote here, the FCC has proposed to amend its regulatory fees for broadcasters, in particular changing the allocations of the amount owed by the radio industry to allocate a greater burden to big stations in big markets, and less to smaller stations in small markets. Initial comments are due on June 22, with replies due on July 7.
The next generation of television is on tap in the FCC’s proceeding on the adoption of the ATSC 3.0 standard. While comments were filed in that proceeding in early May, reply comments are due on June 8.
TV broadcasters required to repack following the incentive auction should also be planning to file their construction permit applications specifying the facilities that they will be using to operate their stations on their new channels, which are due on or before July 12. If stations believe that they will have problems meeting that deadline, requests for extensions of the deadline are due 30 days before, or by June 12 (though the FCC would like to know even sooner if there are issues).
There is also an early July date worth noting. The FCC’s Modernization of Media Regulation proceeding is now open for comment. Comments are due in early July (July 5), but broadcasters should be working on their suggestions for rule changes that would ease their regulatory burden to avoid having to finalize them over the holiday. We wrote about that proceeding here and here.
As in any month, there are numerous other regulatory dates of importance that will come up. So pay attention to all of your regulatory responsibilities to ensure that none of them cause you any problems. And look for opportunities offered by FCC filings to suggest ways to make regulations more in synch with today’s broadcast business realities.