September is one of the few months without a due date for the standard regulatory filings – no renewals, EEO public file reports, and no Quarterly Issues Programs Lists or Children’s Television Reports. Instead, the big filing this month is one that applies to all commercial broadcasters (and most entities regulated by the FCC in other services as well) – the annual regulatory fees due on September 20. We wrote about the deadline here (with links to the FCC webpage on which you can look up your fees), and the amounts of the fees by category of broadcaster, here. But just because there are no other regular filings due at the FCC does not mean that those in charge of regulatory compliance at your stations can take the month off once they have paid the fees.
No, there are plenty of other deadlines to which broadcasters should pay attention. Those who filed license renewal applications for radio stations in California and for TV stations in Illinois and Wisconsin should be running their post-filing license renewal announcements on the 1st and the 16th of the month. The next round of license renewals will be filed on October 1, and stations in the states where those renewals are due should be running the third and fourth of their pre-filing renewal announcements on the 1st and 16th. That would be TV stations in Iowa and Missouri, and radio stations in Alaska, Hawaii, Oregon, Washington, American Samoa, Guam, the Mariana Islands, and Saipan.
October 1 will bring the next round of license renewals, EEO public file reports, Quarterly Issues Programs Lists and Children’s Television Reports. The month will also bring the long-awaited Low Power FM Window, about which we wrote here. Preparing for these deadlines will keep more than a few people busy during the month of September.
And, while there are no major rulemaking comments in exclusively broadcast proceedings due in September (comments on Internet captioning, for instance, are due this month), informal comments seems to continue to come in on a number of matters on which the comment deadline has passed (e.g. indecency and ownership). And there are lots of rumors that the FCC will start a new proceeding to examine the UHF discount used in computing the national multiple ownership caps on television stations. And of course, the plans for the FCC incentive auction march on, with the FCC still trying to finalize some of those rules this year. Plus, once Congress returns from its August recess next week, we may see some movement on the pending nominations for the open seats on the Commission.
As in any month, there is plenty to think about on the regulatory front for the broadcast industry.