The FCC on Friday issued a reminder to all TV stations that, as of July 1, they will have to upload all of their new political broadcasting documents to their online public files.  Up to this point, only stations affiliated with the Top 4 networks in the Top 50 markets had to worry about putting their political file materials online.  Later this year, that obligation is extended to all TV stations.  Materials created before July 1 do not need to be uploaded, but need to be retained at the station in the remnants of their paper public file (which should still contain letters from the public about station operations, which are not to be uploaded to the FCC online public file).  For more details about the online public file, see our article here.  For more about the requirements for the political file, see our Guide to the FCC’s Political Broadcasting Rules, here.

This public notice is interesting in that it reminds broadcasters of their obligations, without taking into account the inquiry begun by the Commission last June. That inquiry was to review the experience of large stations in complying with the online public file rules for political broadcasting materials (see our article here), and to look at complaints by certain public interest groups that the online files were not user-friendly and pleadings by broadcasters suggesting alternative ways of presenting political file materials that would be both more useful to the public and less burdensome on broadcasters.  Last June’s notice is mentioned in a footnote in Friday’s reminder, but the footnote merely states that the inquiry exists and that comments were received, but the FCC has not decided what to do with those comments.  The implication is that the FCC does not intend to do anything with the June inquiry any time soon, so the July 1 deadline remains in place. It looks like no relief from the FCC can be expected, so it is full-steam ahead for small TV broadcasters, as all of their political documents will need to be online starting July 1.  With an active political broadcasting season in store for many states, be prepared!