One week to go to the effective date for the online public inspection file for commercial radio stations in the Top 50 radio markets that are part of employment units with 5 or more full-time employees. Two weeks ago, I conducted a webinar for 19 state broadcast associations on what goes into that file (see our article here), and last week the FCC did their own webinar about how broadcasters make the new cloud-based filing system work (see the archived webinar here). While the mechanics of uploading documents won’t be too unfamiliar for those who have worked with FCC electronic filing systems in the past, there is one detail that you need to note to make the system work – there is an ON/OFF “switch” on the webpage that stations get when they log into their public file. It is initially set to the OFF position (and OFF is in red letters). The switch is next to a sentence that says “W[your call letters here]__ is now ready for keeping public inspection files online. W___ profile is currently turned [OFF] for public view.” Before the public can see the documents in your online public file, you need to toggle that switch to ON (where it will turn green) and then your online file is live. So don’t forget to go there and turn it on for the June 24 effective date. Once you do, it is also a good time to make sure that the FCC has uploaded all the documents that they are supposed to upload to your file (e.g. applications and most other electronic FCC filings, and a coverage map for the station).
For stations not required to begin their transition by June 24 (and June 24 is just the beginning of the transition even for Top 50 stations, as it just marks the date by which they need to upload new documents into the file – they have 6 months to get all of their old public file documents online), this button also gives them the ability to transition to the online public file early. Once they upload all their documents (they have until March 1, 2018 to do so), they just flip the switch and they are live – and then they have no more need for the paper file except for letters from the public and old political file documents (post-transition political file documents need to be uploaded – the pre-effective date political documents are kept on paper for two years). We’ve heard from many smaller stations that they might as well make the transition sooner rather than later, as all the new documents that they are creating (like Quarterly Issues Programs lists, and Annual EEO Public File Reports) will need to get into the online public file sooner or later anyway. So why not do it now? Load your documents and flip the switch and kiss the paper file goodbye (that is, once the political documents age out and once the FCC eliminates the need for the letters from the public which they are proposing to do (see our article here). To watch an archived version of the FCC webinar, you can go here.