2015 Broadcasters’ Calendar

I. Applications for Renewal of License: The three-year long license renewal cycle for broadcast stations in radio services (AM, FM, FM Translator, LPFM), which began on June 1, 2011, ended in 2014. The renewal cycle for television services (television, Class A, LPTV, TV Translator), which began on June 1, 2012, continues in 2015. The date on which a station's license renewal application is due depends on the state or territory in which its community of license is located. All licensees should familiarize themselves now with the dates associated with this important filing, including the dates on which public notice announcements must air in advance of the license renewal filing; the filing date itself, which is four months before the date of license expiration; and the dates on which post-filing announcements must air.

II. Television Station Online Public Inspection File: The FCC adopted a requirement that full-power and Class A television stations post the content of their public inspection file on the FCC's website, effective as of August 2, 2012. For such stations, all references herein to the public inspection file refer to the TV station’s online public inspection file. The FCC is currently considering a Notice of Proposed Rulemaking which would expand the online public file requirement to include radio stations as well.

III. Quarterly Issues/Programs Lists: As of this publication, radio, television, and Class A television licensees must continue to prepare and place these documents in their public inspection files on a quarterly basis on the dates noted. Television broadcasters should be alert to a future announcement regarding the effective and due dates of a new form the FCC has proposed to replace the Quarterly Issues/Programs List. The FCC previously adopted a new form, FCC Form 355, to replace the Quarterly Issues/Programs List for television stations. While that form was later rescinded before becoming effective, the FCC issued a Notice of Inquiry proposing a new FCC Form to replace the current issues/programs list. The new form requires that television stations document specific details regarding their public interest service. However, because the FCC must issue a Notice of Proposed Rulemaking prior to implementing any new rules, it may be some time until a new reporting form is adopted by the FCC.

IV. Broadcast Annual Employment Report on FCC Form 395-B: The FCC suspended use of this form in 2001 in connection with the revision of its EEO Rule. In 2004, the FCC announced that it would resume use of the form and would advise the broadcast industry of the due date for the first filing of the reinstated form. As of the date of this publication, no such announcement has been made. Broadcasters should be alert to a future announcement regarding the possible reinstatement of this filing requirement. While the Form 395-B is currently suspended, other important EEO outreach and reporting obligations remain in effect, and their 2015 deadline dates are noted in this Calendar.

Disclaimer

The following deadlines are based on information known by us as of the date hereof. These deadlines may or may not apply to any particular broadcaster. These deadlines are provided for general informational purposes only and should be double-checked for currency close to each pertinent date/deadline. Actions by the FCC, Congress, or the courts could affect any of these deadlines by, for example, eliminating a particular reporting/filing obligation altogether or modifying the form used, content, deadline, fee, or manner of reporting/filing. It should also be noted that, as a general rule, when a deadline for filing a document with the FCC falls on a weekend or a federal holiday, the filing deadline will shift to the next business day. The listing of deadlines below is not intended to be complete or exhaustive of all regulatory and non-regulatory deadlines that may apply to a given broadcaster year-to-year. Accordingly, broadcasters should seek the advice of communications counsel in each instance to assure timely and proper filing. This edition of our annual "Broadcasters' Calendar" supersedes all prior editions and accordingly any prior editions should no longer be used.

Download: 2015 Broadcasters’ Calendar