2012 Broadcasters' Calendar

Items of Note in 2012

I. Applications for Renewal of License: The three year long license renewal cycle for broadcast stations in radio services (AM, FM, FM Translator) which began on June 1, 2011 continues in 2012. Licensees in the television services will begin the license renewal process in 2012, starting with television, Class A, LPTV, and TV translator stations located in Maryland, Virginia, West Virginia, and Washington, D.C., whose license renewal applications must be filed by June 1, 2012. 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 approximately four months before the date of license expiration; and the dates on which post-filing announcements must air.

II. Biennial Ownership Report Filing Requirements: Commercial radio, television, Class A television and LPTV stations will not file biennial ownership reports in 2012. Their next report is due on November 1, 2013. As of this publication, noncommercial radio and television stations will continue to file every other year on the anniversary date of their license renewal filing. As noted above, this date will depend on the state or territory of each station's community of license.

III. Television Station Online Public File: The FCC is proposing to adopt a requirement that television stations largely maintain the contents of their public inspection files (including their political files) on the Commission's website. Comments on the FCC's online public file proposals were due on December 22, 2011, and reply comments are due on January 17, 2012. Accordingly, television stations are not presently required to maintain online public inspection files, but should be alert to any future announcement regarding implementation of an online public file requirement.

IV. 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 will require that television broadcasters document specific details regarding their public interest service that will need to be submitted to the FCC for inclusion in the proposed online public inspection file discussed above. As of this publication, comments in that proceeding are due by January 17, 2012, and reply comments by January 30, 2012. Because the FCC must issue a Notice of Proposed Rulemaking prior to implementing any new rules, it may be some time until any new reporting form will be adopted and become effective.

V. 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 Commission 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 2012 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 immediate 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: 2012 Broadcasters' Calendar