Mark Down These Regulatory Dates For Broadcasters


David Oxenford, partner at the Washington, D.C. office of the Wilkinson Barker Knauer law firm, reminds broadcasters that Thursday is a major deadline for routine regulatory obligations. Here, he reviews some of the key items that must be completed by the close of business Dec. 1.

While we are into the holiday season, that does not stop the routine regulatory obligations for broadcasters.

Dec. 1 brings a host of routine obligations for stations in many states.

EEO public file reports must be added to the public files of Commercial and Noncommercial Full-Power and Class A Television Stations and AM and FM Radio Stations in the following states that are part of an employment unit with 5 or more full-time employees:

Alabama, Colorado, Connecticut, Georgia, Maine, Massachusetts, Minnesota, Montana, New Hampshire, North Dakota, Rhode Island, South Dakota, and Vermont

For TV stations and radio stations that have converted to the online public file, that will mean uploading those reports to the FCC-hosted public file.

For all stations, a link needs to be included on the main page of your station website — if your station has a website — that leads to these reports.

Mid-Term EEO Reports on FCC Form 397 must be filed with the FCC by Dec. 1 by radio employment units with 11 or more full-time employees in Colorado, Minnesota, Montana, North Dakota, and South Dakota; and by television employment units with five or more full-time employees in Alabama and Georgia.

Additionally, Noncommercial Television Stations in Alabama, Connecticut, Georgia, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont; and Noncommercial AM and FM Radio Stations in Colorado, Minnesota, Montana, North Dakota, and South Dakota have the obligation to submit their Biennial Ownership Reports to the FCC.

There is also the obligation of TV stations to report on the ancillary and supplementary revenue received from non-broadcast use of their digital spectrum. A fee is due if these TV stations received revenue from non-broadcast sources, and even stations that did not receive any such revenue must report that fact, by Dec. 1, to the FCC.

Dec. 1 also is the filing deadline for reconsideration petitions on the FCC’s Quadrennial Review of the multiple ownership rules.

We will see if the impending change in presidential administration and FCC control will cause broadcasters and others to seek reconsideration of the FCC’s decision instead of pursuing court appeals.

We will also be watching to see if other news about the new administration’s picks for FCC Chair, and the status of the Democratic FCC Commissioners, become clearer as December progresses.

As in any month, there are no doubt other regulatory dates of significance to many station’s operations.

Don’t be distracted by holiday parties – stay on top of the regulatory obligations that affect you.


This article was condensed and reprinted by permission from David Oxenford and Wilkinson Barker Knauer’s

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