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2009 Broadcasters’ Calendar Print E-mail
Thursday, 01/15/2009

The following deadlines are based on information known by us as of the date hereof, may or may not apply to a particular broadcaster, are 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, such as requiring the posting of a report on the Internet or filing a report with the FCC electronically.  It should also be noted that any FCC filing date which falls on a weekend or federal holiday, as a general rule, causes the filing deadline to be shifted to the immediately following business day.  Furthermore, the listing of deadlines 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.

In FCC actions which are not yet effective, full-service television stations and Class A television stations will be required to post most of the contents of their public inspection files on their websites.  Furthermore, the FCC has adopted a new reporting form for television stations that is intended to take the place of the Quarterly Issues/Programs Lists.  The report form will have to be filed electronically with the FCC and be placed in a station’s public inspection file and posted on its website.  Accordingly, affected broadcasters should coordinate with their webmasters to evaluate the cost and speed of designing and implementing changes to their websites in order to be prepared to implement these new FCC posting requirements.  Furthermore, affected broadcasters should review their program “logging” practices so that they can readily and accurately extract from those logs the types of information that the new reporting form requires.  Radio stations may wish to consider conducting the same types of evaluations in light of other recent FCC proceedings which will examine whether the new television report form and posting requirements should be applied to full-service radio stations.

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