by David Oxenford
All commercial broadcasters have to file their Biennial Ownership Reports today, beginning a very busy month in the broadcaster's regulatory world. December 1 is also the deadline for noncommercial ownership reports to be filed by noncommercial radio stations in Alabama, Connecticut, Georgia, Massachusetts, Maine, New Hampshire, Rhode Island and Vermont. Annual EEO Public File reports are also due to be in station files for stations in all of the states where noncommercial stations have ownership filings.
License renewals for radio broadcasters in Georgia and Alabama are also due on that date. And all full-power broadcasters need to file their reports on the results of the recent Nationwide EAS Test by December 27.
December also brings a Commission meeting, at which the CALM Act rules will be adopted according to the tentative agenda for the December 12 meeting. The CALM Act is intended to eliminate loud commercials. These rules are required by statute to be adopted in December. Comments on a number of other FCC proposals in rulemaking proceedings are also due. The FCC just announced that comments in the proceeding to determine if FM digital operations using the IBOC technology (so-called HD Radio) can operate with different power levels on each side of the main channel are due by December 19.
Radio broadcasters may be using December to prepare applications for the next auction of new FM channels, with an FCC filing window that opens on January 3. We also expect, based on press reports, to see a Notice of Proposed Rulemaking on the FCC's multiple ownership rules.
About the only recent deadline that we?ve recently written about that won?t go into effect in December, is one that is not an FCC deadline, but one from the National Labor Relations Board, which had required virtually all companies across the country to begin posting at their businesses a statement about employee rights under Federal labor laws. This was supposed to have been done by November 14 but, due to objections by certain business groups to the NRLB?s power to require this notice, the date has been extended to January 31.
So get your regulatory hat on, and find time to take care of all of your legal obligations this month ? between your holiday shopping.
David Oxenford is a partner in Davis Wright Tremaine's Washington, DC office. He has represented broadcasters for over 25 years on a wide array of matters from purchases and sales of broadcast properties and the negotiation of programming agreements to regulatory matters.
Visit his website HERE
Send him and e-mail HERE
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