Many commercial radio stations will need to start placing their public inspection files online beginning June 24, 2016.
As we advised in a prior client alert, under a new rule adopted by the FCC last January, all commercial radio stations that have five or more full-time employees in their employment units, and are located in one of the top 50 Nielsen Audio markets, must upload new public and political file documents to their online public inspection files on a going-forward basis. The FCC announced in a Public Notice that this requirement will go into effect June 24, 2016. This means that as stations create public inspection file documents dated on or after June 24, 2016, they must upload those documents to their new online public files instead of placing them in the physical public inspection files that they have historically maintained at their main studios.
By December 24, 2016, the stations subject to the initial June 24 deadline must upload older documents from their physical public inspection files – that is, documents dated before June 24, 2016 – to their online public inspection files. The FCC will automatically upload certain documents electronically filed in CDBS (or LMS) into each station’s online public file, including: authorizations, applications and related materials, ownership reports and related materials, contour maps, EEO materials, The Public and Broadcasting manual, and non-confidential letters of inquiry and investigative information requests from the Commission. On or shortly after June 24, 2016, stations should review their new online public inspection files to ensure that the FCC has correctly imported those documents to their new online public files.
Noncommercial radio stations, commercial radio stations that are in the top 50 Nielsen Audio markets but have fewer than five full-time employees in their employment units, and commercial radio stations that are in markets smaller than the top 50 Nielsen Audio markets will have until March 1, 2018 to comply with the new online public file rules.
The new online public inspection files will be hosted in a database provided by the FCC. Stations should begin to familiarize themselves with the new online public inspection file database as soon as possible. Stations can preview and test the new database here.
There are other requirements related to the new radio public inspection files. Stations must:
If you have any questions about the FCC’s radio online public inspection rules, please contact any attorney in our office.