March 1 Deadline For Radio Stations To Transition To Online Public Inspection Files

By March 1, 2018, radio stations that have not already transitioned to an online public inspection file must do so. Online public files are hosted on an FCC website at: https://publicfiles.fcc.gov/. The online public file requirement does not change the contents of the public file. It simply changes where those documents are stored.

By the deadline, stations must upload to their online public files certain documents that are currently in their paper public files. Stations must then continue to use the online file on a going forward basis. Stations will be primarily responsible for uploading items that are not electronically filed with the FCC, such as quarterly issues/programs reports, EEO public file reports, and political files. For political file materials that exist prior to the March 1 deadline, stations have the option of keeping those documents at the station rather than uploading them to the online file, and must keep them there until the retention period expires. Any new political file materials dated after March 1, however, must be uploaded to the online file.

The FCC will automatically import to the online file certain documents that are electronically available in the Commission’s databases, including authorizations, applications and related materials, ownership reports, contour maps, and certain EEO materials. However, stations should review their online public inspection files to ensure that the FCC has correctly imported these documents.

Each station must also:

  • Include a link to its online public inspection file on the homepage of the station’s website, if it has one;
  • Include contact information on its website homepage (if it has one) for a station representative who can assist persons with disabilities with issues related to the public file; and
  • Maintain a local electronic backup of the political file. The online file has a tool that allows stations to make electronic copies of their online political file.

Documents are date and time stamped when uploaded to the online public file. Therefore, the FCC and the public can see if a document is timely uploaded.

Just like with the paper file, the online public file must be maintained in an orderly manner and outdated documents that are past their retention period should be removed.

If you have questions about bringing your station into compliance with the online public inspection file requirements, or about the FCC’s online public file rules in general, please contact any attorney in our office.

Categories: Media