Radio station online Public Inspection File deadline rapidly approaching

posted on 1.29.2018

Texas Radio broadcasters have until March 1 – about 30 days from now – to upload their Public Inspection File to the FCC’s website, a rule which applies to commercial and non-commercial educational Radio stations alike. This deadline applies to Radio stations in markets 51 and higher; stations in markets 1-50 and all TV stations already have made the transition.

TAB’s FCC legal counsel, Pillsbury Winthrop Shaw Pittman, confirms that those in this “last wave” of stations moving their public files online do not have to upload their Political File by this date, but must at a minimum commence uploading their Political File documents to the FCC’s online public file on a going-forward basis beginning on March 1.

For stations that still haven’t begun this process, the most efficient thing to do immediately is to start scanning the Public File documents to a PDF form for uploading. It’s the most time-consuming aspect of the whole process.

The actual uploading, in comparison, isn’t anywhere near as time-intensive but one should not wait till the last minute to start uploading documents. The FCC’s website has crashed with other online filing deadlines.

Stations should be very aware of how easy it will be for the FCC to ascertain whether a station is in compliance.

TAB resources at your fingertips

TAB presented an online Public Inspection File webinar in late November featuring Pillsbury’s Scott Flick and Lauren Lynch Flick. The webinar is archived.
View here

The webinar should answer most if not all of a station’s questions.  One can view it at any time and as many times as needed.  If a station still has a question, TAB can put you in touch with one of the attorneys to get you the answers you need on the TAB legal hotline.

Stations often have questions about four aspects of the Public Inspection File:

• What should be in the Issues/Programs lists?
• What format should be used?
• What documents need to be kept in each folder of the Public Inspection File?
• How long does a station need to keep those documents?

The Pillsbury law firm has TAB members covered there, too, publishing an Issues/Programs List advisory that covers what should be in them and which also includes a sample issues/programs format to use.
Download Issues/Programs List Advisory  

Another Pillsbury advisory discusses the contents of each component file of the station Public Inspection File and includes a retention schedule for each specific document.
Download Public Inspection File Advisory

TAB urges radio broadcasters to complete this task before it is too late and costly fines are meted out to those stations that fail to upload the file in a timely fashion.

Questions?  Contact TAB's Michael Schneider or call (512) 322-9944.

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