Sept. 19 Deadline for TV Shared Service Agreements to be the Station Public Inspection File

An important FCC regulatory deadline for TV stations on Sept. 19 may go unnoticed by some, so here’s a quick reminder as we head into the Labor Day weekend.  Stations may recall FCC action in 2016 to define and create public availability requirements for shared service agreements (SSAs) entered into by commercial television station stations.

“This obligation for TV stations to put in their public file agreements between independently owned TV stations for shared broadcast services (including shared news operations, accounting staffs and other operational matters) became effective on March 23,” said David Oxenford, an attorney with TAB Associate member Wilkinson Barker Knauer.  SSA’s executed after the March 23 effective date must be uploaded to the station public inspection file “in a timely fashion.”

As is the case with much FCC regulation, “timely fashion” is not defined.  Importantly, agreements existing before the March 23 effective date need to be uploaded to the station public inspection file within 180 days of that date.  That 180-day period ends Sept. 19.

Now would be a good time for commercial television stations to review existing SSA’s entered into by the station to assess what exists, what has been uploaded, and what may still need to be uploaded.  “As the definition of shared services agreements is very broad, seemingly including pretty much any kind of service other than an on-the-fly, single event-based news cooperation agreements and agreements totally unrelated to broadcast operations (like shared janitorial services), if your TV station shares services of any sort with another station in its market, talk to your attorney about whether that agreement needs to be included in your public file,” Oxenford said.

Interested stations can review the FCC’s SSA Public Notice here.

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