Online Public File Deadline Nears for Radio Stations

March 1 is the date for final transition from paper to digital
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This is excerpted from Hardy, Carey, Chautin & Balkin’s December issue of its monthly Broadcast Newsletter.

Has your radio station not yet transitioned its public file to the FCC’s online portal? First, we can tell you that’s OK. But second, you need to get moving. March 1, 2018, is your deadline — not just for establishing a public file and putting stuff in in going forward, but also for uploading all of the items that currently belong and are in your paper public file. And third, you can start anytime, even while sitting on your couch in your new holiday slippers. The FCC’s system lets stations begin the process by gradually uploading documents before clicking the button to go “live” with the file.

Many stations that still have paper public files have several file drawers packed full of documents from past years, and those files contain a slew of documents that should have long ago been discarded. So figure out what can be tossed before you start scanning documents from that bulky file cabinet that don’t need to be in your online public file. Under the existing public file rule, you only have to have documents in your public file from your current license period. And in certain cases, the retention period is even shorter than that. So, if you have documents in there from the 1970s, escort them to your shred pile. The FCC’s online public file system has a helpful description of the documents required and retention periods at the top of each folder page.

One final note and recommendation — train two people on your staff to be in charge of the online public file. If one is sick, the other can post. When one posts to the file, the other double checks. Why be so retentive about this? Because the online public file has a built-in truth serum that places the date and time on every upload to the file. That means stations won’t be able to hide from that document that was placed in the file late. It’s the equivalent of admitting your fault to the FCC at the time you upload the late document.

At license renewal time, the renewal application doesn’t shy away from those dark, deep recesses of your public file. The form is direct, and asks the licensee to certify that it has timely placed all required items in the public file for the entire 8-year license term. So this time around, completely with a brand spanking new online public file, stations will have to answer that question consistent with the visible and verifiable dates/times on your public file uploads. And if any are late, the prospect of a monetary fine for every such infraction has just entered your budgeting process. So get some insurance against fines by assigning two people to the online file and making absolutely certain that nothing is late.

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