The lazy days of summer provide little respite from the regulatory actions of importance to broadcasters.  July brings quarterly requirements, including most importantly, the obligation to upload Quarterly Issues/Programs Lists to a station’s online public file.  There are comment deadlines in July in three FCC proceedings: on regulatory fees, on a proposal for LPTV stations to operate under the 5G Broadcast transmission standard, and in the FCC’s proposal to expand foreign ownership disclosure requirements for FCC-issued licensees, including broadcasters.  Political file windows are also opening in a few states.  So, even if the beach chair is calling, remember to keep an eye on dates that can affect your stations.

The one date that affects all full-power broadcasters, including Class A TV stations, is July 10 -the deadline for all full power and Class A television stations and full power AM and FM radio stations, both commercial and noncommercial, to upload their Quarterly Issues/Program lists for the second quarter of 2025 to their OPIFs.  The lists should identify the issues of importance to the station’s service area and the programs that the station aired between April 1 and June 30, 2025, that addressed those issues.  These lists must be timely uploaded to your station’s OPIF, as the untimely uploads of these documents probably have resulted in more fines in the last decade than for any other FCC rule violation.  As you finalize your lists, do so carefully and accurately, as they are the only official records of how your station is serving the public and addressing the needs and interests of its community.  See our article here for more on the importance of the Quarterly Issues/Programs list obligation.

July 10 is the deadline for a number of other online public file obligations that apply to certain stations.  The following obligations apply to stations if they have any of the information listed below:

• documentation from noncommercial educational stations not affiliated with NPR or CPB of any on-air fundraising benefitting third parties that interrupted their normal programming (see our article here for a further explanation of this requirement),
• documentation by Class A television of their continuing eligibility for Class A status, and
• documentation from full power television, Class A television, and full power radio stations of any programming time that was leased by a foreign government or an agent of a foreign government or provided by a foreign entity for free in exchange for its airing (see our articles here and here for more information).

There are also deadlines for public comment in a number of FCC proceedings. July 1 is the deadline for reply comments responding to comments filed in early June on HC2 Broadcasting Holdings, Inc.’s petition for rulemaking proposing that LPTV stations be permitted to operate using the 5G Broadcast transmission standard as an alternative to the ATSC 1.0 and 3.0 transmission standards.  According to the petition, this standard can be received by compatible mobile devices and can offer services including enhanced programming, datacasting, and other digital connectivity.  The petition proposes requiring 5G Broadcast LPTV stations to provide at least one free-to-air video signal.

July 7 is the deadline for comments responding to the FCC’s Notice of Proposed Rulemaking proposing its fiscal year 2025 regulatory fees for broadcasters and for operational earth stations.  The FCC proposes to continue calculating each full-power TV station’s regulatory fee using the population-based methodology in use since 2020, using a factor of $0.006379 per population served for the full-power TV station regulatory fee.  This represents roughly a 3% decrease from the prior year ($0.006598).  Radio fees are proposed to change very little from those paid last year.  The FCC is also proposing an earth station fee of $2,840 for fiscal year 2025, which will be assessed under its new fee methodology adopted this month (see our discussion here).  Reply comments are due July 21.

July 9 is the comment deadline on the FCC’s proposal to close numerous “dormant” rulemaking proceedings. Numerous Media Bureau proceedings are proposed to be deleted.  These go from station-specific items to those that affect numerous stations in which there has been little recent activity including, for instance, portions of the proceeding to revitalize AM radio.   Broadcasters should carefully review the list of proceedings proposed for termination to see if any were inadvertently included that affect your station. Reply comments on the proposals are due by July 24.

July 21 is the deadline for comments responding to the FCC’s Notice of Proposed Rulemaking proposing to require certain FCC-regulated entities and auction applicants, including all broadcast licensees and permittees, to file a certification stating if they are owned or controlled by a foreign adversary.  As we discussed here and here, the FCC proposes to define foreign adversaries as the Peoples’ Republic of China, Cuba, Iran, North Korea, Russia, and Venezuela.  Entities certifying yes would then need to disclose all ownership interests held by a foreign adversary (including interests held by their citizens or companies organized under their laws) of 5% or greater and describe the nature of the foreign adversary’s control.  The FCC also proposes to revoke FCC authorizations for entities filing false or incomplete certifications or for failing to file certifications when required.  For broadcasters, the FCC seeks comment on whether to use the broadcast ownership rules’ attribution criteria to determine a foreign adversary’s attribution to a broadcaster, and whether to make any changes to the existing foreign sponsorship identification rules to require disclosures for programming provided by foreign adversaries.  Reply comments are due August 19.

In past monthly updates, we have noted certain Lowest Unit Rate windows that opened in June for elections in July.  There are additional LUR Windows that open in July.  There are special Congressional elections in Virginia and in Arizona to fill vacant seats in the US House of Representatives.  In Virginia’s 11^th District, an election to fill the vacant seat will be held on September 9, so stations serving that District have an LUR Window that opens on July 11^th.  In the Arizona 7^th District, the special election to fill the seat will be held on September 23, meaning that the Window will open on July 25^th.  Additional LUR windows for broadcasters located in Delaware, Oklahoma, and Tennessee open this month tied to state and local elections occurring in August and September – meaning that Lowest Unit Rates apply to sales to candidates and their authorized committees (see our article here on the basics of computing LUR):

As a refresher, in the 45 days before a primary election, and 60 days before a general or special election, broadcasters must extend to legally qualified candidates their lowest unit rate and continue to follow all other applicable political broadcasting rules.  For a deeper dive on how to prepare for the 2025 elections, see our post here, which also includes a link to our comprehensive Political Broadcasting Guide.  Also, take a look at our 2025 Broadcasters’ Calendar to see if your state has any upcoming primary, general, or special election (though confirm these dates locally as some dates have changed since the calendar was prepared).

Looking ahead to August, Annual EEO Public File Reports are due August 1 for radio and television station employment units with five or more full-time employees located in California, Illinois, North Carolina, South Carolina, and Wisconsin.  Mid-Term EEO Reviews also commence August 1 for radio station employment units in California with eleven or more full-time employees and for television station employment units in Illinois and Wisconsin with five or more employees.  We’ll have more August regulatory dates at the end of July.

As always, consult your own legal and technical advisors for other dates of importance that might apply to your stations in the upcoming month.