Our friends at the DC law firm of Pillsbury Winthrop Shaw Pittman LLP issued an advisory reminding stations to upload their “issues programs lists” into their public file by on or before April 10, 2021. The FCC can now see the time and date when you upload this list. So do not be late with this important filing. According to the Pillsbury advisory:
“The FCC requires each broadcast station to air a reasonable amount of programming responsive to significant community needs, issues, and problems as determined by the station. The FCC gives each station the discretion to determine which issues facing the community served by the station are the most significant and how best to respond to them in the station’s overall programming.
To demonstrate a station’s compliance with this public interest obligation, the FCC requires the station to maintain and place in the Public Inspection File a Quarterly List reflecting the “station’s most significant programming treatment of community issues during the preceding three month period.” By its use of the term “most significant,” the FCC has noted that stations are not required to list all responsive programming, but only that programming which provided the most significant treatment of the issues identified.”
The Pillsbury advisory includes an example of a typical “issues programs list” that will be accepted by the FCC. Remember, the FCC’s base fine for failing to include an “issues program list” in your on-line public file can be $10,000.
To see the Pillsbury Advisory click HERE.
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