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FCC Returns, New Filing Deadline Guidance

The FCC has resumed normal operations after the end of the recent partial government shutdown. During the shutdown, broadcast stations were unable to upload documents to the FCC’s online public files, including the 4th quarter Issues/Programs Lists which would normally have been due by January 10th.

In a Public Notice released prior to the shutdown, the FCC advised that items due to be filed or uploaded during the shutdown would be required to be uploaded on the second business day of normal resumed FCC operations. On Monday the FCC issued a Public Notice extending the deadline for these filings one additional day.

In accordance with the new Public Notice, deadlines for all filings that would have been due from January 3, 2019, through January 29, 2019, are now extended until Wednesday, January 30, 2019. The Commission waived its rules to the extent necessary to effectuate this extension.

Issues/Programs Lists should be uploaded to each station’s online public file no later than Wednesday, January 30, 2019. This would also include the upload of any political file or other public file material generated since the shutdown.

Finally, any STAs that would have expired from January 3, 2019, through January 29, 2019, are extended until January 30, 2019, except to the extent that such STAs relate to the post-incentive auction transition or other activities authorized under section 309(j).


In Public Notice (Revisions to Deadlines Following Resumption of Normal Operations) , the FCC has now further extended the deadline for uploading 4 thQuarter Issues/Programs Lists and any political file or other public file material generated during the shutdown to February 11, 2019.

The FCC in the same Public Notice addresses other fling deadlines that would have otherwise occurred during the shutdown.

The FCC’s several public notices granting additional extensions of time for filings are confusing at best. Given that the FCC was closed for a total of 23 days, this latest extension offers broadcasters and others with business before the FCC a more relaxed opportunity to fully comply with FCC deadlines.

Copyright © 2020 Womble Bond Dickinson (US) LLP All Rights Reserved.National Law Review, Volume IX, Number 30


About this Author

John Garziglia, Womble Carlyle Law Firm, Radio and Television Attorney

John F. Garziglia is a Partner in the Washington, DC office of Womble Carlyle. In the 1980’s, John served at the Federal Communications Commission as an attorney in the FCC's AM Branch and as a trial attorney in the Hearing Branch of the FCC's Mass Media Bureau. John was formerly a broadcaster, working in the industry in St. Louis, Washington, D.C., and several smaller markets. John represents broadcasters large and small. He is a frequent speaker at both national and state broadcaster conventions.

John has represented radio...

Gregg Skall, Attorney Womble Carlyle, Telecommunications Attorney, FCC Regulatory Compliance Lawyer

Mr. Skall actively represents telecommunications companies in domestic and international telecommunications enterprises in their regulatory matters and business dealings. He represents real estate developers in the acquisition of competitive broadband local exchange (CLEC) telecommunications services for new residential and commercial developments. He also works with telecommunications equipment manufacturers to obtain FCC approvals and to assure regulatory compliance. He assists companies in need of appropriate spectrum support for emerging telecommunications products and has been recognized by the National Journal as one of the leading radio spectrum lobbyists in Washington.

Of Counsel

Rebecca has a diverse communications law practice, guiding clients in media law, Internet, telecom, cable, broadcast and privacy/data protection matters.

She counsels communications industry clients in negotiating contracts and complex business transactions, as well as helping them resolve disputes and regulatory challenges. Her clients include cable operators, broadband service providers, video programmers, network operators, spectrum owners, radio broadcasters and telecommunications companies.

Rebecca has extensive experience in E-Rate (Universal Service...

Robert Silverman, Womble Dickinson Law Firm, Washington DC, Communication Law Attorney
Senior Counsel

Bob Silverman provides guidance to telecommunications carriers and technology companies seeking to navigate through complex regulatory, commercial and compliance structures established by the Federal Communications Commission (FCC) and other government agencies.  Bob’s wireless spectrum experience spans a variety of services—including 700 MHz, 2.5 GHz, AWS, Cellular, PCS and Citizens Broadband Radio Service—and runs the gamut from auctions and compliance reporting to assignments, lease agreements, and enforcement actions.  On behalf of various communications trade...

Michael Bennet Communications Attorney

Michael Bennet has been advocating for and advising companies across the communications spectrum for over 30 years. Michael began his career in the pre-divestiture world as a broadcast attorney assisting radio and television stations with their licensing and transactional needs, as well as litigating in comparative hearings, before expanding his practice to servicing public utilities, petroleum companies, and providers of wireline and wireless telecommunications and broadband services.

As a founding member of a successful boutique telecommunications law firm known for strongly...