UPDATED: Business as usual for LPFM political files despite recent online filing R&O

The FCC has issued a Report and Order in MB Docket 14-127 in regards to the public file and political file obligations of radio stations, satellite radio providers (Sirius/XM), direct broadcast satellite providers (DIRECTV & DISH) and cable television providers. 

Based on our inquiry to the FCC, it has been confirmed that this Report and Order does not apply to LPFM stations.  LPFM stations will continue to keep their political files on paper and as a part of the station records.  LPFM stations will not have access to upload public or political file data. 

First and foremost, the order does not add any new public file reporting requirements for LPFM stations.  LPFM stations are not required to maintain a public file but are required to maintain a political file. (§73.801 and §73.1943)

Full service non-commercial educational (NCE) stations will have until March 1, 2018 to start uploading poltical and public file data.  Stations will not be required to upload their past political file data but can start uploading their political file going forward.   According to the R&O, these uploads will be made into CDBS.

 

What is kept in the political file?  (§73.1943)

(a) Every licensee shall keep and permit public inspection of a complete and orderly record (political file) of all requests for broadcast time made by or on behalf of a candidate for public office, together with an appropriate notation showing the disposition made by the licensee of such requests, and the charges made, if any, if the request is granted. The “disposition” includes the schedule of time purchased, when spots actually aired, the rates charged, and the classes of time purchased.

(b) When free time is provided for use by or on behalf of candidates, a record of the free time provided shall be placed in the political file.

(c) All records required by this paragraph shall be placed in the political file as soon as possible and shall be retained for a period of two years. As soon as possible means immediately absent unusual circumstances.