Five things to know about your FCC public inspection file

One

There are four deadlines a year, and all of them are the 10th

The quarterly issues and programs list is due ten days after the quarter it covers closes: January 10, April 10, July 10 and October 10. Each list names the significant community issues your station identified that quarter, and the programming you aired that addressed them.

The lists are not replaced each quarter. They accumulate, and the whole run is what somebody reads later. A file with a four-year hole in it is not four late documents. It reads as four years of a station not describing what it did for its community.

The folder never closes, though. If you missed one, you can still upload it. A list filed late is worth considerably more than a list never filed, and backfilling old quarters is an ordinary thing to do.

Two

Filing it in the wrong folder counts the same as not filing it

This is the one that surprised us, and it is the reason this article exists.

We check stations by hand and call the ones whose Issues and Programs Lists folder looks empty. A large share of the time, the station had already done the work. The lists were uploaded, most of them on time, into a different folder: FCC Authorizations, and then Additional Documents inside it.

It is easy to see why. Additional Documents is the upload button on your station's main profile page, right where you land. Issues and Programs Lists is somewhere else entirely, behind More Public Inspection Files. One of those is in front of you and the other is not.

So the station does everything right except the last click, and its file reads as though it did nothing at all. We have found stations that filed this way for years, quarter after quarter, never missing one. The person doing the filing was certain the station was up to date, and on the substance they were right. The folder just did not agree.

If this is you, do not try to move the files. The public file offers no move, and it does not let a licensee delete an upload either. Upload a fresh copy of each list into Issues and Programs Lists and leave the originals sitting where they are. A duplicate in the wrong folder costs you nothing. An empty Issues and Programs Lists folder is the thing that gets noticed.

Three

The list has to say what you actually aired, and nobody can write that part for you

A quarterly issues and programs list is a statement about your station's service to its community. The usual shape is a handful of issues, each followed by the programming that addressed it: the program or segment title, the date and time it aired, how long it ran, and a short description of how it treated the issue.

The FCC does not prescribe how many issues, or which ones, or a format. Stations choose, and the lists broadcast counsel circulate all open by saying the list is not exhaustive and the order implies no priority. What the Commission does expect is that the list describes programming you really broadcast.

That is the part no software, consultant or service can supply, because none of them were listening to your station. Anyone offering to generate the substance of your list is offering to invent a federal filing under your license. The paperwork around a list can be handled by somebody else. The list itself is yours.

Four

The file is public, and renewal is when it gets read

Your public file is not something you mail to Washington. It is a folder on a public website, open right now, and anyone can look: a listener, a competitor, an attorney, or the Media Bureau. Your own file is at publicfiles.fcc.gov, under your call sign.

Most of the time nobody looks. The exception is license renewal, when the licensee certifies that the station's public file was complete. That certification is the moment a long run of missing quarters stops being an oversight that nobody noticed.

The FCC's base forfeiture amount for public file violations is $10,000. The Media Bureau has also used short-term renewals and consent decrees for stations with missing quarterly lists, which means the station keeps its license but on a shorter term and with a compliance plan to run. Both outcomes cost more than the filing ever would have.

Five

Nothing tells you when you have missed one

There is no reminder. No confirmation email, no receipt, no warning on the FCC's site, and nobody calls. Miss the July 10 deadline and the only thing that happens is that nothing happens.

That is why the gaps we find run so long. A file that has not been added to in years is rarely a station being defiant. It is usually a station where the person who handled it left, or retired, or the license changed hands, and the file kept quietly not being updated because a public file gives no feedback at all. Nobody notices, because there is nothing to notice.

The only way to know where you stand is to look. Open your own file and read it the way an inspector would, folder by folder, and check the dates.