As JSI alerted clients earlier this year, the FCC expanded its requirements to place Public Inspection File documents in an FCC-hosted online database to include cable operators (as well as DBS satellite operators and broadcast and satellite radio stations). The Order, which was published in the Federal Register this week, becomes effective June 24, 2016. Cable operators will have six months from the effective date, or until December 24, 2016, to upload existing Public File documents to the FCC-hosted online database.

If your cable system has fewer than 1,000 subscribers, you are exempt from the new online system requirements. However, you must continue to maintain applicable Public File documents at your local cable system office.

If your cable system has 1,000 or more subscribers, existing Public File documents must be uploaded by December 24, with a few exceptions:

  • Political File
    • If your cable system has 5,000 or more subscribers – New Political File material must be provided online on a going-forward basis as of June 24, 2016. Existing material will continue to be retained in your cable system office Public File for the duration of the two-year retention period.
    • If your cable system has 1,000-4,999 subscribers – New Political File material will not be required to be uploaded until March 1, 2018. Companies can voluntarily upload material prior to this date, but by doing so they will be required to upload all subsequent Political File material once they do.
  • Form 396-C Cable EEO Annual Reports – The FCC will import the Form 396-C from its database and load it into your online Public Folder. Companies do not need to take any action on this.
  • Channel Listing – Companies must either upload the full channel lineup or include a link to the webpage listing of channel lineup.
  • Designation and location of principal headend – Companies may opt to note in the online public file that this information is maintained in the local public file. Otherwise, it must be uploaded to the online Public File.

The FCC-hosted online database will also require the following information to be included in your online Public File:

  • The address of your local cable system Public File (for any paper or electronic documents that remain or not fully transitioned online)
  • Cable operator contact for Online Public File
  • List of zip codes served by cable system, by Physical System Identifier (PSID)

In addition, your company website must include a link that connects to the first page of your FCC-hosted online Public File, as well as contact information for a representative who can assist any person with disabilities with issues related to the content of the public file

JSI will be assisting clients over the next six months with establishing the online Public Inspection Files and with overall Public File compliance. Please contact Valerie Wimer or Marty Kluh in JSI’s Maryland office at 301-459-7590 for assistance.

Source: JSI e-Lert