Media Bureau “reminder” seems to eliminate any hope of extension of exemption for non-Top Four affiliates outside of top 50 DMAs.

If you’re a TV licensee who doesn’t happen to be either (a) in any of the top 50 DMAs or (b) affiliated with one of the top four commercial networks (ABC, CBS, FOX and NBC), we’ve got some news for you: it looks like you’ll be having to upload all your new (but none of your old) political file data to your online public inspection file starting July 1, 2014.

That, at least, is the unmistakable take-away message from a public notice issued by the Media Bureau.

The notice reminds one and all of a wrinkle the Commission included when it imposed the online public file requirement for TV licensees back in 2012. At that time, the obligation to upload the political file component of each station’s public file was limited to Top Four affiliates in the top 50 DMAs. All other stations were still required to maintain a political public file, but only on paper, as they had done for years.

In 2012, the Commission said the exemption would be good only until July 1, 2014. BUT the FCC held out at least a glimmer of hope that the exemption might be extended: in 2013 the Media Bureau was to invite comments on whether “any changes [to the online political file rule] should be made before it takes effect for the other stations.” The Bureau dutifully solicited comments in June, 2013 and, as we reported last year, the response was less than overwhelming.

Of course, the full Commission has not yet addressed the question on which it told the Bureau to request comments, but so what? The way the exemption sunset was worded in 2012, the exemption seems to go away automatically unless the FCC changes its mind. And, as the Bureau’s latest public notice acknowledges, there’s been no indication of any change of mind on the Eighth Floor.

So, presumably to give everybody plenty of time to get ready for the Big Day, the Bureau has “remind[ed]” TV licensees of the upcoming July 1 “deadline”.

Truth be told, though, it’s not really a “deadline” in the classic sense. July 1 merely marks the date as of which TV stations must start to upload any new political materials to their online public files. That is, until July 1, no uploading need occur, and after July 1, only new materials must be uploaded. So it’s not like TV licensees have any specific chores to complete by the July 1 “deadline” – other than to be ready to start uploading political materials once July 1 arrives.

The two-year exemption has been nice, but it appears to be coming to an abrupt end. All TV licensees who have been enjoying the exemption so far should probably take this opportunity to review the online public file requirements and the political file rules to be sure that you will, in fact, be ready when the time comes.