A practical, station-side view based on how past shutdowns have worked
This information may help you sort out your obligations until the government reopens. This is not legal advice. Before taking any action, consult your communications attorney, your state association’s legal service, or NAB Legal.
Most FCC e-systems usually stay online. LMS, ECFS, CORES, and the Online Public Inspection File (OPIF) typically remain up. You can still upload and file. What pauses is staff processing and most routine correspondence.
Deadlines that fall during a shutdown are usually extended—except the political file. Historically, the FCC issues a blanket notice moving due dates that fall within the shutdown to the first full business day after the FCC reopens. Two important caveats for radio: Political file items (orders, invoices, scripts) still must be placed “as soon as possible.” Treat those as not delayed.
Public-safety/EAS obligations are unaffected.
- Public file uploads (if the site is up) — do them on time. For radio that means: Quarterly Issues/Programs Lists (Jan 10, Apr 10, Jul 10, Oct 10)
- EEO Annual Public File Report (by your anniversary date)
- Any political file additions (ASAP)
If the website is reachable, upload by the normal deadline even if the agency is “closed.”
If the site is down or flaky, document and upload ASAP after. Grab screenshots of error pages and note date/time.
- Keep a timestamped PDF of the item in your internal records (and, if you like, email it to yourself or counsel to lock in a contemporaneous record).
- Upload as soon as the system returns and add a brief note in the file description (“System unavailable on [date/time]; uploaded at first opportunity.”)
Applications and fee-triggering filings. You can usually submit renewal/STA/transfer apps in LMS; formal “acceptance for filing” and staff action will wait until the FCC reopens.
If the fee portal is unavailable, fee-dependent filings are effectively tolled—watch for the FCC’s reopening notice that sets a new uniform due date.
Rulemakings and comments. If a comment or reply date hits mid-shutdown, expect a new consolidated deadline after reopening. You can still file in ECFS; it just won’t be acted on until later.
Don’t pause compliance that isn’t an FCC upload. Public-file posting at the station (if you maintain any local material), contest rules disclosures, EEO recruitment, EAS monitoring/tests, and Sponsorship ID all continue per normal rules.
Quick checklist for GMs, PDs, engineers
- Try OPIF first; if it’s up, upload on time.
- If down: document outage → keep timestamped copy → upload ASAP.
- Political file = ASAP regardless.
- For anything with a fee or formal Bureau action, watch for the FCC’s post-shutdown public notice resetting dates.
- Keep your EAS and on-air compliance steady.
—Editor