Effective January 3, 2012, the FCC will no longer accept Cable Special Relief (CSR) and Cable Show Cause (CSC) petitions filed on paper. The new electronic filing requirement will affect broadcasters because these filings include petitions to modify a station’s market for purposes of cable carriage, must-carry complaints, complaints relating to retransmission consent, petitions to have a station designated “significantly viewed” and petitions concerning the enforcement of network non-duplication, syndicated exclusivity and sports blackout requirements.

As of January 3, 2012, all CSR and CSC petitions must be filed electronically using the FCC’s Electronic Comment Filing System (ECFS). The electronic filing requirement applies to both the initial petitions and any responsive pleadings. The FCC has established a transition period beginning December 1, 2011, during which parties may voluntarily file CSR and CSC petitions using MB Docket No. 11-187 (the “Cable Special Relief and Cable Show Cause Petitions for 2011” docket). Once petitions are accepted for filing, they will be assigned individual petition-specific docket numbers and transferred to separate electronic dockets. In 2012, the FCC will create a new holding docket for 2012 petitions, which also will be transferred to individual dockets after they are accepted for filing.

The FCC urges filers to record the confirmation number generated by ECFS when their petitions are filed in case issues arise concerning the status of the filing. If a filer does not receive a confirmation number, the filer should assume that the petition was not successfully filed and contact ECFS customer support for assistance.

The FCC states that it will post information on the new filing procedures on its website. The FCC also encourages parties to submit questions regarding the new filing procedures to CRS_CSC_Help@fcc.gov. Questions regarding the new filing requirements also can be directed to the NAB Legal Department at (866)682 0276.