Et Voilà – The New Form 177!!
As we reported last Friday (i.e., October 30), the FCC has asked the Office of Management and Budget to approve new Form 177, the form that broadcasters intending to participate in the reverse auction will have to file no later than 6:00 p.m. (ET) on December 18, 2015. Also as we indicated there, the FCC is looking for hyper-accelerated treatment by OMB, with the usual (and statutorily-mandated) 90-day-plus comment opportunity whittled to a mere 14 days - with OMB approval to issue just five days later.
And also as we mentioned, while the FCC's Federal Register notice alerting us (albeit somewhat obliquely) to all this said that a copy of the draft Form 177 would be available on the OMB website, that turned out not to be the case at all on Friday - or on Saturday morning, either.
But mirabile dictu! Bright and early this morning the Form turned up on the OMB website - along with two related certification forms that will also come into play during the reverse auction window.
Since the delayed availability of the draft forms has effectively pared three days from the already abbreviated 14-day comment period, we here in the CommLawBlog bunker figure that, as a public service, we ought to provide our readers easy access to the forms. So here you go. Click here to view the screen shots of Form 177; click here to view the draft certification to be filed by full-power TV stations planning to channel-share; and click here to view the draft certification for Class A stations planning to channel-share.
Instructions on how to submit comments on any or all of these were set out in Friday's Federal Register notice - but, given the rush-rush status of things, you should probably not expect much deliberation about any comments you may choose to submit.