BREAKING, READ: Hillary's SNL Appearance Might Trigger 'Equal Time' Demands; NBC Advises Affiliates To Play It Safe

In a surprising move and out of an abundance of caution, NBC advised its affiliates that Hillary Clinton's Saturday Night Live appearance might trigger 'equal time' demands, and that they should file a notice with the FCC that they gave the Democratic presidential candidate 3 minutes, 12 seconds of free airtime.

Arizona's Politics discovered the network's play-it-safe decision this afternoon after the Tucson affiliate uploaded the notice below to its FCC file.

  KVOAHillary Clinton - 100315 SNL Appearance (14441471524889)

Arizona's Politics then confirmed that the filing was not a KVOA decision, when it discovered that NBC O&O station KNBC in Los Angeles filed the entire Sunday morning memo from the network. The networ said that all stations that aired the program featuring a skit with Clinton (in which she impersonated GOP candidate Donald Trump) "should complete the following notice...and upload(ing) a copy of the notice to the online political file maintained for public inspection by the station."

The memo concluded by urging GM's to "Please let Affiliate Relations know promptly if your station receives a demand for equal time from any of the other candidates."

  KNBC Clinton FCC Notice KNBC (14440577969819)

The law on whether NBC and its affiliates opened themselves up to equal time demands to the other 20 major party candidates, under federal law, is unclear.  Here is the FCC ("Federal Communications Commission") regulation:

As pointed out by broadcast attorney David Oxenford (in 2007), the equal time doctrine has not been repealed, just broadened significantly to include most or all of the candidate appearances on shows that are not generally considered as news.

Apparently, NBC had not previously considered candidates' appearances on SNL - a long and storied tradition - to be worthy of either equal time demands or FCC filings; Arizona's Politics checked the 2012 political files for both reporting NBC affiliates in Arizona and the two O&O stations in New York (where the appearances are "live from New York") and Los Angeles (where they are delayed three hours), and found no such filings. (Though, Barack Obama did appear shortly before the election.)

Whether this change of heart has to do with the nature of Clinton's appearance, with a possible reaction or reactions from other candidates (Donald Trump, who Clinton impersonated?), with a notification from the FCC (unlikely), or with  a more cautious legal department, is not yet clear.




(Arizona political law attorney Paul Weich contributed to this article.)

(Updated, 2:30pm to include language from the NBC memo.)

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