NBC affiliates may want to get their stop watches out when Donald Trump hosts Saturday Night Live.
Per FCC rules, qualified candidate appearances on non-news broadcasts are subject to the "equal opportunities" requirement, which requires TV stations who give airtime to one candidate to offer other qualified candidates for the same office an equivalent amount of airtime on the station.
NBC could ask the FCC for a ruling that the show was a bona fide news broadcast or news interview program or documentary, and thus exempt from the requirement, but that would be a stretch.
The FCC makes such rulings on a case-by-case basis, including in the past that Entertainment Tonight was a news show that did not trigger equal opportunities requirements.
Instead, look for it to advise affiliates of their obligation to post a notification in their FCC online political files of Trump's appearance and the exact screen time. That will trigger a seven-day window for Trump's opponents, so long as they are declared candidates and have been active in the state where the TV station is located, to seek a similar amount of time.
The requirement is on stations, not networks, to provide that equal opportunity,
For its part, NBC is expected to evaluate any equal time requests it receives on its owned stations following Trump's Nov. 7 appearance on SNL in accordance with all applicable regs.
Following Hillary Clinton's appearance on SNL, NBC's owned station in New York, WNBC, filed the following in its FCC political file, indicating it was aware of the obligation.
"Notice Required by Section 73.1943 of the Rules of the Federal Communications Commission.
Former Secretary of State Hillary Clinton, a candidate for the Democratic nomination for President in the 2016 national election, appeared without charge on NBC's Saturday Night Live for a total period of 3:12 (three minutes and twelve seconds) commencing at 11:53:01 PM EDT on October 3 and ending at 12:01:44 AM EDT on October 4, 2015. Station WNBC New York, NY, is affiliated with the NBC Television Network and broadcast the Oct. 3 episode of Saturday Night Live, including the segments in which Secretary Clinton appeared."
While the "equal opportunities" clause is sometimes called "equal time," it should not be confused with the equal time "fairness doctrine" corollary the FCC finally took off the books in 2011. It required TV stations to offer equal time to other candidates if a station endorsed a candidate in an editorial.