Deadlines! Get your deadlines here! With summer in the rearview mirror, it’s time to get back to work and look ahead to the rest of the year. Here’s a list of FCC-related broadcast and telecom deadlines. Please note that the list is NOT exclusive, so there may be others. For help meeting these deadlines or answering questions about any that may not be listed here, please contact FHH at 703-812-0400.
October 10, 2018 – Children’s Television Programming Reports – For all commercial television and Class A television stations, the third quarter 2018 children’s television programming reports must be filed electronically with the Commission. These reports then should be automatically included in the online public inspection file, but we would recommend double-checking to ensure this occurred, as the FCC bases its initial judgments of filing compliance on the contents and dates shown in the online public file. Please note that, as has been the case for some time now, the required use of the Licensing and Management System for the children’s reports means that the licensee FRN and password are necessary to log in; therefore, you should have that information at hand before you start the process.
Commercial Compliance Certifications – For all commercial television and Class A television stations, a certification of compliance with the limits on commercials during programming for children ages 12 and under, or other evidence to substantiate compliance with those limits, must be uploaded to the online public inspection file.
Website Compliance Information – Television and Class A television station licensees must upload and retain in their online public inspection files records sufficient to substantiate a certification of compliance with the restrictions on display of website addresses during programming directed to children ages 12 and under.
Issues/Programs Lists – For all commercial and noncommercial radio, television, and Class A television stations, a listing of each station’s most significant treatment of community issues during the past quarter must be placed in the station’s online public inspection file. The list should include a brief narrative describing the issues covered and the programs which provided the coverage, with information concerning the time, date, duration, and title of each program.
Class A Television Continuing Eligibility Documentation – The Commission requires that all Class A Television stations maintain in their online public inspection files documentation sufficient to demonstrate that the station is continuing to meet the eligibility requirements of broadcasting at least 18 hours per day and broadcasting an average of at least three hours per week of locally produced programming. While the Commission has given no guidance as to what this documentation must include or when it must be added to the public file, we believe that a quarterly certification which states that the station continues to broadcast at least 18 hours per day, that it broadcasts on average at least three hours per week of locally produced programming, and lists the titles of such locally produced programs should be sufficient.
November 19, 2018 – EAS National Test – Participants’ ETRS Form Three Due – All EAS participants must submit Form Three, which reports the results of the national EAS test held on October 3 by this date. If a station successfully received and passed on the test, it must report from which source it first received the test, when it received the test, when it forwarded the alert, and other details of what was received. If the station did not receive the test properly, it will be asked to explain what it knows of why not.
December 1, 2018 – EEO Public File Reports – All radio and television stations with five (5) or more full-time employees located in Alabama, Colorado, Connecticut, Georgia, Maine, Massachusetts, Minnesota, Montana, New Hampshire, North Dakota, Rhode Island, South Dakota, and Vermont must place EEO Public File Reports in their public inspection files. TV stations must upload the reports to the online public file. Radio stations in the top 50 markets and in an employment unit with five or more employees will have to place these reports in the new online public inspection file; all other radio stations may continue to place hard copies in the paper public file for the time being. For all stations with websites, the report must be posted there as well. Per announced FCC policy, the reporting period may end ten days before the report is due, and the reporting period for the next year will begin on the following day.
EEO Mid-Term Reports – All television stations with five or more full-time employees in Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont must electronically file a mid-term EEO report on FCC Form 397, with the last two EEO public file reports attached.
November 1, 2018 – Quarterly Telecommunications Reporting Worksheet – Telecommunications carriers and Interconnected VoIP providers must report quarterly revenues for the preceding quarter and projected revenue for the upcoming quarter on FCC Form 499-Q.