Article 32KG6 Fall FCC Broadcasting and Telecommunications Deadlines

Fall FCC Broadcasting and Telecommunications Deadlines

by
FHH Law
from CommLawBlog on (#32KG6)

Note our list is not comprehensive. Other proceedings may apply to you. Please do not hesitate to contact FHH if you have any questions. period-481452_960_720-300x113.png

September 26, 2017 - Annual Regulatory Fees - These will be due and payable for Fiscal Year 2017, and will be based upon a licensee's/permittee's holdings on October 1, 2016, plus anything that might have been purchased since then and less anything that might have been sold since then. The fees must be paid through the FCC's online Fee Filer, and once again this year, the FCC will not accept checks as payment of the fees but will require some form of electronic payment (credit card, ACH transfer, wire transfer, and the like). Please keep in mind that timely payment is critical, as late payment results in a 25 percent penalty, plus potential additional interest charges.

September 27, 2017 - EAS National Test - Participants' ETRS Form Two Due - All EAS participants must be prepared for the national EAS test on September 27 at 2:20 p.m. EDT. Additionally, all participants must prepare and file in the EAS Test Reporting System (ETRS) a Form Two for each station by 11:59 p.m. EDT on September 27. This form is scheduled to become available at 2:20 p.m. EDT, immediately following the EAS test, and will provides information as to results of the test.

October 2, 2017 - EEO Public File Reports - All radio and television stations with five (5) or more full-time employees located in Alaska, American Samoa, Florida, Guam, Hawaii, Iowa, Mariana Islands, Missouri, Oregon, Puerto Rico, the Virgin Islands, and Washington must place EEO Public File Reports in their public inspection files. TV stations must upload the reports to the online public file. 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.

October 2, 2017 - All radio stations with eleven or more full-time employees in Alaska, American Samoa, Guam, Hawaii, the Mariana Islands, Oregon, or Washington, and all television stations with five or more full-time employees in Iowa or Missouri must electronically file a mid-term EEO report on FCC Form 397, with the last two EEO public file reports attached.

October 10, 2017 - Children's Television Programming Reports - For all commercial television and Class A television stations, the third quarter 2017 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 checking, 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.

October 10, 2017 - 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.

October 10, 2017 - 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.

October 10, 2017 - 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 public inspection 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, while all other radio stations may continue to place hard copies in the paper file for the time being. Television and Class A television stations will continue upload them to the online 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.

October 10, 2017 - Class A Television Continuing Eligibility Documentation - The Commission requires that all Class A Television 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.

October 10, 2017 - Repack Transition Progress Reports. All full power and Class A stations modifying their facilities as part of the incentive auction repack must file their first quarterly progress report in LMS on FCC Form 2100 - Schedule 387. The report must provide details on the station's construction status and transition progress during the preceding quarter.

If you have any questions about these deadlines, or want any assistance in ensuring compliance, please reach out to us; we are happy to help.

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