Upcoming FCC Broadcast and Telecom Deadlines for October – December
Broadcast Deadlines:
October 1, 2019
License Renewal Applications Due - Applications for renewal of license for radio stations located in Florida, Puerto Rico, and the Virgin Islands must be filed in the Commission's Licensing and Management System (LMS). These applications must be accompanied by Schedule 396, the Broadcast Equal Employment Opportunity (EEO) Program Report, also filed in LMS, regardless of the number of full-time employees.
Radio Post-Filing Announcements - Radio stations licensed in Florida, Puerto Rico, and the Virgin Islands must begin broadcasts of their post-filing announcements with regard to their license renewal applications on October 1. These announcements then must continue on October 16, November 1, November 16, December 1, and December 16. Once complete, a certification of broadcast, with a copy of the announcement's text, must be posted to the online public file within seven days.
License Renewal Pre-Filing Announcements - Radio stations licensed in Alabama and Georgia must begin broadcasts of their pre-filing announcements with regard to their applications for renewal of the license. These announcements must be continued on October 16, November 1, and November 16.
EEO Public File Reports - All radio and television station employment units with five (5) or more full-time employees located in located in Alaska, American Samoa, Florida, Guam, Hawaii, Iowa, the Mariana Islands, Missouri, Oregon, Puerto Rico, the Virgin Islands, and Washington must place EEO Public File Reports in their online public inspection files. 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 10, 2019
Children's Television Programming Reports - For the last time, all commercial television and Class A television stations must file electronically the third quarter 2019 children's television programming reports 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. The Commission has changed the requirement to an annual filing, but that change is not effective until after the filing of the third quarter 2019 reports. Comments are due for the Office of Management and Budget (OMB) consideration of the new annual reports by October 7, 2019.
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. As with the children's TV programming report, the FCC has acted to change this filing requirement to be an annual rather than a quarterly obligation, but the effective date of the change must wait for OMB approval.
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. Again, the effectiveness of the FCC action changing the filing requirement to specify annual rather than quarterly filing is awaiting OMB approval.
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 Stations 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.
October 15, 2019
Children's TV Programming - Support for Educational and Informational (E/I) Programs on Other Stations - Reply comments are due in response to the FCC's Further Notice of Proposed Rulemaking (FNPRM), which seeks to further revise the children's television programming rules and policies to establish standards that would give broadcasters greater flexibility to meet their obligation to serve the educational and informational needs of children, at least in part, by supporting educational and informational programming aired on other stations in the market. This option has historically been available but, without standards, has not been useful to broadcasters.
Closed Captioning - Comments due in response to the FCC's Public Notice (CG Docket 05-231, DA-19-776A1) requesting comments on a Petition for Declaratory Ruling and/or Rulemaking on Live Closed Captioning Quality Metrics and the Use of Automatic Speech Recognition Technologies by Telecommunications for the Deaf and Hard of Hearing, Inc.
October 30, 2019
Closed Captioning - Reply Comments due in response to the FCC's Public Notice (CG Docket 05-231, DA-19-776A1) requesting comments on a Petition for Declaratory Ruling and/or Rulemaking on Live Closed Captioning Quality Metrics and the Use of Automatic Speech Recognition Technologies by Telecommunications for the Deaf and Hard of Hearing, Inc.
November 4, 2019
EEO Rules and Enforcement - Reply comments are due with regard to the FCC's NPRM requesting comments on how to improve EEO compliance and enforcement.
December 1, 2019
License Renewal Pre-Filing Announcements - Radio stations licensed in Arkansas, Louisiana, and Mississippi must begin broadcasts of their pre-filing announcements with regard to their applications for renewal of the license. These announcements must be continued on December 16, January 1, and January 16.
Radio Post-Filing Announcements - Radio stations licensed in Alabama and Georgia that have filed license renewal applications must begin broadcasts of their post-filing announcements with regard to their license renewal applications on December 1. If the renewal application is not filed until the December 2 deadline, wait until then to begin the post-filing announcements. Either way, these announcements must continue on December 16, January 1, January 16, February 1, and February 16. Once complete, a certification of broadcast, with a copy of the announcement's text, must be posted to the online public file within seven days.
December 2, 2019
License Renewal Applications Due - Applications for renewal of license for radio stations located in Alabama and Georgia must be filed in the Commission's LMS. These applications must be accompanied by Schedule 396, the Broadcast EEO Program Report, also filed in LMS, regardless of the number of full-time employees.
EEO Public File Reports - All radio and television station employment units with five (5) or more full-time employees and 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 online public inspection files. 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.
Telecom Deadlines:
November 1, 2019
Quarterly Telecommunications Reporting Worksheet (FCC Form 499-Q) - FCC rules require telecommunications carriers and interconnected VOIP providers to file quarterly revenue statements reporting historical revenue for the prior quarter and projecting revenue for the next quarter. The projected revenue is used to calculate contributions to the Universal Service Fund (USF) for high cost, rural, insular and tribal areas as well as to support telecommunications services for schools, libraries, and rural health care providers. USF assessments are billed monthly.
November 14, 2019
Quarterly Percentage of Insterstate Usage (PIU) Reporting and Certification - Prepaid calling card providers (PCCPs) must report the percentage of interstate use factors and associated call volumes to carriers that provide them with transport services. Additionally, PCCPs must file traffic information and a certification signed by a company officer stating that the provider is in compliance with the FCC's PIU and USF reporting requirements.