Upcoming FCC Broadcast and Telecom Deadlines for July – September
Broadcast Deadlines:
July 10, 2020
Children's Television Programming Reports - For the first time, and after two delays, all commercial television and Class A television stations must file electronically annual children's television programming reports with the Commission, although the first one will cover only the portion of the year which began with the effective date of the revised rules (September 16-December 31, 2019). These reports should be automatically included in the OPIF, 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.
Issues/Programs Lists - For all commercial and noncommercial radio, television, and Class A television stations, listings of each station's most significant treatment of community issues during both the first and second quarters of 2020 must be placed in the station's OPIF. The lists should include brief narratives describing the issues covered and the programs which provided the coverage, with information concerning the time, date, duration, and title of each program with a brief description of the program. Although with the postponed deadline, it should not matter whether these reports are formatted as one report or two, we would recommend retaining two separate reports and uploading one for each quarter to avoid confusing future reviewers.
Class A Television Stations Continuing Eligibility Documentation - The Commission requires that all Class A Television Stations maintain in their OPIF 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. Whether you upload one document or two in this category, make sure you include both the first and second quarters in the time period covered.
August 1, 2020
Radio Post-Filing Announcements - Radio stations licensed in Illinois and Wisconsin must begin broadcasts of their post-filing announcements concerning their license renewal applications on August 1. If the renewal application is not filed until the August 3 deadline, wait until then to begin the post-filing announcements. Either way, these announcements must continue on August 16, September 1, September 16, October 1, and October 16. Once complete, a certification of broadcast, with a copy of the announcement's text, must be posted to the OPIF within seven days, or by August 23.
Television Post-Filing Announcements - Television stations licensed in North Carolina and South Carolina must begin broadcasts of their post-filing announcements concerning their license renewal applications on August 1. If the renewal application is not filed until the August 3 deadline, wait until then to begin the post-filing announcements. Either way, these announcements must continue on August 16, September 1, September 16, October 1, and October 16. Once complete, a certification of broadcast, with a copy of the announcement's text, must be posted to the OPIF within seven days, or by August 23.
August 3, 2020
Radio License Renewal Applications Due - Applications for renewal of license for radio stations located in Illinois and Wisconsin must be filed in the 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.
Television License Renewal Applications Due - Applications for renewal of license for television stations located in North Carolina and South Carolina must be filed in 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 or more full-time employees and located in California, Illinois, North Carolina, South Carolina, and Wisconsin must place EEO Public File Reports in their OPIFs. 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.
September ??, 2020
Annual Regulatory Fees - On a date not yet determined but certainly before September 30, 2020, annual regulatory fees will be due. These will be due and payable for Fiscal Year 2020 and will be based upon a licensee's/permittee's holdings on October 1, 2019, 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.
Telecom Deadlines:
July 1, 2020
Eligible Telecommunications Carrier Data Collection (FCC Form 481) - Eligible Telecommunications Carriers (ETCs) that receive funds from the High Cots Program and/or Lifeline support program must complete Form 481. Mobility Fund recipients are not required to submit the form. Form 481 collects financial and operations information regarding ETCs and fulfills the annual certification requirement in Section 54.313 of the Commission's rules. ETCs required to submit Form 481 must file the form electronically using their online USAC portal.
August 1, 2020 (Due August 3, 2020 this year because August 1 falls on a Saturday)
Numbering Resource Utilization Forecast (NRUF) (FCC Form 502) - Twice a year, service providers with numbers from the North American Numbering Plan Administrator (NANPA), a Pooling Administrator, or another telecommunications carrier must file a numbering resource utilization forecast. Subscriber toll-free numbers are not included in the report. Interconnected Voice over Internet Protocol (VoIP) providers are subject to the reporting requirement along with other service providers who receive NANPA numbers, such as wireless carriers, paging companies, incumbent local exchange carriers (ILECs), and competitive local exchange carriers (CLECs). The next biennial reporting deadline is August 1, 2020.
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.
August 14, 2020
Quarterly Percentage of Interstate 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.
September 1, 2020
FCC Form 477 - This form is filed online biannually on March 1 and September 1. The Commission collects a variety of information about broadband deployment and wireless and wired telephone service on Form 477. Broadly speaking, the following providers must fill Form 477: 1) facilities-based providers of broadband connections to end users, 2) providers of wired or fixed wireless local exchange telephone service, 3) providers of interconnected VoIP service; and 4) facilities-based providers of mobile telephony (mobile voice) services. If you have any questions about whether your company must file Form 477 or what information your company is required to submit in the filing, you should contact your telecommunications counsel.