Need to know what to plan for over the next three months?
Fletcher Heald & Hildreth has provided a great summary of the broadcast deadlines you’ll need to take note of. Be sure to print it and share with those at your radio or TV stations who are actively involved with these tasks!
Broadcast Deadlines:
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 License and Management System. These applications must be accompanied by Schedule 396, the Broadcast Equal Employment Opportunity (EEO) Program Report, also filed in the License and Management System (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.
Public Notice of Broadcast Applications – Reply Comments are due in response to the FCC’s Further Notice of Proposed Rulemaking (FNPRM) regarding proposals to modernize and simplify the written and on-air public notices broadcasters must provide upon the filing of certain applications
December 23, 2019
Assessment and Collection of Regulatory Fees for Fiscal Year 2019, FNPRM – Reply Comments are due with regard to proposed policies for next year’s and following years’ regulatory fees, as outlined above.
January 10, 2020
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 with a brief description of the 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.
January 30, 2020
Children’s Television Programming Reports – For the first time, 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 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.
Commercial Compliance Certifications – Assuming Office of Management and Budget (OMB) approval in time, all commercial television and Class A television stations must upload an annual 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, to the online public inspection file. Again, this “annual” report will cover only the period from September 16 through December 31, 2019.
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, this is an annual requirement but covers only the period during which the revised rule was effective; i.e., September 16-December 31, 2019.
January 31, 2020
Biennial Ownership Reports – All licensees and entities holding an attributable interest in a licensee of one or more AM, FM, TV, Class A television, and/or Low Power TV (LPTV) stations must file a biennial ownership report reflecting information as of October 1, 2019. Please recall that not only corporations and limited liability companies, but also sole proprietorships and partnerships composed entirely of natural persons (as opposed to a legal person, such as a corporation) are included in the licensees that must file reports. Please recall that noncommercial and commercial entities are required to file by the same date. Additionally, all persons holding an attributable interest in a commercial licensee must have acquired either an FCC Registration Number (FRN) or Restricted Use FRN.
February 1, 2020
License Renewal Pre-Filing Announcements – Radio stations licensed in Indiana, Kentucky, and Tennessee must begin broadcasts of their pre-filing announcements with regard to their applications for renewal of the license. These announcements must be continued on February 16, March 1, and March 16.
Radio Post-Filing Announcements – Radio stations licensed in Arkansas, Louisiana, and Mississippi that have filed license renewal applications must begin broadcasts of their post-filing announcements with regard to their license renewal applications on February 1. If the renewal application is not filed until the February 3 deadline, wait until then to begin the post-filing announcements. Either way, these announcements must continue on February 16, March 1, March 16, April 1, and April 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.
February 3, 2020
License Renewal Applications Due – Applications for renewal of license for radio stations located in Arkansas, Louisiana, and Mississippi must be filed in the Commission’s License and Management System. 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 Arkansas, Kansas, Louisiana, Mississippi, Nebraska, New Jersey, New York, and Oklahoma 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.
