April 10, 2018 Deadline for Quarterly Television Reports

Below are the deadlines for the fourth quarter reports that full power and Class A television stations must file:

Documents That Must Be Uploaded Into Each Station’s Online Public Inspection File By April 10, 2018:

• All commercial and noncommercial stations: Issue-Responsive Programming List for programming broadcast between January 1, 2018 and March 31, 2018
• Commercial stations only: Documentation of compliance with Children’s Advertising Limits
• Class A TV stations only: Documentation that the station continues to meet Class A eligibility requirements

FCC Filings Due By April 10, 2018:

• Commercial stations only: Children’s Television Programming Report
• Repacked full power and Class A stations, and non-reimbursable stations: Progress Report

I. Issue-Responsive Programming Lists

Commercial and noncommercial television and Class A stations must prepare and place in their public inspection files a list of programs that have provided the most significant treatment of community issues during the previous quarter. The listing should include a brief narrative statement that identifies the issues that were given significant treatment, and should describe the programs in which the issues were addressed. Each program description must include the date, time, and title of the program, the duration of each responsive programming segment, and a brief explanation of how the programming addressed the issue(s).

II. Records Verifying Compliance With Children’s Advertising Limits

Commercial television stations must upload into their online public inspection files documentation verifying compliance with the children’s television advertising limits during the previous quarter. This documentation must identify the programs that were subject to the limits and describe any instances of non-compliance.

III. Documentation Of Continued Class A Eligibility

Class A television stations must maintain documentation in their public inspection files demonstrating compliance with both of the Class A eligibility requirements: (i) the broadcast of a minimum of 18 hours per day; and (ii) the broadcast of an average of at least three hours per week of locally produced programming each quarter. We recommend that Class A stations place a statement of compliance in their public inspection files on a quarterly basis.

IV. Children’s Television Programming Report

Commercial television and Class A stations must file a Children’s Television Programming Report with the FCC. The report documents commercial broadcasters’ compliance with the children’s educational programming requirements during the preceding quarter. The report is filed in the FCC’s Licensing and Management System.

V. Repack Progress Report Filings

All full power and Class A TV stations that are being repacked and all non-reimbursable television stations transitioning to new channels as a result of the Broadcast Incentive Auction must file a quarterly Progress Report with the FCC by April 10, 2018. Non-reimbursable television stations include band-changing stations, displaced Class A stations, and stations that elected a service rule waiver. The quarterly Progress Reports notify the FCC of the steps the station has taken toward constructing the station’s post-auction facilities. The report is filed in the FCC’s Licensing and Management System.

If you have any questions about these ongoing recordkeeping and related obligations, please contact any attorney in our office.