By January 10, 2020, full power and Class A television stations must file their quarterly reports for the Fourth Quarter of 2019. For the first time, stations will not file a quarterly Children’s Television Programming Report. Instead, stations will file their first annual Children’s Television Report by March 30, 2020.
Documents That Must Be Uploaded to Each Station’s Online Public Inspection File by January 10, 2020:
FCC Filing Due by January 10, 2020:
FCC Filing Due by March 30, 2020:
Please note that even though the deadline to file the first annual Children’s Television Report is March 30, 2020, stations must still upload quarterly Children’s Advertising Limits compliance certifications to their public files by January 10, 2020. After that, stations will no longer need to file Children’s Advertising Limits certifications each quarter. Instead, stations will file an annual certification that will be due by January 30 of each year.
Here is a description of the various reports that stations must file:
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. 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.
IV. Repack Progress Report Filings
All full power and Class A TV stations that are being repacked (except those stations that have fully completed the repack process), and all television stations transitioning to new channels as a result of the Broadcast Incentive Auction, must file a quarterly Progress Report. Such stations include band-changing stations and displaced Class A stations.
V. 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 compliance with the children’s educational programming requirements during the preceding reporting period.
If you have any questions about these ongoing recordkeeping and related obligations, please contact any attorney in our office.