By July 10, 2020, full power and Class A television stations must file quarterly reports for the second quarter of 2020.
In addition, stations that have not yet uploaded their quarterly issues responsive programming lists for the first quarter of 2020 should do so by July 10. In March, the FCC extended the filing deadlines for first quarter reports to July 10, 2020 due to the challenges stations faced because of the COVID-19 pandemic. Annual children’s television programming reports that were originally due January 30, 2020 are also due by July 10.
Documents That Must Be Uploaded to Each Station’s Online Public Inspection File by July 10, 2020:
• All commercial and noncommercial television stations: Issue-Responsive Programming List for programming broadcast between April 1, 2020 and June 30, 2020. Stations that have not yet uploaded their first quarter reports, which cover the January 1, 2020 – March 31, 2020 time period, must also upload those reports by July 10.
• Class A TV stations only: Documentation that the station continues to meet Class A eligibility requirements
FCC Filings Due by July 10, 2020:
• Annual children’s television programming report
• Repacked full power and Class A stations, and transitioning stations: Progress Report
Here is a description of the 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 issues.
II. 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.
III. Annual Children’s Television Report
Commercial television and Class A stations must file an annual Children’s Television Programming Report with the FCC. The report documents commercial broadcasters’ compliance with the children’s educational programming requirements.
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.
If you have any questions about these ongoing recordkeeping obligations, please contact any attorney in our office.