Here Are Those Upcoming Broadcast and Telecom Filing Deadlines

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Communications law firm Fletcher Heald & Hildreth has taken to its Commlawblog.com website to remind broadcast media owners to mark their calendars for FCC filing deadlines for broadcasting and telecommunications.


Whole FHH’s list is not comprehensive, we are pleased to share it with you as a strong guideline for what you and your stations should be working on today.

 

September 1, 2017:

Local Telephone Competition and Broadband Report – Facilities-based providers of broadband services to end-users must report certain broadband deployment data on FCC Form 477.

September 2017 (exact date not known):

Annual Regulatory Fees  On a date not yet determined but certainly before September 30, 2017, annual regulatory fees will be due.  These will be due and payable for most FCC licensees and other regulates for Fiscal Year 2017The 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. We will update you when the finalized due date is announced.

September 27, 2017:  

EAS National Test – Participants’ ETRS Form Two Due–  All EAS participants must be prepared for the national EAS test on September 27 at 2:20 p.m. EDT.  Additionally, all participants must prepare and file in the EAS Test Reporting System (ETRS) a Form Two for each station by 11:59 p.m. EDT on September 27.  This form is scheduled to become available at 2:20 p.m. EDT, immediately following the EAS test and will provide basic information as to the results of the test, and whether the participant experienced any problems in receiving or sending the test message.

October 1, 2017:

EEO Public File Reports – All radio and television stations with five or more full-time employees located in Alaska, American Samoa, Florida, Guam, Hawaii, Iowa, Mariana Islands, Missouri, Oregon, Puerto Rico, the Virgin Islands, and Washington must place EEO Public File Reports in their public inspection files.  TV stations must upload the reports to the online public file.  For all stations with websites, the report must be posted there as well.

EEO Mid-Term Reports – All radio stations with eleven or more full-time employees in Alaska, American Samoa, Guam, Hawaii, the Mariana Islands, Oregon, or Washington, and all television stations with five or more full-time employees in Iowa or Missouri, must electronically file a mid-term EEO report on FCC Form 397, with the last two EEO public file reports attached.

October 10, 2017:

Children’s Television Programming Reports – For all commercial full-power television and Class A television stations, the third quarter 2017 Children’s Television Programming Reports must be filed electronically with the FCC.  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.  Please note that as has been the case for some time now, the required use of the Licensing and Management System for the Children’s reports means that the licensee FRN and password are necessary to log in; therefore, you should have that information at hand before you start the process.

Commercial Limits Compliance Certifications  For all commercial full-power television and Class A television stations, a certification of compliance with the limits on commercials during programming for children ages 12 and under, including the restrictions on the display of website addresses, or other evidence to substantiate compliance with those limits, must be uploaded to the online public inspection file.

Issues/Programs Lists – For all commercial and non-commercial radio, full-power 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 public inspection file.  Radio stations in the top 50 markets and in an employment unit with five or more full-time employees will have to place these reports in the new online public inspection file, while all other radio stations may continue to place hard copies in the paper file for the time being.  Television and Class A television stations will continue to upload them to the online 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.

Class A Television Continuing Eligibility Documentation – The FCC 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.

December 1, 2017:   

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 LPTV stations must file a biennial ownership report reflecting ownership information as of October 1, 2017.  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. For the first time, noncommercial and commercial entities are required to file by the same date.  Additionally, all persons holding an attributable interest in a commercial broadcast licensee must have acquired either an FCC Registration Number (FRN) or Restricted Use FRN.

DTV Ancillary Services Statements – All DTV licensees and permittees must file a report in the LMS filing system stating whether they have offered any ancillary or supplementary services together with their broadcast service during the previous fiscal year.  Please note that the group required to file includes Class A TV, LPTV, and TV translator stations that are offering digital broadcasts.  If a station has offered such services, and has charged a fee for them, then it must separately submit a payment equal to five percent of the gross revenues received and an FCC Remittance Advice (Form 159) to the Commission.  The report specifically asks for a list of any ancillary services, whether a fee was charged, and the gross amount of revenue derived from those services.  Ancillary services do not include broadcasts on multicast channels of free, over-the-air programming for reception by the public.


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