quarterly childrens television report

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July brings the obligation for each full-power broadcaster to add a new Quarterly Issues Programs List to their online public inspection file. These reports, summarizing the issues facing each station’s community of license in the prior three months and the programs broadcast by the station to address those issues, must be added to the public file by July 10. As we wrote here, these reports are very important – as they are the only documents legally required by the FCC to show how a station served the public interest. With the online file, these reports can be reviewed by anyone with an Internet connection at any time, which could be particularly concerning for any station that does not meet the filing deadline, especially with license renewals beginning again next year.

Also to be filed with the FCC by July 10, by full-power and Class A TV stations, are Quarterly Children’s Television Reports. While the FCC announced last week that it will be considering a rulemaking proposal at its July meeting to potentially change the rules (see its proposed Notice of Proposed Rulemaking here), for now the requirements remain in place obligating each station to broadcast 3 weekly hours of programming designed to meet the educational and informational needs of children for each free program stream transmitted by the station. Also, certifications need to be included in each station’s online public file demonstrating that the station has complied with the rules limiting the amount of commercialization during children’s television programs.
Continue Reading July Regulatory Dates for Broadcasters – Quarterly Issues Programs Lists and Children’s Television Reports, EAS Reform, LPFM and FM Translators, C Band Earth Stations and More

April brings with it a milestone – as it is the end of the first quarter since all radio stations have had to have their online public inspection file “live” so that anyone, anywhere, can view a station’s compliance with rules that previously could only be judged by going to the station and reviewing the paper public file. April 10, in particular, is important, as it is when Quarterly Issues Programs Lists, summarizing the most important issues facing the community which the broadcaster serves and the programs that the broadcaster aired to address those issues, must be in the online public file for all full-power radio and TV stations. We wrote about the importance of these sometimes overlooked documents here, as these are the only FCC-mandated documents that reflect how a station has served the needs and interests of its community. We have also noted that, in the past license renewal cycle, missing Quarterly Issues Programs lists were the source of the most fines issued to broadcasters. Now that compliance can be judged at any time by the FCC, their importance is only magnified. So be sure that you get these documents into your online public file by April 10.

EEO Public Inspection File Reports, summarizing a station’s employment record for the prior year, are also to be uploaded to a station’s online public file. For radio and TV stations in Delaware, Indiana, Kentucky, Pennsylvania, Tennessee, and Texas, these reports need to be completed and included in the public file by April 1 by all stations that are part of employment units with 5 or more full-time (30 hours per week) employees. In addition, radio stations in employment units with 11 or more full-time employees in Delaware and Pennsylvania, and TV stations in Texas with 5 or more full-time employees, also need to file EEO Mid-Term Reports, commonly referred to as FCC Form 397 applications. While the FCC is considering the abolition of the Mid-Term Report (see our article here), the obligation is still in place so, for now, stations must comply.
Continue Reading April Regulatory Dates for Broadcasters – First Quarterly Issues Programs Lists in Online Public File for All Radio Stations and Other Important Dates

The holidays are over, and while the regulation never stops, it is time to once again buckle down and look at what is on the horizon for broadcasters. While, in the next few days, we will have our typical look ahead at the broadcast regulatory agenda in Washington for the New Year, we also need to look at more immediate deadlines in the month of January. As we are at the beginning of a calendar quarter, the tenth of the month is the date for broadcasters to add their Quarterly Issues Programs Lists for the just completed quarter to their public file – whether it be the online public file for TV broadcasters and the many radio groups that have already converted to the online file, or into the paper file for those radio broadcasters waiting until the last minute before making the conversion to the online file as required by March 1. These Quarterly Issues Programs lists are the only FCC-required documents showing how a broadcaster has met its public interest obligations to serve their communities and, as we have written many times (see, for instance, here and here), the FCC considers them to be very important, and thus have led to numerous substantial fines for broadcasters who have not met the FCC’s requirements.

TV broadcasters also need to file their Children’s Television Reports with the FCC by the 10th of the month, and place information into their public file about how they complied with the commercial limits on children’s television programming. As we have written before (see our articles here and here), these, too have been the subject of numerous FCC enforcement actions when the Commission becomes aware that the reports were not filed, or were submitted late. So be sure to timely file these reports with the FCC, and place the information about compliance with the commercial limits in your online public file by the deadline.
Continue Reading January Regulatory Dates for Broadcasters – Quarterly Issues Programs Lists and Children’s Television Reports, FM Translator Window, Main Studio Rule Change and Streaming Requirements

The beginning of a calendar quarter always brings numerous regulatory obligations, and October is one of those months with a particularly full set of obligations. All full-power broadcasters, commercial and noncommercial, must complete their Quarterly Issues Programs Lists and place these reports into their public inspection files by October 10. These reports are the FCC’s only official record of how a station served its community. They document the broadcaster’s assessment of the most important issues facing their communities, and the programming that they have broadcast to address those issues. Failing to complete these reports was the biggest source of fines during the last license renewal cycle – with fines of $10,000 or more common for stations missing numerous reports during the license renewal term (see, for example, our articles here, here and here). With the public inspection file for all TV stations now being online and the public file of large radio groups in major markets also already converted to being online, the timeliness of the completion of these reports and their inclusion in the public file can now be assessed by the FCC and anyone else who wants to complain about a station’s regulatory compliance (as documents added to the public file are date stamped as to their inclusion, and the FCC has used this stamp to assess station’s compliance in other areas, see our post here). All other radio stations will be converting to the online file by March 1, 2018 and will need to upload this quarter’s reports into the file by that date (along with all others back to your last license renewal, see our post here), meaning the reports they complete this quarter too can be scrutinized from afar. Thus, be sure that you complete this important requirement.

TV stations have the additional quarterly obligation of filing with the FCC by October 10 their Quarterly Children’s Television Reports, Form 398. These reports detail the educational and informational programming directed to children that the station broadcast in the prior quarter. These reports are used to assess the station’s compliance with the current obligation to broadcast at least 3 hours per channel of programming addressing the educational and informational needs of children aged 16 or younger. Late-filed Children’s Television Reports, too, were the source of many fines for TV broadcasters in the last renewal cycle (see, for instance, our articles here and here), so don’t forget this obligation and don’t be late in making the required filings. At the same time, TV stations should also include in their public file documentation showing that they have complied with the limitations on commercialization during children’s programming directed to children 12 and under.
Continue Reading October Regulatory Dates for Broadcasters – Quarterly Issues Programs and Children’s Television Reports, EEO Obligations, Repacking Reports and More

The FCC announced a Consent Decree with a New Jersey TV station where the licensee agreed to make a $17,500 payment to the US Treasury for failing to identify “core” educational and informational programming directed to children with the required “E/I” symbol on the programming itself. This programming was, according to the consent decree, run…

July is a big month on the Washington regulatory scene for broadcasters. There are, of course, the routine quarterly regulatory obligations. For all stations, commercial and noncommercial, Quarterly Issues Programs Lists, summarizing the most important issues facing a broadcaster’s community, and the programs that were broadcast in the prior quarter to address those issues, must be in a station’s public file (the online public file for all TV stations and for radio stations that have already converted to the online file) by July 10. These are the only required records documenting a station’s service to its community, so do not forget to complete these reports and to timely place them in your public file.

Children’s Television Reports documenting the educational and informational programing broadcast by TV stations to meet their obligation to program at least three hours a week of such programming for each program stream are due to be filed at the FCC by July 10. Also, TV stations must place into their public file documentation showing that they have met the advertising limits imposed on commercials during children’s programming.
Continue Reading July Regulatory Dates for Broadcasters – Quarterly Issues Programs and Children’s Television Reports, Comment Dates on Main Studio Rule Elimination and Modernization of Media Regulation, Incentive Auction CP Filing Deadline, Effective Date for Captioning Clips of Live and Near-Live Programming, and Window for FM Translators for AM Stations

April has many important dates for broadcasters – both radio and TV.  This includes both regular regulatory obligations and dates unique to this April for both radio and TV – including the release of the FCC’s Closing Notice for the TV incentive auction and the effective date for the new rules liberalizing the location of FM translators used to rebroadcast AM stations.

The regular dates include the requirement for commercial and noncommercial full-power and Class A Television Stations and AM and FM Radio Stations in Delaware, Indiana, Kentucky, Pennsylvania, Tennessee, and Texas that they, by April 1, add to their public file (and upload to their websites for stations that have not yet converted to the FCC’s online public file) their Annual EEO Public File Report if the station is part of an Employment Unit with 5 or more full-time employees.  For Radio Stations in Texas which are part of an employment unit with 11 or more full-time employees; and for Television Employment Units with five or more full-time employees in Indiana, Kentucky, and Tennessee, by April 3 (as April 1 is on the weekend), these stations must file with the FCC their EEO Mid-Term Reports (see our summary of this requirement here).  The Mid-Term Report includes the last two EEO public file reports for these stations and other information about the station’s EEO program. 
Continue Reading April Regulatory Dates for Broadcasters – Quarterly Issues Programs Lists and Children’s Television Reports, Incentive Auction Closing Notice, AM Translator Site Relocation Relaxation Effective Date

Here we are at the start of a new year, and right away we have numerous regulatory deadlines for broadcasters. By the 10th of the month, all broadcast stations need to have placed in their public inspection files (online for TV and for those radio stations that have already converted to the online public file, and paper for the remaining radio stations), their Quarterly Issues Programs lists, documenting the issues of importance to their communities and the programs broadcast in the last quarter addressing those issues. TV stations have quarterly Children’s Television Reports due to be filed at the FCC by the 10th, addressing the programming that they broadcast to meet the educational and informational needs of children. Commercial TV stations should also add to their public file documentation to demonstrate their compliance with the commercial limits in programming addressed to children.

For TV stations, on the 1st of the year, new obligations became effective for online captioning. “Montages” of clips from TV programs, where all of those clips were captioned when broadcast, also need to be captioned when made available online. By July 1, clips of live and near-live programming must be captioned; however, they may be posted online initially without captions as long as captions are added to clips of live programming within 12 hours and to clips of near-live programming within eight hours after the conclusion of the TV showing of the full-length programming. For more on this requirement, see our article here.
Continue Reading January Regulatory Dates for Broadcasters – Quarterly Issues Programs Lists and Children’s Television Reports, Ownership and EEO Comments, Copyright Issues and More

Another month has started – and it is one with regulatory dates for broadcasters. All broadcasters, commercial and noncommercial, have an obligation to complete their Quarterly Issues Programs lists and place them into their public inspection filed by October 10. For TV stations and large-market commercial radio, that means that these lists need to be in the online public file by that date (see our article here about the online public file for radio). For TV stations, the 10th also brings the obligation to submit Quarterly Children’s Television Reports on Form 398 to the FCC (as the 10th falls on a Federal holiday, you may be able to file on the 11th, but consult your legal advisor for details on that deadline).

For stations in Alaska, Florida, Hawaii, Iowa, Missouri, Oregon, Washington, American Samoa, Guam, the Mariana Islands, Puerto Rico, Saipan, and the Virgin Islands that are part of employment units with 5 or more full-time employees (30 hours a week or more), EEO public inspection file reports should have been included in their public inspection file by October 1. For Radio Station Employment Units with 11 or more full-time employees in Iowa and Missouri and Television Employment Units with five or more full-time employees in Florida, Puerto Rico, and the Virgin Islands, Mid-Term EEO Reports on FCC Form 397 should also have been filed at the FCC by October 1. See our article here on the obligation to submit Mid-Term EEO Reports.
Continue Reading October Regulatory Dates for Broadcasters – Quarterly Issues Programs Lists and Children’s Television Reports, EEO Obligations, Noncommercial Biennial Ownership Reports, and Incentive Auction Comment Deadlines

While TV broadcasters can enjoy an incentive auction respite in July as attention shifts to the “forward auction” where we will see whether wireless carriers come up with enough money to fund the $86,422,558,704 (plus $1.75 billion for repacking costs, plus auction-related administrative costs) needed for the buyout of TV stations who agreed to surrender their spectrum, radio broadcasters will get some of their own attention as, at the end of the month, the second window for the filing of 250-mile waiver applications opens for Class A and B AM stations. We wrote about these waivers here, which allow an AM licensee to acquire an FM translator and file an application to move it up to 250 miles and operate it on any commercial frequency that does not create interference in their market. That window for Class A and B AM stations opens July 29 and runs through October 31 (and remains open for any other AM that has not already filed one of these waivers in the first window which opened back in January).

In addition to the AM window, there are routine filing deadlines for all TV stations – required to file their FCC Form 398 Children’s Television Reports by the 11th of the month (because the 10th of July is a Sunday) demonstrating the educational and informational programming they broadcast directed to children. By the 10th television stations also need to upload information into their online public files to demonstrate compliance with the limits on commercial time in children’s programs.
Continue Reading July Regulatory Dates for Broadcasters – FM Translators for Class A and B AMs; Quarterly Issue Programs and Children’s Television Reports; Comments on EAS, Letters from the Public and Regulatory Fees, Cable Royalty Claims; and More