The FCC on Friday released a Public Notice announcing that they are giving stations more time in which to upload their Quarterly Issues Programs lists to their online public file and to file their first Annual Children’s Television Report. In our list of April regulatory dates for broadcasters last week, we had highlighted both of those filings. Because of the disruption of the schedules of so many people, and the lack of access to many broadcast stations, the FCC appears to have decided that broadcasters should get more time to meet these regulatory obligations.
Quarterly Issues Programs lists are required to be uploaded to the online public inspection file of all full-power stations every quarter – and would normally be required to be in the public file by April 10. While urging stations to upload those lists as soon as possible, the Commission has given stations until July 10 (when the next quarter’s lists will be due) to upload this quarter’s report. So the two reports could be uploaded at the same time.
The first-ever Annual Children’s Television Report was to be filed with the FCC by March 30, reporting on educational and informational programming directed to children since the effective date of the new children’s television rules (see our blog article here about the revised rules). The report would normally be due in January, but was delayed until March 30 to give broadcasters time to become familiar with the new forms (see our article here). Now, those reports must be filed by July 10, 2020.
In the Public Notice, the FCC notes that other public file and FCC filing obligations remain in place. For instance, the FCC has not extended the date for filing license renewal applications by radio stations in Tennessee, Kentucky and Indiana, due on April 1. The Commission has expressed its willingness to be lenient in granting extensions of these filings and others upon request, but the deadlines remain unless specifically extended. Similarly, other public file obligations (including the requirement to upload information about political ad sales and other candidate uses) remain in effect.
The two extensions granted on Friday are additional indications that the FCC recognizes the disruption caused by the COVID-19 pandemic. These follow other actions we’ve written about, including relief for stations in Phase 9 of the television repacking, guidance on the impact of special flights of free advertising spots on lowest unit rates, and relief for newsgathering activities exempting temporary pooling arrangements from public file requirements under shared services agreement rules and liberalized waivers of attribution rules for TV news sharing agreements that exceed 15% of a station’s programming time. The FCC is doing its best to assist broadcasters in coping with the sudden realities of today’s business in these most unusual times.
Courtesy Broadcast Law Blog