November is perhaps the month with the lightest schedule of routine FCC regulatory filing obligations – with no requirements for EEO Public File Reports, Quarterly Issues Programs or Children’s Television Reports. Nor are there other routine obligations that come up in the course of any year, though during November of 2019, broadcasters will be preparing for next year’s December 1 Biennial Ownership Report deadline. So does that mean that there are no dates of interest this month for broadcasters? As always, there are always a few dates of which you need to keep track.
The one November date applicable to all broadcasters is the requirement for the filing of ETRS Form Three, which gives a detailed analysis of the results of the nationwide EAS test conducted on October 3. Stations should have filed Form Two on the day of the test reporting whether or not the test was received. They now need to follow up with the more detailed Form Three report by November 19. See our article here for more information.
The FCC has also recently asked for public comment on its estimate of the specific costs that will be incurred by LPTV and TV translator stations and FMs that are affected by the incentive auction and the repacking of the TV band. The list will be used in determining when an item of reimbursement can be routinely paid, and when a reimbursement request exceeds the expected cost and requires further justification. See our article here for more information. Comments on the FCC’s cost estimates are due November 21.
“Long form” applications for licensees of Class A and B AM stations that filed for FM translators in the FCC’s second translator window, and which resolved situations where their applications were found to be mutually exclusive with other applicants, must be filed by November 5. These long-form applications set out the technical specifics of the translator to be constructed, as the initial translator short-form filings just provided very basic information about the proposal. See our article here for more information.
As always, there may be other proceedings out there that could affect your operations, and any station may be facing deadlines unique to that station, so always consult your own advisors for other deadlines of importance to you.
