January 10, 2023
Issues/Programs Lists – For all commercial and noncommercial radio, television, and Class A television stations, listings of each station’s most significant treatment of community issues during the fourth quarter of 2022 (October, November, December) must be placed in the station’s OPIF. The lists should include brief narratives describing the issues covered and the programs which provided the coverage, with information concerning the time, date, duration, and title of each program with a brief description of the program. The issues may be either local or national, so long as they are of concern to the local community.
Foreign Government-Provided Programming Disclosures – In the event that a station, pursuant to the sale of a block of time, aired any programming provided by a foreign governmental entity during the prior quarter, copies of the required disclosures and records relating to the programming must be posted in the OPIF.
Records of Third-Party Fundraising Efforts – Any noncommercial educational broadcast station that interrupts regular programming to conduct fundraising activities on behalf of a third-party non-profit organization must post records of such activities during the prior quarter in the station’s OPIF.
Class A Television Stations Continuing Eligibility Documentation – The Commission 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.
January 30, 2023
Children’s Television Programming Reports – Each commercial TV and Class A television station must electronically file its annual Children’s Television Programming Report, on FCC Form 2100 Schedule H, to report on programming aired by the station and other efforts in 2022 that were specifically designed to serve the educational and informational needs of children.
Commercial Compliance Certifications – Each commercial TV and Class A television station must also post to its OPIF a certification (or certifications) of compliance during 2022 with the statutory limits on commercial time during children’s programming. The certification(s) should cover both the primary programming stream and all subchannels aired by the station.
February 1, 2023
Television License Renewal Applications Due – Applications for renewal of license for television stations located in New Jersey and New York must be filed in LMS. These applications must be accompanied by Schedule 396, the Broadcast EEO Program Report, also filed in LMS, regardless of the number of full-time employees. Under the current public notice rules, television stations (including LPTV stations that originate programming) filing renewal applications must begin broadcasts of their post-filing announcements concerning their license renewal applications between the date the application is accepted for filing and five business days thereafter and must continue for a period of four weeks. Once complete, TV stations must post a certification of broadcast, with a copy of the announcement’s text, to the Online Public Inspection File (OPIF) within seven days. LPTV stations that do not originate programming and TV translators must post renewal notice texts on an acceptable website (station, licensee, parent or as otherwise described by the FCC), linked under the title FCC Applications, within five business days after the date on which the FCC issues PN of the acceptance of the renewal application and must remain posted for 30 days.
EEO Public File Reports – All radio and television station employment units with five or more full-time employees and located in Arkansas, Kansas, Louisiana, Mississippi, Nebraska, New Jersey, New York, and Oklahoma must place EEO Public File Reports in their OPIFs. For all stations with websites, the report must be posted there as well. Per announced FCC policy, the reporting period may end ten days before the report is due, and the reporting period for the next year will begin on the following day.
Courtesy Fletcher, Heald & Hildreth, PLC