In a Public Notice (“Notice”) released late this afternoon (March 27), the FCC announced that, as a result of the “fluid and challenging situation caused by” COVID-19, it is extending: (1) the deadline by which commercial TV stations must file the first annual Children’s Television Programming Report, from March 30 to July 10, and (2) the deadline by which all broadcasters must upload to their OPIFs the First Quarter 2020 Issues/Programs List, from April 10 to July 10. Note that, as a result, the filing deadline for both the First Quarter and Second Quarter Issues/Programs Lists will be the same date.
The Commission in the Notice explains that it is extending these two deadlines to provide broadcasters flexibility during this time. The Commission also states that, despite the extensions, licensees are encouraged to file their Children’s Television Programming Report and their Quarterly Issues/Programs lists “as soon as practicable.” We strongly recommend that stations go ahead and prepare and file and/or upload their materials by the original deadline if possible so that they don’t have to think about them later.
Significantly, stations must note that the FCC emphasizes that it is not modifying any requirements or filing deadlines related to stations’ political files, nor is it at this time modifying any other filing obligations or deadlines related to broadcasters’ public files. In particular, the FCC did not extend certain other upcoming deadlines. For example:
- Class A television stations must still upload to their Online Public Inspection Files their First Quarter 2020 Class A Eligibility Certifications by April 10;
- Certain full power and Class A TV stations must still file their First Quarter 2020 Transition Plan Progress Reports (Form 387) by April 10; and
- Eligible NCE stations that engaged in on-air third-party fundraising during First Quarter 2020 must still upload to their OPIFs their First Quarter 2020 third-party fundraising reports by April 10.
Please let us know if you have questions regarding the above. Of course, we’ll keep you posted if the FCC extends any other deadlines during the COVID-19 emergency.