Could Filing of FCC Quarterly Issues/Programs Lists be Affected by a Federal Shutdown?

posted on 9.25.2023

Broadcasters are advised to be mindful of the looming potential federal government shutdown.

Attorneys at TAB’s longtime FCC counsel, Pillsbury Winthrop Shaw Pittman, are cautioning stations that the FCC has not indicated how a such a shutdown could affect online filings such as the Third Quarter Issues/Programs List.

Accordingly, stations should consider uploading the report closer to the end of September rather than by the due date of Oct. 10.

The Third Quarter Issues/Programs List covers the period from July 1 to Sept. 30.

“The FCC requires each broadcast station to air a reasonable amount of programming responsive to significant community needs, issues, and problems as determined by the station,” said attorneys Scott Flick and Elizabeth Craig.

“The FCC gives each station the discretion to determine which issues facing the community served by the station are the most significant and how best to respond to them in the station’s overall programming.”

Flick and Craig have prepared the law firm’s latest informative advisory on satisfying the quarterly report’s requirements.

It includes a helpful sample template for organizing the report information as well as guidance on the report’s contents.

TAB urges stations to timely file the reports as fines can be significant.

Last week the FCC’s Media Bureau issued a proposed $6,000 forfeiture notice to a Texas television station for “failing to timely file the Station’s TV quarterly issues/programs lists (IP Lists) in violation of section 73.3526(e)(11)(i) of the Rules.”

The station self-admitted its failure to timely upload 12 reports during its recent license renewal filing.

TAB notes that a station’s Online Public Inspection File is accessible 24/7, so FCC staff can review your station’s timeliness in filing IP lists whenever they choose, not just during a station’s license renewal period.

Questions? Contact TAB’s Michael Schneider or call (512) 322-9944.

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