TV Stations’ First Ever Quarterly Transition Progress Report Due October 10

As we noted back in April (has it really been that long ago?) when the FCC first announced the TV spectrum repack deadlines, TV stations being repacked now have yet another quarterly filing obligation.  Television stations transitioning to a new channel in the repack must file a quarterly Transition Progress Report by the 10th of October, January, April, and July.  Yesterday, the FCC issued a Public Notice reminding stations of this obligation.

Each transitioning television station must electronically file the report (FCC Form 387) informing the FCC and public of the station’s progress towards constructing facilities on its newly-assigned channel and terminating operations on its current channel.  The quarterly reporting requirement will continue for each repacked station until the station has completed its transition and filed a final report indicating that it has done so.

While it is still early in the transition process, it is a mistake to assume that stations will have little to report in this first filing.  The Form 387 asks a number of baseline questions, such as whether a station needs to conduct a structural analysis of its tower, obtain any non-FCC permits or FAA Determinations of No Hazard, or order specific types of equipment to complete the transition.

Depending on a station’s response to a question, the electronic form will then ask for additional information regarding that particular subject.  For example, if a station indicates that it needs to make structural changes to its tower, it will be prompted to provide information about whether those changes are major and if so, whether they have been scheduled or completed.  In some cases, narrative responses may be necessary.

Ultimately, the form requires each station to indicate whether it anticipates that it will receive its equipment and complete any needed tower work in time to meet the construction deadline for its transition phase.

Don’t let the simple Yes/No appearance of the Form 387 fool you.  It requires input from both engineering and management personnel, and future reports will then be compared against the baseline it creates.  In other words, it would be a mistake to merely leave the task to the person who handles your other quarterly FCC reports as you walk out the station door.  You’ll likely be getting a panicked call from them shortly thereafter.