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Full power commercial and noncommercial radio stations and LPFM stations licensed to communities in Arkansas, Louisiana, and Mississippi must begin airing pre-filing license renewal announcements on December 1, 2019. 

Full power commercial and noncommercial radio stations and LPFM stations licensed to communities in Arkansas, Louisiana, and Mississippi must begin airing pre-filing license renewal announcements on December 1, 2019.  License renewal applications for these stations, and for in-state FM translator stations, are due by February 1, 2020.  Note that because this filing deadline falls on a weekend, submission of the license renewal application may be made on February 3.  However, the post-filing license renewal announcement for that day (discussed below) must still be made on February 1.

Full power commercial and noncommercial radio and LPFM stations must air four pre-filing announcements alerting the public to the upcoming renewal application filing.  As a result, these radio stations must air the first pre-filing renewal announcement on December 1.  The remaining pre-filing announcements must air once a day on December 16, January 1, and January 16, for a total of four announcements.  At least two of these four announcements must air between 7:00 am and 9:00 am and/or 4:00 pm and 6:00 pm.

The text of the pre-filing announcement is as follows:

On [date of last renewal grant], [call letters] was granted a license by the Federal Communications Commission to serve the public interest as a public trustee until June 1, 2020.  [Stations that have not received a renewal grant since the filing of their previous renewal application should modify the foregoing to read: “(Call letters) is licensed by the Federal Communications Commission to serve the public interest as a public trustee.”]

Our license will expire on June 1, 2020.  We must file an application for renewal with the FCC by February 1, 2020.  When filed, a copy of this application will be available for public inspection at www.fcc.gov.  It contains information concerning this station’s performance during the last eight years [or other period of time covered by the application, if the station’s license term was not a standard eight-year license term].  Individuals who wish to advise the FCC of facts relating to our renewal application and to whether this station has operated in the public interest should file comments and petitions with the FCC by May 1, 2020.

Further information concerning the FCC’s broadcast license renewal process is available at [address of location of the station][1] or may be obtained from the FCC, Washington, DC 20554, www.fcc.gov.

If a station misses airing an announcement, it should broadcast a make-up announcement as soon as possible and contact counsel to further address the situation.  Special rules apply to noncommercial educational stations that do not normally operate during any month when their announcements would otherwise be due to air, as well as to other silent stations.  These stations should also contact counsel regarding how to give the required public notice.

Post-Filing License Renewal Announcements

Once the license renewal application has been filed, full power commercial and noncommercial radio and LPFM stations must broadcast six post-filing renewal announcements.  These announcements must air, once per day, on February 1 and February 16, 2020, as well as March 1, March 16, April 1, and April 16, 2020.  At least three of these announcements must air between 7:00 am and 9:00 am and/or 4:00 pm and 6:00 pm.  At least one announcement must air in each of the following time periods: between 9:00 am and noon, between noon and 4:00 pm, and between 7:00 pm and midnight.

The text of the post-filing announcement is as follows:

On [date of last renewal grant], [call letters] was granted a license by the Federal Communications Commission to serve the public interest as a public trustee until June 1, 2020.

Our license will expire on June 1, 2020.  We have filed an application for renewal with the FCC.

A copy of this application is available for public inspection at www.fcc.gov.  It contains information concerning this station’s performance during the last eight years [or such other period of time covered by the application, if the station’s license term was other than a standard eight-year term].

Individuals who wish to advise the FCC of facts relating to our renewal application and to whether this station has operated in the public interest should file comments and petitions with the FCC by May 1, 2020.

Further information concerning the FCC’s broadcast license renewal process is available at [address of location of the station] or may be obtained from the FCC, Washington, DC 20554, www.fcc.gov.

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This Pillsbury Broadcast Station Advisory is directed to radio and television stations in the areas noted above, and highlights upcoming deadlines for compliance with the FCC’s EEO Rule.

December 1 is the deadline for broadcast stations licensed to communities in Alabama, Colorado, Connecticut, Georgia, Maine, Massachusetts, Minnesota, Montana, New Hampshire, North Dakota, Rhode Island, South Dakota, and Vermont to place their Annual EEO Public File Report in their Public Inspection File and post the report on their station website.  In addition, certain of these stations, as detailed below, must submit their two most recent EEO Public File Reports along with FCC Form 2100, Schedule 396 as part of their license renewal application submissions due on December 1.

Under the FCC’s EEO Rule, all radio and television station employment units (“SEUs”), regardless of staff size, must afford equal opportunity to all qualified persons and practice nondiscrimination in employment.

In addition, those SEUs with five or more full-time employees (“Nonexempt SEUs”) must also comply with the FCC’s three-prong outreach requirements.  Specifically, Nonexempt SEUs must (i) broadly and inclusively disseminate information about every full-time job opening, except in exigent circumstances, (ii) send notifications of full-time job vacancies to referral organizations that have requested such notification, and (iii) earn a certain minimum number of EEO credits, based on participation in various non-vacancy-specific outreach initiatives (“Menu Options”) suggested by the FCC, during each of the two-year segments (four segments total) that comprise a station’s eight-year license term.  These Menu Option initiatives include, for example, sponsoring job fairs, participating in job fairs, and having an internship program.

Nonexempt SEUs must prepare and place their Annual EEO Public File Report in the Public Inspection Files and on the websites of all stations comprising the SEU (if they have a website) by the anniversary date of the filing deadline for that station’s license renewal application.  The Annual EEO Public File Report summarizes the SEU’s EEO activities during the previous 12 months, and the licensee must maintain adequate records to document those activities.  As discussed below, nonexempt SEUs must submit to the FCC their two most recent Annual EEO Public File Reports when they file their license renewal applications.

For a detailed description of the EEO Rule and practical assistance in preparing a compliance plan, broadcasters should consult The FCC’s Equal Employment Opportunity Rules and Policies – A Guide for Broadcasters published by Pillsbury’s Communications Practice Group.  This publication is available at: http://www.pillsburylaw.com/publications/broadcasters-guide-to-fcc-equal-employment-opportunity-rules-policies. Continue reading →

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The Federal Communications Commission released a Public Notice reminding broadcast licensees that the filing window for Broadcast Biennial Ownership Reports (FCC Form 323 and 323-E) will open on November 1, 2019.  All licensees of commercial and noncommercial AM, FM, full-power TV, Class A Television and Low Power Television stations must submit their ownership reports by January 31, 2020.

We previously reported that the FCC had modified the dates for the filing window.  At that time, the FCC explained that there would be “additional technical improvements” that required the FCC to delay the opening of the filing window.  Now, we know more about those improvements.

In particular, the FCC modified its filing system to permit parties to validate and resubmit previously-filed ownership reports, so long as those reports were submitted through the current filing system.  Further, filers will be able to copy and then make changes to information included in previously-submitted reports.  The FCC also created a new search page dedicated solely to reviewing submitted ownership reports.

As a reminder, biennial ownership reports submitted during this filing window must reflect the ownership interests associated with the facility as of October 1, 2019, even if an assignment or transfer of control was consummated after October 1, 2019.

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Pillsbury’s communications lawyers have published FCC Enforcement Monitor monthly since 1999 to inform our clients of notable FCC enforcement actions against FCC license holders and others.  This month’s issue includes:

  • Virginia FM Station’s Years of Missing Quarterly Lists Lead to Proposed $15,000 Fine and a Reduced License Term
  • FCC Investigates Ohio College Station Over Unauthorized Silence and Scheduling Violation
  • New York Amateur Radio Operator’s Threats and Harmful Interference Lead to Proposed $17,000 Fine

Feeling Listless: Virginia Station With Years of Missing Quarterly Issues/Programs Lists Hit with Proposed $15,000 Fine, Shortened License Term

In a Memorandum Opinion and Order and Notice of Apparent Liability for Forfeiture, the FCC found that a Virginia FM station failed to prepare and upload eight years’ worth of Quarterly Issues/Programs lists, resulting in a proposed $15,000 fine.  The FCC also indicated it would grant the station’s license renewal application, but only for an abbreviated two-year license term.

As we noted in a recent advisory, the FCC requires each broadcast station to maintain and place in the station’s online Public Inspection File a Quarterly Issues/Programs List reflecting the “station’s most significant programming treatment of community issues during the preceding three month period.”  At license renewal time, the FCC may review these lists to determine whether the station met its obligation to serve the needs and interests of its local community during the license term.  The FCC has noted this and other such “public information requirements” are “integral components of a licensee’s obligation to serve the public interest and meet its community service obligations.”

Starting with TV stations in 2012, the FCC has required stations to transition their physical local Public Inspection Files to the FCC’s online portal.  By March 1, 2018, all broadcast radio stations were required to have uploaded the bulk of their Public File materials to the online Public Inspection File and maintain the online file going forward.  At license renewal time, licensees must certify that all required documentation has been placed in a station’s Public Inspection File in a timely fashion.  The license renewal cycle for radio stations began in June of this year.

In its license renewal application, the FM station admitted that it had run into some “difficulties” with the online Public Inspection File and had not met “certain deadlines.”  In the course of its investigation, the Media Bureau found that the licensee had in fact failed to prepare any Quarterly Issues/Program Lists during the preceding eight-year license term, and, as a result, also failed to upload the materials to the station’s Public Inspection File.

The FCC’s forfeiture policies establish a base fine of $10,000 for failure to maintain a station’s Public File.  However, the FCC may adjust a fine upward or downward depending on the circumstances of the violation.  Considering the extensive nature of the violations and the station’s failure to disclose its behavior in the years prior to its license renewal application, the Media Bureau increased this amount to $12,000.  The Media Bureau then tacked on an additional $3,000 fine, the base amount for a station’s failure to file required information, for a total proposed fine of $15,000.

Turning to the station’s license renewal application, the Media Bureau deemed the station’s behavior “serious” and representative of a “pattern of abuse” due to years of violations.  As a result, the Bureau indicated it would only grant the station a shortened license term of two years, instead of a full eight-year term, and even then, only assuming the Bureau found no other violations that would “preclude such a grant.”

In a Silent Way: University FM Station Warned Over Unauthorized Silence and Time Share Violation

In a recent Notice of Violation, the FCC cited a northern Ohio university’s FM station for failing to request authorization to remain off-air for several months and for altering the broadcast schedule that it shares with another station on the same frequency without notifying the FCC.

Part 73 of the FCC’s Rules requires a station to broadcast in accordance with its FCC authorization.  While stations are generally authorized to operate for unlimited time, some noncommercial FM stations split time on a shared frequency via a time-sharing agreement.  The FCC will usually only permit a departure from the schedule set forth in a time-sharing agreement once a written and signed agreement to that effect has been filed with the FCC by each licensee.  In the event that circumstances “beyond the control of a licensee” make it impossible for a station to adhere to this schedule or continue broadcasting altogether, the station must notify the FCC by the tenth day of limited or discontinued operation.  A station that expects to be silent for over 30 days must request Special Temporary Authority from the FCC to do so. Continue reading →

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On October 10, 2019, the FCC announced that it will hold a full-power FM Broadcast auction for 130 new construction permits starting on April 28, 2020.  For now, the FCC is seeking comment on the procedures for the auction, although it does not propose any significant changes from past FM broadcast auctions.  In connection with the auction, the FCC also announced a filing freeze prohibiting minor change applications, petitions, or counter-proposals directly affecting or failing to protect the construction permits to be auctioned.

A majority of the construction permits will be for lower-power Class A facilities, but there are 28 new facilities that are authorized to operate at 25 kW or higher.  For example, a Class B facility in Sacramento will be available, along with stations on the outskirts of major cities like Dallas and Seattle.  Overall, Texas is home to the most available permits (32), with numerous opportunities also available in Wyoming (11), California (10), and Arizona (8).

Parties seeking to file comments regarding the list of available construction permits and/or the auction procedures should submit them by November 6, 2019.  Reply comments are due November 20, 2019.  After reviewing the record, the FCC will release the final list of available permits and auction procedures, most likely in early January 2020.

 

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Quarterly documentation of stations’ compliance with their obligations under the Children’s Television Act of 1990 for the Third Quarter of 2019 is due to be placed in stations’ Public Inspection Files by October 10, 2019, and in the case of educational children’s television programming, to be filed electronically with the FCC on that same date. 

Interim Filing Procedures Regarding Educational Children’s Television Programming

The Children’s Television Act of 1990 requires full power and Class A television stations to: (1) limit the amount of commercial matter aired during programs originally produced and broadcast for an audience of children 12 years of age and under, and (2) air programming responsive to the educational and informational needs of children 16 years of age and under.  On July 12, 2019, the FCC adopted a number of changes to its children’s television programming rules, primarily with respect to the educational television programming requirements.  Substantively, the new rules provide broadcasters with additional flexibility in scheduling educational children’s television programming, and modify some aspects of the definition of “core” educational children’s television programming.  These portions of the revisions went into effect on September 16, 2019.

Procedurally, the new rules eliminate quarterly filing of the Children’s Television Programming Report in favor of an annual filing, and change other information collection and reporting provisions.  Unfortunately, the rule changes that affect broadcasters’ reporting requirements have not yet been approved by the Office of Management and Budget, and the report form itself has not been updated to reflect the new substantive requirements.

As a result, for purposes of the quarterly Children’s Television Programming Report due on October 10, 2019, broadcasters should answer all questions regarding such programming that aired prior to September 16, 2019, and should not respond to the question concerning what programming will be aired in the upcoming quarter.  When calculating the average number of hours per week of educational children’s television programming aired, broadcasters should only consider the first 11 weeks of the quarter.  Programming aired on or after September 16, 2019 is to be reported on the station’s next report.

The next report will be broadcasters’ first “annual” Children’s Television Programming Report and will cover the period from September 16, 2019 through December 31, 2019.  That report must be filed by January 30, 2020.

Summary of Changes 

Prior to September 16, 2019, the FCC’s educational children’s television programming rules generally required that a station air an average of 3 hours of “core” educational children’s television programming per week on each of its streams, averaged over a six-month period, to receive staff-level license renewal approval.  To be considered a “core” program, the program had to be specifically designed to meet the educational and informational needs of children 16 years of age and under; be identified as such on-air with the “E/I” symbol displayed throughout the airing of the programming; be identified to publishers of program guides along with the target age range of the program; be “program-length,” that is, at least 30 minutes in length; and be regularly scheduled to air on a weekly basis between the hours of 7:00 a.m. and 10:00 p.m.  In addition, broadcasters had to identify the educational purpose of the program in their quarterly Children’s Television Programming Report and advertise the availability and location of that report to the public.  Further provisions applied with regard to preempting and making good educational children’s television programming and the treatment of educational children’s programming airing on two of a station’s programming streams during a quarter.

The FCC’s new rules revise both the three hour per week renewal processing guideline and the definition of core children’s television programming.  Specifically, as of September 16, 2019, stations can continue to meet their obligation by airing an average of 3 hours per week of regularly-scheduled, weekly, program-length educational programming on their primary stream, but are not required to air additional children’s television programming on their multicast streams.  As an alternative to airing 3 hours per week of regularly-scheduled educational programming, stations may now air 26 hours per quarter (2 hours per week) of regularly scheduled, weekly, program-length educational programming, and air an additional 52 hours of programming throughout the year that is not provided on a regularly-scheduled basis (such as educational specials or other non-weekly programming) which is at least 30 minutes in length.   Alternatively, these 52 hours of non-regularly-scheduled programming can be educational programming that is less than 30 minutes in length, such as PSAs or interstitials.

Under any scenario, licensees may move up to 13 hours per quarter of their regularly-scheduled, program-length educational children’s television programming to a multicast stream, but any station opting to air 52 hours per year of programming that it is not regularly-scheduled must air that programming on the station’s primary stream.  In addition, broadcasters are permitted to count as regularly-scheduled any children’s educational program episode that was preempted but made good within seven days before or after the date on which it was originally scheduled to air.

For purposes of compliance with the new rules in the Fourth Quarter of 2019, stations must therefore either air 45 hours of regularly-scheduled weekly core programming on their primary stream from September 16 through December 31, 2019, or they must air at least 30 hours of such programming (at least 4 hours on or before September 30) and an additional 15 hours of core programming that is not regularly-scheduled and which may be less than 30 minutes in length.  Of those 30 hours, up to 2 hours can air on the station’s multicast streams on or before September 30 and up to 13 hours can air on the station’s multicast streams from November 1 to December 31.  All of the remaining 15 hours of non-regularly-scheduled or short form programming must air on the station’s primary stream.

Third Quarter 2019 Filing Requirements

Turning back to the Third Quarter 2019 Report due on October 10, broadcasters must comply with two paperwork requirements.  Specifically, stations must (1) place in their Public Inspection File one of four prescribed types of documentation demonstrating compliance with the commercial limits in children’s television, and (2) submit the Children’s Television Report (FCC Form 2100, Schedule H, which is often referred to by its former designation as Form 398), which requests information regarding the educational and informational programming the station has aired for children 16 years of age and under.  The Children’s Television Programming Report must be filed electronically with the FCC.  The FCC automatically places the electronically filed Children’s Television Programming Report filings into the respective station’s Public Inspection File.  However, each station should confirm that has occurred to ensure that its Public Inspection File is complete. Continue reading →

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Pillsbury’s communications lawyers have published FCC Enforcement Monitor monthly since 1999 to inform our clients of notable FCC enforcement actions against FCC license holders and others.  This month’s issue includes:

  • Faith-Based Station Settles With FCC After Preempting KidVid Programming With Fundraising
  • Arizona LPFM Gets License Reinstated in Consent Decree
  • Christmas Tree’s Harmful Interference Results in Consent Decree With LED Company

Gotta Have Faith: Washington TV Station That Preempted Children’s Programming With Fundraising Settles With FCC

The FCC recently entered into a Consent Decree with the licensee of a faith-based Washington TV station for inaccurate Children’s Television Programming Reports and for failing to provide a sufficient amount of “core” children’s educational programming.

Pursuant to the Children’s Television Act of 1990, the FCC’s children’s television programming (“KidVid”) rules require TV stations to provide programming that “serve[s] the educational and informational needs of children.”  Under the KidVid guidelines in place at the time of the alleged violations, stations were expected to air an average of at least three hours per week of “core” educational children’s programming per program stream.  To count as “core” programming, the programs had to be regularly-scheduled, at least 30 minutes in length, and broadcast between the hours of 7:00 a.m. and 10 p.m.  A station that aired somewhat less than the averaged three hours per week of core programming could still satisfy its children’s programming obligations by airing other types of programs demonstrating “a level of commitment” to educating children that is “at least equivalent” to airing three hours per week of core programming.  The FCC has since acknowledged that this alternative approach resulted in so much uncertainty that stations rarely invoked it.

Stations must file a Children’s Television Programming Report (currently quarterly, soon to be annually) with the FCC demonstrating compliance with these guidelines.  The reports are then placed in the station’s online Public Inspection File.  Upon a station’s application for license renewal, the Media Bureau reviews these reports to assess the station’s performance over the previous license term.  If the Media Bureau determines that the station failed to comply with the KidVid guidelines, it must refer the application to the full Commission for review of the licensee’s compliance with the Children’s Television Act of 1990.  As we have previously discussed, the FCC recently made significant changes to its KidVid core programming and reporting obligations, much of it having gone into effect earlier this month.

During its review of the station’s 2014 license renewal application, the Media Bureau noticed shortfalls in the station’s core programming scheduling and inaccuracies in the station’s quarterly KidVid reports over the previous term.  It therefore issued a Letter of Inquiry to the station to obtain additional information.  In response, the station acknowledged that it had in fact preempted core programming with live fundraising, but asserted that it still met its obligations through other “supplemental” programming, albeit outside of the 7 a.m. to 10 p.m. window for core programming.  Inaccuracies in its reports were blamed on “clerical errors.”

The Media Bureau concluded that the station’s supplemental programming did not count toward the station’s core programming requirements.  Without getting into the merits of the programming itself, the Media Bureau found the programming insufficient because it was aired outside of the core programming hours.  The Media Bureau also concluded that the station had provided inaccurate information on several of the quarterly reports.

In response, the FCC and the station negotiated a Consent Decree under which the station agreed to pay a $30,700 penalty to the U.S. Treasury and implement a three-year compliance plan.  In return, the FCC agreed to terminate its investigation and grant the station’s pending 2014 license renewal application upon timely payment of the penalty, assuming the FCC did not subsequently discover any other “impediments” to license renewal.

Radio Reset: LPFM License Reinstated (for Now) in Consent Decree Over Various Licensing and Underwriting Violations

In response to years of ownership, construction, and other problems that culminated in its license being revoked in 2018, the licensee of an Arizona low power FM (“LPFM”) station entered into a Consent Decree with the Media Bureau and the Enforcement Bureau. Continue reading →

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The next Quarterly Issues/Programs List (“Quarterly List”) must be placed in stations’ Public Inspection Files by October 10, 2019, reflecting information for the months of July, August and September 2019.

Content of the Quarterly List

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. 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.

To demonstrate a station’s compliance with this public interest obligation, the FCC requires the station to maintain and place in the Public Inspection File a Quarterly List reflecting the “station’s most significant programming treatment of community issues during the preceding three month period.” By its use of the term “most significant,” the FCC has noted that stations are not required to list all responsive programming, but only that programming which provided the most significant treatment of the issues identified.

Given that program logs are no longer mandated by the FCC, the Quarterly Lists may be the most important evidence of a station’s compliance with its public service obligations. The lists also provide important support for the certification of Class A television station compliance discussed below. We therefore urge stations not to “skimp” on the Quarterly Lists, and to err on the side of over-inclusiveness. Otherwise, stations risk a determination by the FCC that they did not adequately serve the public interest during the license term. Stations should include in the Quarterly Lists as much issue-responsive programming as they feel is necessary to demonstrate fully their responsiveness to community needs. Taking extra time now to provide a thorough Quarterly List will help reduce risk at license renewal time.

It should be noted that the FCC has repeatedly emphasized the importance of the Quarterly Lists and often brings enforcement actions against stations that do not have fully complete Quarterly Lists or that do not timely place such lists in their Public Inspection File. The FCC’s base fine for missing Quarterly Lists is $10,000.

Preparation of the Quarterly List

The Quarterly Lists are required to be placed in the Public Inspection File by January 10, April 10, July 10, and October 10 of each year. The next Quarterly List is required to be placed in stations’ Public Inspection Files by October 10, 2019, covering the period from July 1, 2019 through September 30, 2019. Continue reading →

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Each full power and Class A TV station being repacked must file its next quarterly Transition Progress Report with the FCC by October 10, 2019. The Report must detail the progress a station has made in constructing facilities on its newly-assigned channel and in terminating operations on its current channel during the months of July, August and September 2019.[1]

Following the 2017 broadcast television spectrum incentive auction, the FCC imposed a requirement that television stations transitioning to a new channel in the repack file a quarterly Transition Progress Report by the 10th of January, April, July, and October of each year. The first such report was due on October 10, 2017.

The next quarterly Transition Progress Report must be filed with the FCC by October 10, 2019, and must reflect the progress made by the reporting station in constructing facilities on its newly-assigned channel and in terminating operations on its current channel during the period from July 1 through September 30, 2019. The Report must be filed electronically on FCC Form 2100, Schedule 387 via the FCC’s Licensing and Management System (LMS), accessible at https://enterpriseefiling.fcc.gov/dataentry/login.html.

The Transition Progress Report form includes 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 then asks for additional information regarding the steps the station has taken towards completing the required item. Ultimately, the form requires each station to indicate whether it anticipates that it will meet the construction deadline for its transition phase. Continue reading →

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Full power commercial and noncommercial radio stations and LPFM stations licensed to communities in Alabama and Georgia must begin airing pre-filing license renewal announcements on October 1, 2019. 

License renewal applications for these stations, and for in-state FM translator stations, are due by December 1, 2019.  Note that because this filing deadline falls on a weekend, submission of the license renewal application may be made on December 2.  However, the post-filing license renewal announcement for that day (discussed below) must still be made on December 1.

Full power commercial and noncommercial radio and LPFM stations must air four pre-filing announcements alerting the public to the upcoming renewal application filing.  As a result, these radio stations must air the first pre-filing renewal announcement on October 1. The remaining pre-filing announcements must air once a day on October 16, November 1, and November 16, for a total of four announcements.  At least two of these four announcements must air between 7:00 am and 9:00 am and/or 4:00 pm and 6:00 pm.

The text of the pre-filing announcement is as follows:

On [date of last renewal grant], [call letters] was granted a license by the Federal Communications Commission to serve the public interest as a public trustee until April 1, 2020.  [Stations that have not received a renewal grant since the filing of their previous renewal application should modify the foregoing to read: “(Call letters) is licensed by the Federal Communications Commission to serve the public interest as a public trustee.”]

Our license will expire on April 1, 2020.  We must file an application for renewal with the FCC by December 1, 2019.  When filed, a copy of this application will be available for public inspection at www.fcc.gov.  It contains information concerning this station’s performance during the last eight years [or other period of time covered by the application, if the station’s license term was not a standard eight-year license term].  Individuals who wish to advise the FCC of facts relating to our renewal application and to whether this station has operated in the public interest should file comments and petitions with the FCC by March 1, 2019.

Further information concerning the FCC’s broadcast license renewal process is available at [address of location of the station][1] or may be obtained from the FCC, Washington, DC 20554, www.fcc.gov.

If a station misses airing an announcement, it should broadcast a make-up announcement as soon as possible and contact counsel to further address the situation.  Special rules apply to noncommercial educational stations that do not normally operate during any month when their announcements would otherwise be due to air, as well as to other silent stations. These stations should also contact counsel regarding how to give the required public notice.

Post-Filing License Renewal Announcements

Once the license renewal application has been filed, full power commercial and noncommercial radio and LPFM stations must broadcast six post-filing renewal announcements.  These announcements must air, once per day, on December 1 and December 16, 2019, as well as January 1, January 16, February 1, and February 16, 2020.  At least three of these announcements must air between 7:00 am and 9:00 am and/or 4:00 pm and 6:00 pm.  At least one announcement must air in each of the following time periods: between 9:00 am and noon, between noon and 4:00 pm, and between 7:00 pm and midnight.

The text of the post-filing announcement is as follows: Continue reading →