Articles Posted in

Published on:

By and

Pillsbury’s communications lawyers have published the 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:

  • Airport Transmissions Lead to FCC Notice of Unlicensed Operation
  • FCC Issues Notice of Violation for Prolonged Tower Lighting Outage
  • FCC Cuts Off Voice Provider Linked to Illegal Robocalls

FCC Issues Notice of Unlicensed Operation for Unauthorized Aviation Frequency Use

Following a complaint of harmful interference at a Billings, Montana airport, the Denver office of the FCC’s Enforcement Bureau issued a Notice of Unlicensed Operation (NOUO) to an aviation services provider operating at the airport.

According to the NOUO, the FCC’s Denver field office received a complaint regarding unauthorized transmissions on 128.825 MHz at the Billings-Logan International Airport.  The complaint alleged that the transmissions were causing interference to a licensed operator at the airport.  During the investigation, an FCC agent located the source of the interference, and ultimately spoke with a provider of airport services, including charters, aircraft sales, and hanger space rentals.  The provider confirmed it was operating radios on 128.825 MHz as part of its fixed-base operator support services at the airport.  The FCC determined that no license had been issued authorizing the services provider to operate on that frequency.

Such unlicensed operations are prohibited by Section 301 of the Communications Act.  In the NOUO, the FCC warned the services provider that operating without a valid authorization violates federal law and could result in “substantial monetary fines, in rem seizure of the offending radio equipment, and criminal sanctions including imprisonment.”

The NOUO directed the company to immediately cease the transmissions and to not resume them unless it obtained the necessary FCC authorization.  It gave the company 10 days to provide any evidence of authority to operate on that frequency, at which point the FCC will “determine what, if any, enforcement action is required to ensure your compliance with the Commission’s rules.”

Michigan Tower Owner Cited for Failing to Maintain Required Obstruction Lighting

The FCC’s Enforcement Bureau issued a Notice of Violation (NOV) to a Michigan tower owner for failing to maintain required obstruction lighting.

According to the NOV, an agent from the FCC’s Chicago field office inspected the tower in November 2025 and found that its obstruction lighting was not operating as specified in the Antenna Structure Registration (ASR) database.  Section 17.23 of the FCC’s Rules requires that antenna structures be painted and lighted in accordance with their registration.  The ASR for the tower required medium intensity white obstruction lighting at night, including a top-level strobe and two mid-level strobes.  At the time of the inspection, however, all of the required lighting was dark except for a single low-intensity, non-strobing white light that did not comply with Federal Aviation Administration specifications. Continue reading →

Published on:

By and

April 1 is the deadline for broadcast stations licensed to communities in Delaware, Indiana, Kentucky, Pennsylvania, Tennessee, and Texas to place their Annual EEO Public File Report in their Public Inspection File and post the report on their station website.

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.

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.

Deadline for the Annual EEO Public File Report for Nonexempt Radio and Television SEUs

Consistent with the above, April 1, 2026 is the date by which Nonexempt SEUs of radio and television stations licensed to communities in the states identified above, including Class A television stations, must (i) place their Annual EEO Public File Report in the Public Inspection Files of all stations comprising the SEU, and (ii) post the Report on the websites, if any, of those stations.  Once the new Report is posted on a station’s website, the prior year’s Report may be removed from that website. Continue reading →