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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:

  • Arkansas University’s Underwriting Violations Lead to $76,000 Consent Decree
  • Large TV Broadcaster Agrees to Pay $1.3 Million Over Predecessor’s Tower Compliance Problems
  • Recent Fine Cancellations Prompt Broadcasters to Double-Check Fees and Fines

A Word From Our Sponsors: Arkansas University Settles With FCC Over Underwriting Violations

The FCC recently entered into a Consent Decree with an Arkansas university for violating the FCC’s underwriting rules for noncommercial stations.  The university admitted that two of its FM stations aired announcements over several days in 2016 that impermissibly promoted the products or services of its financial contributors.  The two stations are operated by a community college under the University’s control.

Noncommercial educational (“NCE”) broadcast stations are prohibited from airing promotional announcements on behalf of for-profit entities in exchange for any benefit or payment.  Instead, NCE stations may broadcast announcements that identify but do not “promote” station benefactors.  Such messages may not, among other things, include product descriptions, price comparisons, or calls to action on behalf of a for-profit donor.  According to the FCC, these limitations “protect the public’s use and enjoyment of commercial-free broadcasts” and “provide a level playing field for the noncommercial broadcasters that obey the law and for the commercial broadcasters that are entitled to seek revenue from advertising.”

The FCC was tipped off to the violations when the licensees of several nearby commonly-owned stations filed a Formal Complaint outlining over a dozen announcements broadcast on the University’s stations.  The complainants alleged that these messages, which were aired on an ongoing basis in 2016, violated the underwriting rules by either including promotional statements or promoting specific products for sale.  Most of the announcements were sponsored by local businesses, including an announcement for a nearby car dealership described as “impressive with a very clean pre-owned model or program unit,” a furniture store that has a “good deal … going there” where listeners can get “pretty stuff,” and a local insurance agent offering services that he had “never done on radio before.”

The Enforcement Bureau responded to the Formal Complaint by issuing multiple Letters of Inquiry to the University seeking additional information about the announcements and the University’s underwriting compliance efforts.  In its response, the University admitted that the announcements had been simulcast on both stations, but emphasized that the stations’ staff had received “extensive” training on underwriting issues, and that it believed that the stations had complied with the underwriting rules.

To resolve the years-long investigation, the University agreed to enter into a Consent Decree under which the University agreed to: (1) pay a $76,000 civil penalty; (2) admit to violating the FCC’s underwriting rules; and (3) implement a five-year compliance plan to ensure there will be no future violations.

Tower Records: Predecessor’s Lax Oversight of Antenna Structures Leads to $1.3 Million Settlement for Large Broadcast Company

A large television broadcast company has agreed to settle an FCC investigation into whether the prior owner of several of the company’s towers failed to sufficiently monitor and maintain records regarding them.

Part 17 of the FCC’s Rules requires a tower owner to comply with various registration, lighting and painting requirements.  Tower marking and lighting is a vital component of air traffic safety, and noncompliant structures pose serious hazards to air navigation.  To this end, a tower owner is responsible for observing the tower at least once every day for any lighting failures or to have in place an automatic monitoring system to detect such failures.  The tower owner must also maintain a record of any extinguished or improperly functioning lights.  The FCC’s rules also require a tower owner to notify the FCC within 5 days of a change in a tower’s ownership.

In September 2018, a small plane crashed into a southern Louisiana broadcast tower, prompting an FCC investigation into the tower and its owner.  The FCC determined that the tower was registered to a subsidiary of a national broadcaster which at the time controlled over a dozen television stations and related antenna structures.  Following up on the crash, the Enforcement Bureau issued the company a Letter of Inquiry seeking information about its compliance with the FCC’s tower rules.  The company responded by disclosing numerous “irregularities” in its monitoring of the lighting systems of the toppled tower and nine other towers.  It also disclosed that it had failed to keep complete records of a dozen lighting failures at several of its towers, and that it had not notified the Commission of its acquisition of two other towers. Continue reading →

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With radio license renewals underway, TV license renewals starting soon, the TV repack chugging along, and a whole new set of deadlines for kidvid launching this year, there are a lot of 2020 deadlines that broadcasters must track and meet.

To help broadcasters accomplish that, Pillsbury has published a new edition of its Broadcasters’ Calendar each year for longer than anyone can recall. (This is the 33rd edition that I’ve personally contributed to.)

And it is a doozy. 2020 is one of the busier regulatory years in recent memory, making the recently published 2020 edition of the Pillsbury Broadcasters’ Calendar an essential tool for broadcasters. While the internet works well for monitoring breaking changes in regulations and deadlines, its tendency to focus your attention on each new change in isolation makes it a poor tool for broadcasters seeking to obtain the big picture and plan their year.

In particular, TV broadcasters will want to focus on the various deadlines related to children’s television. With the FCC’s new rules going into effect on January 21, 2020, broadcasters are entering into a rather complicated transitional period, and we held off on finalizing this year’s Broadcasters’ Calendar until all of those deadlines were set. That allows broadcasters to not only ensure they are meeting their modified January 10 obligations, but to see how those obligations mesh with the shift from quarterly to annual kidvid obligations.

There are sure to be plenty of surprises in 2020. Regulatory obligations that are already in place should not be one of them. We hope you find the 2020 Pillsbury Broadcasters’ Calendar a useful addition to your planning for the year ahead, and wish you a successful 2020.

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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:

  • North Carolina FM Translator Station Hit With $2,000 Proposed Fine Over Primary Station Change
  • FCC Admonishes Georgia TV Stations for Insufficient Political File Disclosures
  • FCC Proposes Historic Fine Against Massachusetts Pirate Radio Operation

Carolina On My Mind: FCC Proposes $2,000 Fine Over Raleigh FM Translator’s Primary Station Confusion

A Raleigh FM translator briefly rebroadcast a station that was not its primary station and which was already being rebroadcast by another commonly-owned translator in the area.  In response, the FCC proposed a $2,000 fine for the licensee’s failure to notify the Commission or to provide any justification for such redundant operations.

An FM translator station rebroadcasts the signal of a primary AM or FM station on a different frequency.  Translators are often used to provide “fill in” service in poor reception areas due to distance or terrain obstructions.  Section 74.1251(c) of the FCC’s Rules requires an FM translator station to notify the FCC in writing if it changes its primary station.  Pursuant to Section 74.1232, an entity may not hold multiple FM translator licenses to retransmit the same signal to substantially the same service area without first demonstrating “technical need” for an additional station, such as a signal gap in the service area.

The Raleigh licensee originally applied for a construction permit to build facilities for an FM translator in July 2018 and shortly thereafter amended the application to change the translator’s proposed primary station.  The FCC’s Media Bureau granted the application a few weeks later.  After completing construction, the licensee filed, and the Media Bureau granted, a license for the translator.

Throughout this process, the licensee of a nearby low power FM station filed multiple petitions–one challenging the FCC’s grant of the construction permit, and a later one challenging the grant of the license itself.  Though the first petition was dismissed by the FCC as “procedurally defective”, the latter became the basis of an investigation into the new station.  The petitioner claimed that since initiating service, the new translator station had been rebroadcasting a nearby AM station rather than the FM station specified as the primary station in its construction permit application.  According to the petitioner, the translator only “returned” to its authorized primary station when the primary FM station began simulcasting the AM station.

The petitioner also asserted that the translator licensee failed to show any “technical need” to rebroadcast the AM station since the AM station was already being rebroadcast to substantially the same area by another translator licensed to an entity that was commonly-owned with the FM translator.

The FCC concluded that the new translator had violated its rules by failing to notify the FCC when it commenced rebroadcasting the AM station during its first month of operation.  The FCC further determined that the licensee should have first submitted a “technical need” showing to support this change due to the presence of the nearby commonly-owned translator station rebroadcasting the same programming.

As a result, the FCC issued a Memorandum Opinion and Order and Notice of Apparent Liability against the licensee, proposing a $2,000 fine.  While FCC guidelines set a base fine of $3,000 for failure to file required forms or information, and a $4,000 base fine for unauthorized emissions, the Commission may adjust a fine upward or downward after considering the particular facts of each case.  Acknowledging the brief duration of the licensee’s violations and finding no history of prior offenses, the FCC proposed a total fine of $2,000.  Additionally, the Commission determined that the licensee’s actions did not raise a “substantial or material question of fact” regarding the licensee’s qualifications to remain a licensee, and affirmed its decision to grant the translator license application.

Political Ad Nauseum: FCC Admonishes Georgia TV Stations Over Political File Defects

In a recent Order, the FCC’s Media Bureau admonished the licensees of two Georgia television stations in response to complaints alleging violations of the FCC’s political file rules.  According to the FCC, the stations failed to sufficiently comply with record-keeping obligations in response to several political ad sales made in 2017.

Pursuant to the Bipartisan Campaign Reform Act of 2002 (often referred to as “BCRA” or the “McCain-Feingold Act”), broadcasters are required to keep and make available extensive records of purchases and requests for purchases of advertising time if the advertisement communicates a message relating to a “political matter of national importance”.  Section 315(e) of the Communications Act of 1934, which was amended by BCRA, states that ads that trigger such disclosure include those that relate to legally qualified federal candidates and elections to federal office, as well as “national legislative issues” of public importance. Continue reading →

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The FCC announced the opening of a new filing window to modify pending applications proposing new digital Low Power TV and TV translator service in rural areas.  This filing window will permit applicants with long-pending applications who have subsequently been displaced by the Incentive Auction and the repacking process to submit amended proposals, subject to certain conditions.

In June 2009, the FCC announced a filing window for new digital LPTV and TV translator stations to serve rural areas.  The window opened on August 25, 2009, and the plan was for the FCC to permit similar new, non-rural proposals to be filed starting on January 25, 2010.  However, at the same time that the FCC was accepting applications for new rural LPTV and TV translator stations, it was also considering the adoption of the National Broadband Plan, which, inter alia, proposed to re-purpose a portion of the UHF television spectrum.  The FCC first delayed, and then cancelled, the “non-rural” filing window, and imposed a freeze on the filing and processing of the rural proposals.

As a result, there are now a significant number of pending applications for new LPTV and TV translator stations to serve rural areas that have been frozen since 2010.  The new filing window, which will be open between December 2, 2019 and January 31, 2020, will permit applicants to submit amendments that (i) specify a new digital channel in the revised TV band and/or (ii) propose a change in transmitter site of 48 kilometers or less.  The amendments must protect full-power, Class A television and LPTV/translator stations that have been licensed or that hold valid construction permits, along with any previously-filed applications for those services.  Moreover, any amendment must continue to qualify as a rural service proposal.

After the window closes on January 31, 2020, the FCC will provide mutually-exclusive applicants the opportunity to resolve conflicting proposals through settlement or engineering amendments.  If an engineering conflict cannot be resolved, the FCC will conduct an auction.  The FCC will dismiss all pending applications that do not submit an in-core amendment during the filing window.

Given the holiday season and the short turnaround on filing amendments, applicants with long-pending applications should move quickly to find a new channel and/or tower site that will permit the FCC to process their application.

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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:

  • Government Shutdown and Other “Compelling Reasons” Prompt FCC to Reinstate NY Radio Station License
  • FCC Fines Virginia AM Station and Limits License Renewal to Two Years for Missing Quarterly Programs/Issues Lists
  • Virginia Station’s Late License Renewal Application Proves Costly

How Do You Measure a Year?  “Unique Circumstances” Lead to New York AM Station’s Reinstatement

In a Memorandum Opinion and Order and related Consent Decree, the Media Bureau agreed to reinstate the license of a Long Island, New York AM radio station that had been silent for nearly all of 2018 before going back on air without authorization in the midst of this year’s partial government shutdown.  The Media Bureau also approved an application to sell the station that had been pending since February.

Section 73.1745(a) of the FCC’s Rules requires a station to broadcast according to the “modes and power” specified in its license, and further requires licensees to seek special temporary authority (often referred to as an “STA”) when seeking to operate at variance from their license.  Even where a station obtains temporary authority from the FCC to remain silent, Section 312(g) of the Communications Act of 1934 provides that a broadcast station’s license automatically expires if it does not transmit a broadcast signal for 12 consecutive months.  The FCC does not consider unauthorized operation to be a “broadcast signal” for purposes of declaring a station’s operations to be resumed under Section 312(g).  Fortunately, the FCC has the discretion to reinstate a license that would otherwise be lost under Section 312(g) where it is appropriate as a matter of “equity and fairness.”

On January 25, 2018, the AM station went silent due to the loss of its licensed transmitter site.  Shortly thereafter, the licensee sought and was granted authority by the FCC to remain silent through August 16, 2018.  When that date arrived, the station continued to remain silent, but failed to apply for an extension of that authority.  On January 15, 2019, the licensee informed the FCC that it had resumed operations on an emergency antenna at low power, and it filed a request for special temporary authority to operate at those parameters.  The station’s request fell on deaf ears, however, as the federal government was shut down at that time due to a budget dispute.  The FCC did not resume normal operations until January 26, 2019, and did not grant the STA request until February 1. Continue reading →

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[Editor’s Note: Pillsbury will be conducting a December 3, 2019 webinar for broadcasters on the new overtime regulations sponsored by the National Alliance of State Broadcasters Associations.  Details can be found here.]

On September 24, 2019, the U.S. Department of Labor published final regulations under the Fair Labor Standards Act that raised the minimum salary level necessary to be exempt from federal overtime rules under the Act by almost 50%.  While the changes affect all businesses subject to the FLSA, broadcasters in particular may feel the impact of the changes given the staffing models used by many TV and radio stations.  The new requirements will go into effect on January 1, 2020, and broadcasters should take steps to adapt to, and minimize the impact of, those changes prior to that deadline.

The Fair Labor Standards Act (“FLSA”) is the federal law governing wage and hour requirements for employees.  Pursuant to the FLSA, employers must pay employees a minimum wage and compensate them for overtime at 1.5 times their regular rate of pay for any time worked exceeding 40 hours in a workweek unless those employees are exempt from the requirement.  On September 24, 2019, the Department of Labor issued a Final Rule that increased the minimum salary threshold for certain types of employees to be exempt from the FLSA’s overtime rules.  As a result, many currently exempt employees whose salaries are below the new thresholds will soon be eligible for overtime pay.  The White House projects the change will impact an estimated 1.3 million previously-exempt employees.

Although the FLSA applies to almost all employers, the law contains exemptions for certain types of employees at small-market broadcast stations.  The Final Rule does not affect these broadcast industry-specific exemptions, but will affect many other currently exempt employees in the broadcast industry who, unless they receive salary raises, will soon become eligible for overtime pay.

This Advisory only addresses federal law.  Some state laws impose stricter standards than federal law as to which employees are exempt from overtime pay.  Employers must ensure that they also meet the requirements of any applicable state or local employment laws.

Overview

The FLSA requires employers to pay non-exempt employees an overtime rate of 1.5 times their regular rate for all hours worked over 40 hours per workweek.  However, the FLSA exempts from its overtime rules certain classes of employees who are paid on a salary basis and who also meet specific “white collar” duties tests.  The Department of Labor’s Final Rule increases the minimum salary required for these classes of employees to be deemed exempt from the FLSA’s overtime rules, but does not alter the duties tests for those exemptions. 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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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 →