Articles Posted in Radio

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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:

  • Numerous Rule Violations Lead to Consent Decree and Sale for Kentucky FM Stations
  • Notice of Violation Issued to Michigan FM Translator Licensee for Excess Transmitter Power and Using Wrong Antenna
  • Texas Tower Owner’s Extended Lighting Outage Generates Notice of Violation

Kentucky Broadcaster Enters Consent Decree Requiring Sale of Stations Over Late License Renewals, Unauthorized Operations and Public File Violations

The FCC’s Media Bureau entered into a Consent Decree with the licensee of four FM radio stations in Kentucky to resolve an investigation into numerous rule violations involving late-filed license renewal applications, periods of silence, reduced-power operations without FCC authorization, Public Inspection File violations, and inaccurate certifications in the stations’ license renewal applications.

The investigation began during the Media Bureau’s review of the stations’ license renewal applications.  Section 73.3539(a) of the FCC’s Rules requires broadcast license renewal applications to be filed no later than the first day of the fourth full calendar month before expiration of the station’s license.  The four stations’ applications were due April 1, 2020, but were not filed until May 1, 2020.  The FCC subsequently received information alleging that the stations had been off the air for an extended period and an Informal Objection to license renewal for one of the stations raising additional questions about that station’s operations and Public Inspection File. Continue reading →

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Broadcasters’ next Quarterly Issues/Programs List (“Quarterly List”) must be placed in stations’ Public Inspection Files by October 10, 2026, reflecting information for the months of July, August, and September 2026.

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. Continue reading →

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October 1 is the deadline for broadcast stations licensed to communities in Alaska, American Samoa, Florida, Guam, Hawaii, Iowa, the Mariana Islands, Missouri, Oregon, Puerto Rico, the Virgin Islands, and Washington 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, October 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 →

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As we reported last week, the FCC adopted its Report and Order establishing the annual regulatory fees for Fiscal Year (FY) 2026.  Today, the FCC released a Public Notice announcing that those regulatory fees must be paid no later than 11:59 PM, Eastern Daylight Time, on September 24, 2026.

In a second Public Notice, the Commission provided more details regarding how to pay those fees.  Fees are due for feeable authorizations granted on or before October 1, 2025.  As in recent years, the fees must be paid electronically through the Commission’s CORES system, which can be found here.  Payments may be made by credit card, debit card, ACH transfer, or wire transfer.  The Commission will not accept payments made by check, money order, or cashier’s check.  There is a $24,999.99 maximum for the use of a credit card.  A larger fee amount cannot be broken into multiple payments of less than $24,999.99 and multiple payments on the same credit card in one day may be aggregated for purposes of hitting that limit.  So those whose fees will exceed $24,999.99 are encouraged to use another payment method.

Early payment is advisable given the large number of submissions to be made on the FCC’s platform in a short period of time, as well as the processing time required for wire transfers or ACH payments, to ensure that payments are processed by the deadline.  Late payments trigger a mandatory 25% penalty, along with interest charges on any unpaid fees.  The FCC will credit partial payments, but any unpaid balances are still subject to the 25% penalty and interest.  Failure to timely pay all regulatory fees can also result in dismissal of pending applications, a stop on all future application processing, and potentially license revocation.

In a third Public Notice issued today, the FCC outlined the procedures licensees should follow if they need to seek relief from regulatory fee obligations by filing a request for waiver, reduction, deferral, or installment payment plan.  Requests citing financial hardship must include supporting documentation sufficient to demonstrate that payment of the fees would impose a financial hardship on the licensee.  Any such filing is due by the payment deadline, as late or unsupported requests are generally denied.

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Yesterday, the FCC released its Report and Order adopting a schedule of regulatory fees to cover the Commission’s Fiscal Year 2026 salaries and expenses appropriation of $416,112,000. The Order largely follows the approach set out in the FCC’s April 2026 Notice of Proposed Rulemaking (NPRM), continuing the full-time employee (FTE)-based methodology the FCC has used in recent years and again reallocating certain FTEs from indirect FTEs of the Office of General Counsel, Office of Economics and Analytics, and Public Safety and Homeland Security Bureau, to direct FTEs of various of the core licensing bureaus.

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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:

  • Georgia GMRS Licensee Receives Notice of Violation for Improperly Linking Repeaters
  • FCC Cites Electronic Billboard Owner in Colorado for Years of Harmful Interference
  • Three Texas FM Translators Cited for Retransmitting Wrong Primary Station

Improperly Linked Repeaters Generate Notice of Violation for Georgia GMRS Licensee
The FCC’s Enforcement Bureau issued a Notice of Violation (NOV) to a Georgia General Mobile Radio Service (GMRS) licensee for improperly linking multiple GMRS repeaters via the internet. Linking the repeaters allowed them to simultaneously retransmit radio messages over a larger geographic area than permitted under FCC rules.

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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:

  • FCC Proposes $25,000 Fines Against Eight Companies for Failing to Respond to Enforcement Bureau Letters of Inquiry
  • Louisiana Broadband Provider Enters $10,000 Consent Decree to Resolve Investigation into Inaccurate Reimbursement Program Certification
  • Texas AM Stations Face Possible License Revocation Over Unpaid Regulatory Fees

Eight Companies Face $25,000 Fines for Failing to Respond to FCC Letters of Inquiry
The FCC’s Enforcement Bureau (Bureau) issued eight Notices of Apparent Liability for Forfeiture (NALs) proposing a total of $200,000 in fines against eight companies for failing to respond to Bureau Letters of Inquiry (LOIs). Each company faces a proposed $25,000 fine for failing to respond to an LOI seeking information about whether it marketed radiofrequency equipment in the United States that was included on the FCC’s Covered List.

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August 1 is the deadline for broadcast stations licensed to communities in California, Illinois, North Carolina, South Carolina, and Wisconsin 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, August 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 →

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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:

  • Texas FM Translator Licensee Agrees to $50,000 Consent Decree for Multiple Rule Violations
  • Public File Violations Result in $41,000 Consent Decree for Pennsylvania Television Station
  • Illinois AM Station Receives Notice of Violation for Tower Registration and Lighting Failures

Violations Yield $50,000 Consent Decree for Texas FM Translator Licensee
The FCC’s Media Bureau entered into a Consent Decree with the licensee of two Texas FM translator stations to resolve an investigation into numerous violations of the Commission’s rules governing FM translator operations, station ownership, use of unauthorized equipment, and the failure to seek Special Temporary Authority (STA) to remain silent for more than 30 days.

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Broadcasters’ next Quarterly Issues/Programs List (“Quarterly List”) must be placed in stations’ Public Inspection Files by July 10, 2026, reflecting information for the months of April, May, and June 2026.

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.

Continue reading →