In several recent actions, the FCC has imposed severe fines on broadcast licensees for operating auxiliary facilities without a license.  These actions highlight the importance of insuring that your broadcast stations have all of the licenses that they need to operate the technical facilities that they are using. 

In a decision issued today, the FCC fined a Regent radio station $7000 for failing to file a required form on a timely basis and for operating an FM translator station without authority.  According to the decision, Regent had inadvertently failed to include the translator on the renewal application for the main station.  Seven months later, it discovered the oversight, filed the renewal, and requested temporary authority to continue to operate the station.   The Commission imposed a fine of $3000 for failing to timely file the renewal, and $4000 for operating for the 7 months without authority.

Two weeks ago, the FCC released another Notice of Apparent Liability, proposing a $6600 fine for the late filing of two renewal applications for earth stations used by a public television licensee.  One renewal was filed about 2 months late, the second about 2 years late.  The FCC again imposed fines both for the late-filing, and for the operation without authorizations for the operation during the period after the licenses had expired and before the late renewals and STA requests were submitted.

For earth stations and some private radio licenses, the broadcaster should beware, as these licenses do not expire at the same time as broadcast licenses, and thus can easily be overlooked.  Similarly, translators and boosters can often be overlooked at renewal time, so stations should check to make sure that all their authorizations have been properly renewed.  In both of the recent decisions, the Commission reduced the fines that it could have imposed because the licensees discovered their own mistakes, admitted those mistakes, and took prompt corrective actions.  The fies would have been higher had the FCC discovered the problems first.

Broadcasters should also check to be sure that they have licenses for all other auxiliary facilities that they use (including STLs, Remote Pick-Up Units, and Inter-city Relays).  These licenses are no longer listed on renewal applications, and the FCC cleaned up its auxiliary database a few years ago, purging it of auxiliary licenses that had not been properly matched up with main broadcast stations.  I’m sure that some licensees did not carefully follow the FCC’s processes to avoid that purge – and they might not even know that they are operating one of these auxiliaries without authority.  You don’t want to be a licensee who gets caught operating a now unlicensed auxiliary station – so check your licenses carefully.