We are less than one year away from the beginning of the next radio license renewal cycle. By June 1 of 2019, radio broadcasters with stations licensed to communities in Maryland, Virginia, West Virginia and the District of Columbia must have their license renewal applications on file. Stations in certain southeastern states follow two months later, with other states to follow every two months until the cycle ends 3 years after it began with the filing of renewals by stations in the northeast. The FCC’s list of state-by-state renewal deadlines is available here. The TV cycle begins the year after the radio cycle and progresses in the same order. We wrote here about how the online public inspection file will heighten scrutiny of the performance of stations in meeting their public service obligations – and the particular importance of timely preparation and uploading of the Quarterly Issues Programs lists – the only officially mandated documents showing how stations addressed issues of importance to their communities in their over-the-air programming. But there are other issues that stations should be considering in this year before renewals are filed.
From time to time in this run-up to the renewal, we will highlight issues that station owners should be considering. In the last week, there have been a few issues that that were highlighted by FCC announcements of fines levied on broadcasters for various rule violations. One obvious issue is making sure that you stay on top of the deadlines, and don’t forget to timely file the renewal application. An FCC decision released yesterday fined a station $1500 for failing to timely file its renewal in the last renewal cycle. This station filed its application about 4 months late, just before the license expired (broadcasters file their renewals 4 months in advance of the expiration of the license to give the FCC time to review and grant the renewal before the current license expires). In the past renewal cycle, other stations were fined even more when they waited even longer to file their late renewals. Obviously, it is important to stay on top of the filing deadlines.
In other decisions released in the last few weeks, the FCC proposed to fine stations – two LPFMs (decisions found here and here) and a full-power station (here) that were operating with facilities other than those specified in their licenses. While the FCC does not itself routinely review the technical operations of a station at license renewal time, in making certain license renewal certifications (e.g. that stations comply with the limitations on RF radiation exposure to the public and station workers), there is at least an implication that the station is operating where it is supposed to be and with the facilities that are specified on its license.
Moreover, the license renewal brings attention to the operation of the station generally, and subjects its operations to scrutiny by anyone who has any reason to want to make trouble for the station or its owner. Operating at variance from authorized facilities can always get a station into trouble. So reviewing all aspect of the station’s operations – including its technical facilities – is always important. Leaving time to make corrections before the renewal is filed gives licensees the incentive to make that review now. Watch for more highlights of potential license renewal issues in coming months.