With the June 3 filing deadline fast approaching for license renewals for radio stations in Maryland, DC, Virginia and West Virginia, stations (including FM translators and LPFMs) licensed to any community in any of those states should be beginning to prepare their applications. As we wrote here, the FCC forms should be available next week, so once May 1 rolls around, early birds in those states can start to file their renewal applications and the accompanying EEO program report. These stations should also be running their pre-filing license renewal announcements on the 1st and 16th of May. Radio stations in the next renewal group, stations in North and South Carolina, should be prepared to begin their license renewal pre-filing announcements in June – so in May they should be recording and scheduling that announcement to run for the first time on June 1 (see this article on pre-filing announcements for more information).
While May is one of those months with no other regularly scheduled regulatory filing deadlines, it is full of other FCC deadlines including comment dates in several proceedings of importance to broadcasters. In addition, broadcasters in Arizona, Idaho, Maryland, Michigan, Nevada, New Mexico, Ohio, Utah, Virginia, West Virginia, Wyoming, and the District of Columbia that are part of an Employment Unit with 5 or more full-time employees should also be preparing to add to their online public inspection file their Annual EEO Public File Report – due to be added to their files by June 1.
One of the FCC proceedings with comment dates in May is the proposal to allow AM broadcasters to, at their option, convert to full-time digital operations. We wrote about that proposal here and here. Comments on the initial Petition for Rulemaking are due on May 13. While the FCC is now just seeking preliminary comments on this proposal (they have not yet issued a formal Notice of Proposed Rulemaking with specifics on proposed actions), filings on or before May 13 are important to let the FCC know whether there really are broadcasters interested in converting their AM stations to all-digital operations. So if you have an interest, file your comments in the proceeding by the upcoming deadline.
As we wrote yesterday, the FCC is also looking for updated information from operators of C Band earth stations as to the uses they are making of the 3.7 to 4.2 GHz band. Those updates are due on May 28.
Reply comments on the FCC’s latest Quadrennial Review of its ownership rules are also due in May. Comments in this proceeding, about which we wrote here, deal primarily with the possibility of changes in the local radio ownership rules. The FCC is also considering providing more definition as to when they will allow the common ownership of two of the top 4 TV stations in any market, and also at whether one party could own 2 of the top 4 broadcast TV networks. Comments on various ownership diversity proposals are also out for comment. Comments in the proceeding are due by April 29, with replies due on May 29.
Comments in the proceeding looking at changes to the rules governing the applications for and processing of new noncommercial FM and LPFM stations are due on May 20. The FCC is looking at changes in the information noncommercial applicants need to supply when filing for new stations, and other changes in dealing with NCE and LPFM construction permits once granted. For more information on this proceeding, see our article here.
At the May 9 FCC open meeting, the Commission will be considering its proposal on how to resolve interference complaints about new FM translator facilities by full-power FM stations. We wrote about the FCC’s draft order in this proceeding here. The FCC will also be considering a Notice of Proposed Rulemaking (here) on this year’s regulatory fees – likely to be paid in August or September. Under this proposal, some broadcast fees, particularly for radio, will be going up. Comments will be due at a later date after the NPRM is adopted.
We should also be on the lookout for dates for the commencement of filing of reimbursement requests by LPTV, TV translators and FM radio stations affected by the incentive auction. We wrote about the FCC’s order adopting rules for this reimbursement here.
All in all, it is a very busy month for broadcast regulatory activities. As always, these are just the regulatory dates that we have thought to highlight for the month. Check with your own advisors for other dates that may affect your station operations. And check out our Broadcasters Regulatory Calendar for dates that will be coming up in future months.