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With the holiday season getting smaller in the rear-view mirror and many parts of the country dealing with ice, snow, and single-digit temperatures, broadcasters could be forgiven for dreaming about the sunshine and warmth that come with spring.  Before spring arrives, however, broadcasters need to tend to important regulatory matters in February.  And, if you find yourself eager to plan past February, use our 2020 Broadcasters’ Calendar as a reference tool for tracking regulatory dates through the end of 2020.

But focusing on the month ahead, by February 3, all AM, FM, LPFM, and FM translator stations in Arkansas, Louisiana, and Mississippi must file their license renewal applications.  For the full-power stations in the state, there’s an additional EEO task to complete irrespective of how many employees a station employment unit (SEU) has.  Before filing for license renewal, stations in these three states must submit FCC Schedule 396. This schedule is the Broadcast Equal Employment Opportunity Program Report, which is a reporting to the FCC of the SEU’s equal employment opportunity activities for the last license period (SEUs with fewer than five full-time employees are not required to maintain an EEO recruitment program and are only required to check a box that they have fewer than 5 full-time employees and skip ahead to the certification).  The sequencing here is important: When filing for license renewal, the application (Schedule 303-S) asks for the file number of your already-filed Schedule 396.  So, without having already filed the schedule, you won’t be able to complete your renewal application.…
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While many of us were trying to enjoy the holidays, the world of regulation kept right on moving, seemingly never taking time off.  So we thought that we ought to highlight some of the actions taken by the FCC in the last couple weeks and to also remind you of some of the upcoming January regulatory deadlines.

Before Christmas, we highlighted some of the regulatory dates for January – including the Quarterly Issues Programs Lists due to be placed in the online public file of all full-power stations by January 10.  Also on the list of dates in our post on January deadlines are the minimum SoundExchange fees due in January for most radio stations and other webcasters streaming programming on the Internet.  January also brings the deadline for Biennial Ownership Reports (postponed from their normal November 1 filing deadline).

In that summary of January regulatory dates, we had mentioned that the initial filing of the new Annual Children’s Television Programming Report would be due this month.  But, over the holiday week, the FCC extended that filing deadline for that report until March 30 to give broadcasters time to familiarize themselves with the new forms.  The FCC will be doing a webinar on the new form on January 23.  In addition, the FCC announced that many of the other changes in the children’s television rules that were awaiting review under the Paperwork Reduction Act had been approved and are now effective.  See our article here for more details.…
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The FCC recently proposed modifying its rules prohibiting a radio station in one service (either AM or FM) from duplicating more than 25% of the weekly programming of another station in the same service if there is more than 50% overlap of the principal community contour of either of the stations.  The FCC this…

As we noted in our list of November Regulatory dates for broadcasters, at its November 22 meeting, the FCC will be considering the adoption of a Notice of Proposed Rulemaking (see the draft order here) allowing AM stations to go all digital – on a voluntary basis. This Notice follows a Petition for Rulemaking which I filed on behalf of my client Bryan Broadcasting (see our articles here and here). The FCC’s NPRM, if adopted in the form of the draft Notice, suggests that the Commission, subject to a review of comments, is inclined to adopt the proposal to allow AM stations to voluntarily convert to an all-digital operation. While that is the tentative conclusion of the FCC, it does pose numerous questions on which it seeks comments.

The FCC’s questions include inquiries on the technical, programming, and operational aspects of the conversion of an AM station to digital. But the FCC recognizes some of the potential benefits of the all-digital operation and identifies some of the likely early adaptors of any such technology. These early adopters would likely include AM stations that have an FM translator that can continue to provide programming to the public even if some of the public does not have a radio with AM digital reception capabilities. We note that some AM operators with FM translators have already suggested the possibility of surrendering their AM signal, a proposal that has thus far been rejected by the FCC (see our articles here and here). The prospect of an all-digital AM operation would allow these stations to rely on their FM translator for current analog coverage of their markets, while trying to provide a more robust AM signal in the long-term rather than simply abandoning the service altogether. In addition, music stations are much more likely to be interested in an all-digital operation with the promise of higher fidelity than possible through an analog operation. But the FCC asks numerous other questions.…
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November is not one of those months with due dates for renewal filings, EEO public file reports or quarterly issues programs reports. Some of those obligations wait until December, when renewal filings for radio stations in Georgia and Alabama are due by December 2 (as December 1 falls on a weekend). Due for uploading on or before December 1 are EEO public file reports for station employment units with 5 or more full-time employees for radio or television stations in Alabama, Colorado, Connecticut, Georgia, Maine, Massachusetts, Minnesota, Montana, New Hampshire, North Dakota, Rhode Island, South Dakota, and Vermont.

November 1 does signal the first day on which radio and TV stations can file their Biennial Ownership Reports. As we wrote here, the FCC has extended the deadline date for those filings until January 31, 2020 as the FCC is making refinements in its forms in the LMS filing system. Reports are to reflect the licensee’s ownership as of October 1, 2019 so stations have the information that they need and can start filing their reports later this week.…
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Last week, the FCC issued Public Notice reminding all broadcasters and other EAS participants of the obligation to file their ETRS Form Three report by September 23. That form provides details about a station’s participation in the August 7 Nationwide EAS Test (see our article here about the test and the required ETRS filings)…

The FCC on Tuesday released its Report and Order on regulatory fees.  The Order says that the fees will be due by September 24.  The FCC should soon issue additional guidance about the exact filing dates and procedures.

In the Order, the FCC did reduce the fees for radio somewhat from those proposed in their Notice of Proposed Rulemaking in May.  However, it was not the decrease sought by many broadcast groups.  The radio fees, even though reduced, still result in an increase from last year’s fees.  The FCC attributed that increase both to a somewhat smaller number of stations and an increase in the operating costs of the FCC that had to be shared among all regulated entities.…
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With the summer winding down, you can expect that come September, like everywhere else, Washington will leap back to life and the government will try to accomplish what they can before the end of the year. That will no doubt mean some regulatory actions (and potentially court actions and legislative actions) affecting broadcasters this Fall, though what they are remains to be seen. In the meantime, there is plenty to keep broadcasters busy. While September is one of those months in which there are few of the normally recurring filing deadlines (no EEO reports, renewal filings or quarterly reports need to be submitted during the month), there is one big deadline that no commercial broadcaster should forget – the filing of annual regulatory fees.

We understand that there is an order circulating at the FCC right now to set the final amount of the regulatory fees for the year. As these fees must be paid before October 1 when the government’s new fiscal year begins, we can expect that order shortly, with fees due at some point in September. As the Commission’s Notice of Proposed Rulemaking proposed significant unexplained increases in the fees paid by radio, and a change to the methodology used to compete TV fees, moving from a DMA-based fee to one calculated based on an individual station’s predicted coverage (which had the effect of raising some fees, especially for high-powered VHF stations, while lowering others), a number of broadcasters and the NAB complained about those proposals. Watch for the FCC’s decision in the coming days to see how it addresses these complaints about the proposed fees, and to see when the fees will be due.…
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