FM Translators and LPFM

The lazy days of summer continue to provide little respite from the regulatory actions of importance to broadcasters.  The good news is that there are no license renewal or EEO  deadlines during the month of July.  Nonetheless, there will be a number of July deadlines that require attention.

On July 1, comments are due on the FCC’s Office of Economics and Analytics annual call for comments on the State of Competition in the Communications Marketplace (see the Public Notice calling for these comments). The comments are used to prepare a report to Congress on communications competition issues and are sometimes referenced by the FCC itself in proceedings dealing with competition issues.  The FCC seeks comments on a list of questions about competition in both the Video and Audio marketplaces, including the impact of digital competitors on traditional providers and the role that regulation plays in the competitive landscape.  Reply comments are due August 1.

July 5 and July 18 are the comment and reply comment deadlines, respectively, for the FCC’s Notice of Proposed Rulemaking on the FCC’s proposed regulatory fees for fiscal year 2022.  The fees that the FCC is proposing for television (full power and otherwise) and radio stations are set forth in Appendix C and Appendix G of the document.  The FCC is proposing an increase of approximately 13% for radio broadcasters.  Among other things, the FCC proposes to continue to assess fees for full-power broadcast television stations based on the population covered by a full-service broadcast television station’s contour, and it seeks comment on its mechanism for calculating the regulatory fee based on the this population-based methodology.  These fees will be set by the end of August or very early September, to be paid before the October 1 start of the government’s new fiscal year.
Continue Reading July Regulatory Dates for Broadcasters:  Quarterly Issues/Programs Lists and Other Public File Obligations, Lowest Unit Charge Periods, License Renewal, Copyright Filings and More

Here are some of the regulatory developments of significance to broadcasters from the last week, with links to where you can go to find more information as to how these actions may affect your operations.

  • Comment dates have been announced in the Federal Register for the FCC’s Notice of Proposed Rulemaking proposing to authorize LPTV

Here are some of the regulatory developments of significance to broadcasters from the last week, with links to where you can go to find more information as to how these actions may affect your operations.

  • The FCC this week announced that in-person meetings at its new headquarters building will now be allowed – though only

Here are some of the regulatory developments of significance to broadcasters from the last week, with links to where you can go to find more information as to how these actions may affect your operations.

  • The FCC issued its Notice of Proposed Rulemaking proposing the annual regulatory fees to be paid by September 30, the

With the traditional beginning of summer upon us, there is no vacation from the regulatory actions of importance to broadcasters.  Let’s start with the routine actions for the upcoming month.  With the radio license renewal cycle having ended with the filing of the last set of renewal applications in April, we enter the last year of the cycle for television.  Renewals applications for Full-Power Television, Class A, LPTV and TV Translator Stations in Arizona, Idaho, Nevada, New Mexico, Utah and Wyoming are due on June 1.  Renewal applications must be accompanied by FCC Form 2100, Schedule 396 Broadcast EEO Program Report (except for LPFMs and TV translators).  Stations filing for renewal of their license should make sure that all documents required to be uploaded to the station’s online public file are complete and were uploaded on time.  Note that your Broadcast EEO Program Report must include two years of annual EEO public file reports for FCC review, unless your employment unit employs fewer than five full-time employees.  Be sure to read the instructions for the license renewal application and consult with your advisors if you have questions, especially if you have noticed any discrepancies in your online public file or political file.  Issues with the public file have already led to fines imposed on TV broadcasters during this cycle.

Also, on or before June 1, all radio and TV station employment units (a station employment unit is a station or stations that are under common control, share at least one full-time employee, and are in the same geographic area) with five or more full-time employees licensed to communities in Arizona, District of Columbia, Idaho, Maryland, Michigan, Nevada, New Mexico, Ohio, Utah, Virginia, West Virginia, and Wyoming must upload to their online public inspection file an Annual EEO Public File report.  This report covers hiring and employment outreach activities for June 1, 2021 through May 31, 2022.  These licensees must also post on the homepage of their station website (if they have one) a link to the most recent report.
Continue Reading June Regulatory Dates for Broadcasters:  TV Renewals, EEO Public File Reports, Comments on Zonecasting, Start of Channel 6 FM Rulemaking and More

Here are some of the regulatory developments of significance to broadcasters from the last week, with links to where you can go to find more information as to how these actions may affect your operations.

  • The FCC has requested comments on a proposal for a new Content Vendor Diversity Report. A public interest group has

The FCC released a Public Notice last week setting the date for comments on the results of GeoBroadcast Solutions tests of their “zonecasting” system that would allow FM boosters within a primary FM station’s protected contour to originate limited amounts of programming different than that carried on the main station. Comments on the tests are due by June 6, with replies to the comments due by June 21.

The zonecasting proposal has been pitched as a way to allow FM stations to localize their content – making it possible for one FM station to use FM boosters to run different commercials or news inserts in different parts of their service area.  The hope of supporters is that adoption of this proposal would give broadcasters a tool to fight back at the targeting of listeners that can be done by online audio services.  While some stations and groups have seen this as a potential positive, others, including the NAB, have been more critical of the proposal.
Continue Reading Comments on Tests of GeoBroadcast Solutions Zonecasting System Due June 6 – What Are the Issues?

Here are some of the regulatory developments of significance to broadcasters from the last week, with links to where you can go to find more information as to how these actions may affect your operations.

  • Follow field testing by GeoBroadcast Solutions of its zonecasting system, the FCC opened a new comment period for interested parties

The FCC yesterday made public four letters to landowners warning them that there were unlicensed FM radio operations coming from their properties and warning that, if the transmissions continued past the 10-business day response period, the landowners could be held liable for penalties up to $2,000,000 for the unlicensed operations coming from their properties.  The

The FCC this week released a Public Notice (that we mentioned in our update on regulatory dates for May) announcing that, on May 17, many new applications and other filings will be migrating to the FCC’s newer LMS filing platform.  These include many of the documents that had been until recently filed in the FCC’s old CDBS platform.  These applications had, since CDBS was closed for new filings, been submitted through emails to the FCC (see our articles here and here).

Most notably, the new LMS filings will include requests for Special Temporary Authority – and future requests for extensions of STAs.  The FCC notes that for STAs that had originally been filed in CDBS, rather than filing an extension request for such STAs, applicants should initially file for a new STA in LMS and indicate in an exhibit that the request is for an extension of an existing STA that was filed in CDBS (or by email in the interim processing period).  The full list of applications that will, as of May 17, be filed in LMS is as follows:

  • FM Engineering Special Temporary Authorizations (STAs)
  • Request for Silent STA
  • Extension of STA – Silent
  • Extension of STA – Engineering
  • Suspension of Operations Notification
  • Resumption of Operations
  • AM/FM Digital Notification
  • Modulation Dependent Carrier Level (MDCL) Notification
  • Change of Primary Station Notification
  • Tolling Notification
  • Reduced Power Notification
  • Withdraw Pending Applications


Continue Reading More FCC Broadcast Applications Moving to LMS – Including Requests for STAs