Low Power Television/Class A TV

On December 1 of this year, Biennial Ownership Reports are due to be filed at the FCC by all full-power radio and TV stations, commercial and noncommercial, as well as from Class A TV and LPTV operators.  These reports are due every two years.  While the last two biennial reports that had been due in December 2019 and in December 2017 had their deadlines extended to early the next year because of issues with the FCC forms that were at that point still being refined, no such issues are expected this year. In fact, a month ago when the window opened for filing these reports, the FCC released a Public Notice reminding broadcasters of the filing deadline, emphasizing its importance, and issuing this warning that there may well be fines or other penalties for stations that do not timely file this required report:

Consistent with the importance of this information, Commission staff intends to pursue enforcement actions against licensees that fail to file their biennial ownership reports in a timely or complete manner. 

Why does the Commission collect this information?  Biennial ownership information not only keeps track for the public of who owns broadcast properties, but it also allows the Commission to track broadcast ownership.  In recent years, the reports ask for the gender and race/ethnicity of owners of stations (and control parties of noncommercial stations), and the Commission plans to use this information to track industry ownership trends.  This was an issue in the most recent change in the broadcast ownership rules, where the Third Circuit, before being overturned by the Supreme Court, had wanted the FCC to determine the impact of past changes in its ownership rules on minority and female ownership – and the FCC fought back, claiming that it did not have that information (see our article here).  These reports are one way in which such information is supposed to be provided by the FCC.
Continue Reading Less than a Month to Go – Reminder to Broadcasters to File Biennial Ownership Reports by December 1 or Potentially Face Penalties

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 Copyright Office initiated a study of the rights of publishers, to explore ways to assist local journalism. The notice

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 a Public Notice to remind potential applicants of the upcoming filing window for applications for construction permits

As we enter the last quarter of the year, the broadcasters’ October calendar is full of important regulatory dates and deadlines.  We share some of those dates below and urge you to stay in close touch with your lawyers, engineers, and consultants for the dates and deadlines applicable to your station’s operations.

On or before October 1, radio stations in Alaska, American Samoa, Guam, Hawaii, Marianas Islands, Oregon, and Washington and TV stations in Iowa and Missouri must submit their license renewal applications.  Pay close attention to the contents of your online public file and be sure that all required documents are complete and were uploaded on time.  Stations filing their renewals (other than LPFMs) are also required to file a Broadcast EEO Program Report (FCC Form 2100, Schedule 396), submitting two years of EEO Public File reports for FCC review unless your employment unit employs fewer than 5 full-time employees.  As you are putting the final touches on your applications, be sure to read the instructions for the license renewal application (radio, TV) and consult with counsel if you have questions.
Continue Reading October Regulatory Dates for Broadcasters: License Renewals, Broadcast Ownership Filings, Quarterly Issues/Programs Lists, Rulemaking Comment Dates and More

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

  • At the last minute, the deadline for broadcasters to pay their annual regulatory fees was extended to Monday, September

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.

  • In anticipation of this week’s deadline for payment of annual regulatory fees – 11:59 pm, Eastern Daylight Time on Friday,

With a week to go before the deadline for submission of annual regulatory fees, we urge broadcasters to get into the FCC’s fee filing system now and pay their fees.  We have been told that there are sometimes glitches in the electronic payment system that can take time to resolve.  With a 25% penalty on payments received after the September 24 deadline, broadcasters should not wait until the last minute to submit these fees and risk having to pay the steep penalty for a late payment should a glitch arise.

The FCC has issued numerous public notices about the payment of these annual regulatory fees that anyone paying fees should review to make sure that they know all that they need to know to make a complete and timely payment.  The FCC initially issued a Public Notice announcing that the payment window is open and will be open for timely payments through 11:59 pm Eastern Daylight Time on September 24, 2021. The Media Bureau subsequently released a Media Bureau Fee Filing Guide setting out payment specifics for computing the fees due from broadcast stations.  The Bureau’s online fee lookup portal for the fees that the FCC believes are due from any specific station was activated early this week (see the FCC Public Notice here).  Remember, fees are based on a station’s status as of October 1, 2020, so stations that have since changed facilities pay on the facilities as they were last year – and that is what should be reflected in the FCC’s database.  This week, the FCC also issued a Fact Sheet explaining who does not owe fees – including noncommercial stations and companies whose total obligations are $1000 or less.
Continue Reading 2021 Regulatory Fee Deadline of September 24 – Don’t Delay!

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 opened the window for Fiscal Year 2021 regulatory fees which must be paid no later than 11:59 pm,

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 and FEMA conducted their annual Nationwide Test of the EAS system on Wednesday, August 11. All broadcasters should