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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Effective yesterday, May 28, the FCC is accepting applications for television stations to begin to convert to the next generation TV transmission standardATSC 3.0 or “NexGen TV.” Last week, the Commission issued a Public Notice announcing that the form (FCC Form 2100) necessary for stations to apply to transition to the new standard is now available for both full-power (Schedule B to Form 2100), low power (Schedule D) and Class A TV stations (Schedule F). Only stations currently sharing channels as part of a Commission-approved channel sharing agreement following the FCC’s incentive auction are not able to apply for the transition at this point, as the FCC Form needs further revisions to its forms to accommodate applications for the transition by these stations. Those forms are expected later this year. In the interim, sharing stations can move forward with 3.0 operations by seeking Special Temporary Authority.

ATSC 3.0 promises to allow broadcasters to transmit more information through their 6 MHz channel – allowing for additional subchannels of programming or more data transmission capabilities that could be sold to those needing to transmit digital information to the wide areas served by TV stations. The transmission standard is far more mobile-friendly than the current standard and also allows for transmissions in an IP format compatible with so many other digital devices receiving information from Internet sources. But the standard is not backward compatible – meaning that to receive the new television signals consumers will need new TV sets with ATSC 3.0 receivers, or converters to provide the signal to existing TV sets. Thus, to ensure that consumers will not lose access to the over-the-air television signals they now receive, the FCC requires that stations converting to the new standard must also simulcast their primary video signal on a station in their market that continues to operate in the current ATSC 1.0 standard. Low power TV stations do not have this simulcasting obligation, meaning they can convert to 3.0 operations and leave the 1.0 standard behind.
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Questions about regulations from Washington don’t disappear just because you are spending time in Las Vegas, and this week’s NAB Convention brought discussion of many such issues. We’ll write about the discussion of antitrust issues that occurred during several sessions at the Convention in another post. But, today, we will report on news about more imminent actions on other issues pending before the FCC.

In his address to broadcasters at the conference, FCC Chairman Pai announced that the order on resolving translator interference complaints has been written and is now circulating among the Commissioners for review. The order is likely to be adopted at the FCC’s May meeting. We wrote here about the many suggestions on how to resolve complaints from full-power stations about interference from FM translators. While the Chairman did not go into detail on how the matter will be resolved, he did indicate that one proposal was likely to be adopted – that which would allow a translator that is allegedly causing interference to the regularly used signal of a full-power broadcast station to move to any open FM channel to resolve the interference. While that ability to change channels may not resolve all issues, particularly in urban areas where there is little available spectrum, it should be helpful in many other locations.
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March is one of those months where without the Annual EEO Public File Reports that come up for different states every other month, or without the Quarterly Issues Programs List and Children’s Television Report obligations that arise following the end of every calendar quarter. But this March has two very significant deadlines right at the beginning of the month – Online Public Files for radio and Biennial Ownership Reports – that will impose obligations on most broadcasters.

For radio stations, March 1 is the deadline for activating your online public inspection file. While TV stations and larger radio clusters in the Top 50 markets have already made the conversion to the online public file, for radio stations in smaller markets, the requirement that your file be complete and active is Thursday. As we wrote here, there are a number of documents that each station should be uploading to their file before the deadline (including Quarterly Issues Programs Lists and, if a station is part of an employment unit with 5 or more full-time employees, Annual EEO Public Inspection File Reports). As the FCC-hosted online public file date-stamps every document entered into the file, and as the file can be reviewed by anyone at anytime from anywhere in the world, stations need to be sure that they are timely uploading these documents to the file, as who knows who may be watching your compliance with FCC requirements. And this is not the only big obligation for broadcasters coming up in March.
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We are already a full month into the New Year, and the regulatory issues for broadcasters keep on coming. February brings the usual requirements for Annual EEO Public File Reports, which should be placed into the public inspection files (those public files being online for TV stations, big clusters of radio stations in Top 50 markets, and for those other radio stations that have converted to the online public file in anticipation of next month’s deadline) of stations in Arkansas, Kansas, Louisiana, Mississippi, Nebraska, New Jersey, New York, and Oklahoma that are part of an Employment Unit with 5 or more full-time employees. Radio stations with 11 or more full-time employees in New Jersey and New York also must file with the FCC a Mid-Term EEO Report on Form 397 by the end of the day today. TV stations with 5 or more full-time employees in Kansas, Nebraska and Oklahoma also must file the Mid-Term Report.

As noted above, March 1 brings the deadline for all radio stations to convert to the online public file hosted by the FCC (see our article here for more details about this requirement). For those radio stations that have not yet completed their conversion, February is the month to be uploading those documents. As the FCC automatically uploads most of the applications and other FCC filings that need to be in the public file, the documents that will likely take the most time for the broadcaster to upload are Quarterly Issues Programs Lists and Annual EEO Public File Reports, documents not filed with the FCC on a regular basis. We have already heard reports that the FCC’s public file system is running slow at certain times of the day, probably because of the strain of so many people uploading documents. We expect that these issues will only get worse as the March 1 deadline approaches. So, if you are a procrastinator, get on this now, as time is getting short.
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It’s a new year, and a good time to reflect on where all the Washington issues for TV broadcasters stand at the moment, especially given the rapid pace of change since the new administration took over just about a year ago. While we try on this Blog to write about many of the DC issues

When the FCC adopted its Report and Order authorizing the “next generation TV” standard ATSC 3.0, it did not resolve all issues, instead leaving a few for further public comment. Notice of the issues raised in the Further Notice of Proposed Rulemaking was published in the Federal Register just before Christmas, setting February 20 as the deadline for initial comments on the outstanding issues, and March 20 as the deadline for reply comments. What issues are left to be resolved?

In allowing the voluntary transition to ATSC 3.0, the FCC required that stations choosing to transition to the new standard must enter into agreements with another station in their market to remain in the current ATSC 1.0 transmission standard and host a “lighthouse” signal rebroadcasting the primary video signal of the converting station on one of the multicast streams of the host station. The FCC recognized that not all stations would be able to find a partner with a signal covering the converting station’s city of license that could host the lighthouse signal in the old standard, and agreed to consider waivers of that requirement. The Further Notice raises questions as to whether the FCC should issue further guidance on the standards that it will apply to such waiver requests.
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The FCC late yesterday released full texts of the decisions adopted last week to revise the broadcast ownership rules and approve the next generation television standard (ATSC 3.0). We summarized last week’s decisions, based on the press releases released after the meetings, in our article here. The full text of the ownership decision, available

At its meeting yesterday, as expected, the FCC approved significant changes to its broadcast ownership rules and also approved the roll out of ATSC 3.0 – the next generation television transmission standard. While any change in ownership rules is always a contentious issue, and thus the 3-2 strict party-line vote approving the ownership changes might not have been surprising, the television technology change adopted yesterday proved to be controversial as well, also being approved by a 3-2 vote.

As of the writing of this article on Friday morning, the final texts of these decisions have not been released, so the details of these actions are not available. We will write further about the decisions next week when we have had a chance to digest the final orders. But summaries of both decisions, and the texts of the Commissioner’s statements on the issues, were released late yesterday.
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