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

  • FCC Chairwoman Rosenworcel announced that she had circulated among the Commissioners for their review and approval a draft Notice of
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Here are some of the regulatory developments of significance to broadcasters from the past week, with links to where you can go to find more information as to how these actions may affect your operations.

  • At the NAB show last week, FCC Chairwoman Jessica Rosenworcel announced a new public-private initiative led by NAB to guide
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Here are some of the regulatory developments of significance to broadcasters from the past week, with links to where you can go to find more information as to how these actions may affect your operations.

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Here are some of the regulatory and legal actions and developments of 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.

  • Information on the FY 2020 regulatory fee process continues to roll out, in advance of the

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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.
Continue Reading FCC To Consider All-Digital AM at its November Meeting – What Questions are Being Asked?

For decades, the FCC has been attempting to solve problems with AM reception – in the 90s looking to protect AMs from each other, and today trying to assist them in overcoming the effects of background “noise” coming from the proliferation of electronic devices in the environment which make AM reception, particularly in urban areas, very difficult. Even a number of car makers have announced plans to remove AM radios from new vehicles – particularly electric ones – given these stations’ susceptibility to interference from in-car electronics. Is there a solution?

Bryan Broadcasting (a long-time client that I assisted with its pleading) thinks it is time that the FCC do something dramatic to give AM a long-term future. This week it filed a Petition for Rulemaking asking the FCC to allow any AM to go all-digital in its operation.  The pleading does not suggest that any AM be forced to convert to an all-digital operation – instead it proposes that stations be given the option to make that conversion whenever they want. This is not a new concept, the FCC having considered it in the past and, in its 2015 AM Revitalization Order and Further Notice of Proposed Rulemaking, discussed listed it as an issue on which they wanted comments so that they could consider such a transition at some point in the future (that discussion principally advanced in the FCC’s questions about the future use of the expanded band – see our post here on that 2015 Order).  Already, there is one AM station in Maryland operating full-time with all-digital facilities under experimental authority, and several tests have been conducted across the country on this all-digital operation.  While these tests have shown many positive results, why suggest this option for AM stations to make this digital conversion now?
Continue Reading Time for All-Digital AM?  Petition for Rulemaking Asks that the FCC Allow It

November is perhaps the month with the lightest schedule of routine FCC regulatory filing obligations – with no requirements for EEO Public File Reports, Quarterly Issues Programs or Children’s Television Reports. Nor are there other routine obligations that come up in the course of any year, though during November of 2019, broadcasters will be preparing for next year’s December 1 Biennial Ownership Report deadline. So does that mean that there are no dates of interest this month for broadcasters? As always, there are always a few dates of which you need to keep track.

The one November date applicable to all broadcasters is the requirement for the filing of ETRS Form Three, which gives a detailed analysis of the results of the nationwide EAS test conducted on October 3. Stations should have filed Form Two on the day of the test reporting whether or not the test was received. They now need to follow up with the more detailed Form Three report by November 19. See our article here for more information.
Continue Reading November Regulatory Dates for Broadcasters – EAS Form Three, LPTV and FM Repacking Reimbursement Costs, and FM Translator Long-Form Applications

Earlier this year, there was a settlement window for mutually exclusive applications in the FCC’s application window for new FM translators for Class A and B AM stations. The FCC yesterday released a list of the applications that are now grantable as a result of conflict resolutions filed during that settlement window. These applicants must…

Only three weeks ago, we wrote about an application for experimental authority filed by an AM station operator in Arizona, seeking permission to cease operating its AM station for a one year test to operate solely with its paired FM translator. We suggested that this proposal portended much for the AM band. However, the…