preparing for license renewal

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We are less than one year away from the beginning of the next radio license renewal cycle. By June 1 of 2019, radio broadcasters with stations licensed to communities in Maryland, Virginia, West Virginia and the District of Columbia must have their license renewal applications on file. Stations in certain southeastern states follow two months later, with other states to follow every two months until the cycle ends 3 years after it began with the filing of renewals by stations in the northeast. The FCC’s list of state-by-state renewal deadlines is available here. The TV cycle begins the year after the radio cycle and progresses in the same order. We wrote here about how the online public inspection file will heighten scrutiny of the performance of stations in meeting their public service obligations – and the particular importance of timely preparation and uploading of the Quarterly Issues Programs lists – the only officially mandated documents showing how stations addressed issues of importance to their communities in their over-the-air programming. But there are other issues that stations should be considering in this year before renewals are filed.

From time to time in this run-up to the renewal, we will highlight issues that station owners should be considering. In the last week, there have been a few issues that that were highlighted by FCC announcements of fines levied on broadcasters for various rule violations. One obvious issue is making sure that you stay on top of the deadlines, and don’t forget to timely file the renewal application. An FCC decision released yesterday fined a station $1500 for failing to timely file its renewal in the last renewal cycle. This station filed its application about 4 months late, just before the license expired (broadcasters file their renewals 4 months in advance of the expiration of the license to give the FCC time to review and grant the renewal before the current license expires). In the past renewal cycle, other stations were fined even more when they waited even longer to file their late renewals. Obviously, it is important to stay on top of the filing deadlines.
Continue Reading Countdown to License Renewal – Recent FCC Decisions Highlight Some Issues to Consider

In less than a month, a four year cycle of radio and television license renewal applications begins with the filing, on or before June 1, of license renewals by radio stations in Maryland, Virginia, West Virginia and the District of Columbia.  To help stations prepare for their upcoming renewals, I conducted a webinar, sponsored by the Michigan Association of Broadcasters and joined by broadcasters from 9 other state associations, discussing issues that broadcasters should be considering.   Slides from that presentation, setting out the renewal process, and various issues that should be considered by broadcasters, including: public file issues, technical matters, EEO and other nondiscrimination matters.  Copies of the slides used in the presentation are available here.

In addition to those slides, we have many other resources available for a broadcaster thinking about their license renewal application.  These include the following:

  • A primer on the issues to be considered in preparing for license renewal, available here.  In that memo, there are links to the texts of the required pre-filing and post-filing announcements that broadcasters must air to inform their listeners about the filing of the renewal application
  • A memo that sets out the materials that should be kept in a commercial station’s public file, and the retention period for those materials, here.
  • A memo generally describing the requirements of the FCC’s EEO rules, here, and a second memo, reminding broadcasters of their yearly EEO public file report obligations, a sample of which is here.  Remember, FCC Form 396 report must be filed with the license renewal application, and that form requires the submission of the station’s last two years public inspection file reports
  • An advisory, here, summarizing the requirements for a station’s quarterly programs issues lists.
  • Recent blog entries on the FCC’s requirement for a nondiscrimination certification in their advertising contracts, here and here.

FCC Sources of information for the renewal filing are also available.  A version of the FCC Form 303S – the license renewal form – can be viewed here.  The form contains a good set of instructions as to what information the FCC is seeking from licensees.  The FCC also has its own webpage on license renewal, here.  Dates for radio license renewals are available here, and the dates for TV renewals are here.Continue Reading Getting Ready for License Renewal – Slides and More Information from State Broadcast Associations’ Webcast