Legal Memorandums - 2019

FCC Delays LPTV/TV Translator Repack Reimbursement Filing Deadline; GMR Sues Over Copyright Infringement; FCC Proposes Another I/P List Fine

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LOW POWER TV AND TV TRANSLATOR REPACK REIMBURSEMENT FILING DEADLINE EXTENDED TO NOVEMBER 14, 2019 We write with good news for low power TV and TV translator stations seeking to submit repack reimbursement requests: earlier this week, the FCC released a Public Notice in which it extended the deadline by which LPTV and TV translator stations must submit their Form 399 reimbursement requests, from October 15, 2019, to 11:59 p.m. on November 14, 2019. Note: the October 15, 2019, repack reimbursement filing deadline remains the same for FM broadcast stations. To learn more, please open the attached memo. * * * PRO GLOBAL MUSIC RIGHTS FILES BILLION-DOLLAR COPYRIGHT INFRINGEMENT SUIT AGAINST MEDIA COMPANY We usually write about performance rights organization Global Music Rights, LLC (GMR) within the context of its pending antitrust litigation with the Radio Music License Committee (RMLC). This time, however, we write about a different GMR lawsuit that we’ll be watching closely: earlier this month, GMR filed a Complaint in a California federal court alleging that a media company with “scores” of radio-station holdings has been violating the copyrights of GMR-affiliated songwriters for years. The Complaint alleges that stations owned by the defendant media company have publicly performed more than 130 GMR compositions at least 10,000 times, all in violation of United States copyright laws. For more on the lawsuit, please open the attached memo. * * * MEDIA BUREAU PROPOSES $15,000 FINE FOR RADIO STATION’S FAILURE TO PREPARE AND FILE QUARTERLY ISSUES/PROGRAMS LISTS We have further evidence (as if we needed it!) that the FCC is taking a close look at stations’ quarterly Issues/Programs lists: it appears another fine is on the way as a result of I/P list deficiencies that were spotted during the course of the license renewal application process. In a Notice of Apparent Liability released this week, the Media Bureau proposed a $15,000 fine for a radio station’s apparent failure throughout the license term to place any issues and programs lists into its online public file. To read more on this story, including the FCC’s reaction to the licensee’s explanation for its lack of I/P lists, please open the attached memo.  

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CC Begins Granting VA Radio Station License Renewals; Media Bureau Proposes $15k Fine for I/P List Failure

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COMMISSION BEGINS GRANTING VIRGINIA RADIO STATION LICENSE RENEWALS; GUIDANCE FOR BROADCASTERS RECEIVING GRANTS We’ve learned that the Commission is now granting Virginia radio station license renewal applications that were timely filed by the June 3, 2019, deadline. At this point, however, the FCC’s automated notification system does not appear to be alerting a licensee when action has been taken on its renewal application(s). As a result, it is possible that your station’s renewal may have been granted already without your knowing it yet! Please open the attached memo, which (1) lets you know where to look to see whether your license renewal application has been granted and (2) provides guidance for the “next steps” once you receive your renewal grant. * * * MEDIA BUREAU ISSUES NOTICE OF APPARENT LIABILITY RELATED TO RECENT VIRGINIA RADIO LICENSE RENEWAL APPLICATION While we’re on the subject of Commission activity on license renewals, we wanted to bring to your attention a Notice of Apparent Liability in the amount of $15,000 issued last week to a Virginia radio station licensee in connection with its license renewal application. To learn more why the Media Bureau thinks such a fine is appropriate, please open the attached memo.  

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  • Added On: 9/25/2019

Breaking News re: Reg Fees & Third Circuit Ruling on Media Ownership; Other Headlines -- EAS Form Three Due Today; Biennial Ownership; and More

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BREAKING NEWS: FCC EXTENDS FY 2019 REGULATORY FEE PAYMENT DEADLINE: PAYMENT OF FY 2019 REGULATORY FEES NOW DUE SEPTEMBER 27 We begin this memo with some breaking news: the FCC today released a Public Notice announcing that it is extending the deadline by which broadcasters must pay their fiscal year (“FY”) 2019 regulatory fees—to September 27 at 11:59 p.m. EDT. (The deadline had been tomorrow, September 24.) Timely payment is critical! The FCC will impose a late payment penalty of 25% of any unpaid amount of regulatory fees owed, and that penalty will be assessed on the first day following the deadline for paying the FY 2019 fees. To learn more, including some important reminders regarding what forms of payment the FCC will accept, please open the attached memo. * * * MORE BREAKING NEWS: THIRD CIRCUIT COURT OF APPEALS REJECTS FCC’S DEREGULATORY ACTIONS ON MEDIA OWNERSHIP; COURT REMANDS ORDERS BACK TO AGENCY The Third Circuit Court of Appeals on Monday released an opinion (“Opinion”) in which it vacated and remanded back to the FCC certain of the Commission’s Orders that seek to deregulate local media ownership, including the agency’s 2017 Order on Reconsideration that significantly liberalized the local media ownership rules by eliminating some of them and reforming others. The FCC signaled it is likely to appeal. Note that we will provide a deeper analysis of what the Opinion means for broadcasters in the coming days, as the immediate impact crystalizes. For our rapid reaction on the Opinion, please open the attached memo. * * * EAS “FORM THREE” DUE TODAY – SEPTEMBER 23 Broadcasters must file the third and final report—called Form Three—associated with last month’s nationwide test of the Emergency Alert System no later than 11:59 p.m. Eastern Time today, September 23. Form Three is the report on which stations provide detailed post-test data and describe any issues with receipt or retransmission of the nationwide test. Form Three must be filed using the FCC’s EAS Test Reporting System. To learn more, please open the attached memo. * * * COMMISSION POSTPONES OPENING OF WINDOW TO FILE BIENNIAL OWNERSHIP REPORTS; FILING WINDOW NOW OPENS NOVEMBER 1, 2019 AND CLOSES JANUARY 31, 2020 Broadcasters will have some extra time to prepare and then file their biennial ownership reports. In a recent Order, the Media Bureau announced that it is postponing (and also lengthening) the ownership report filing window—for this reporting cycle only. Biennial ownership reports must now be filed between November 1, 2019, and January 31, 2020. The original filing window had been set for the time period of October 1, 2019 to December 1, 2019. To learn more, including why the FCC is postponing the window, please open the attached memo. * * * SEPTEMBER 25: MULTIPLE FM, LPFM, AND FM TRANSLATOR APPLICATION FORMS MOVE TO FCC’S LMS FILING SYSTEM The FCC recently announced that several broadcast application forms related to constructing, licensing, and/or modifying commercial and noncommercial FM, LPFM, and FM translator stations will be available for filing in the Commission’s Licensing and Management System (“LMS”) as of September 25. As broadcasters will recall, the Commission is in the midst of updating its application filing systems, gradually transitioning to using LMS (from its Consolidated Database System (“CDBS”)) for all broadcast applications. To find out more information, including which forms are affected, please open the attached memo.  

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  • Added On: 9/23/2019

Deadlines - Reg Fees and EAS Form Three ** Headlines - Local Public Notice Rules, Enforcement Actions, Etc

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REMINDER NUMBER ONE: FY 2019 REGULATORY FEES DUE NEXT WEEK! FEES MUST BE PAID ON OR BEFORE SEPTEMBER 24, 2019 The deadline by which broadcasters must pay their fiscal year 2019 regulatory fees is 11:59 p.m. Eastern Time on Tuesday, September 24, 2019. Broadcasters must use the Commission’s automated filing and payment system, called Fee Filer, which is currently operable and able to receive regulatory fee payments. To learn more, please open the attached memo. * * * REMINDER NUMBER TWO: ONE WEEK UNTIL EAS “FORM THREE” DUE; STATIONS MUST FILE FORM THREE ON OR BEFORE SEPTEMBER 23, 2019 Broadcasters have one more week, until September 23, 2019, to file the third and final report—called Form Three—associated with last month’s nationwide test of the Emergency Alert System. Form Three is the report on which stations provide detailed post-test data and describe any issues with receipt or retransmission of the nationwide test. Form Three (like Forms One and Two before it) must be filed using the FCC’s EAS Test Reporting System. To learn more, please open the attached memo. * * * A TIMELY CAUTIONARY TALE: FCC REVOKES BROADCASTER’S LICENSE FOR FAILURE TO PAY REGULATORY FEES Remember how we just mentioned that timely payment of regulatory fees is critical? The Media Bureau proved just how seriously it takes reg fee payments in a Revocation Order released last week, in which the Bureau revoked an Alabama broadcaster’s license for its “failure to pay the Station’s regulatory fees for a number of fiscal years.” To learn more, please open the attached memo. * * * COMMISSION TO CONSIDER FURTHER NOTICE OF PROPOSED RULEMAKING TARGETED AT MODERNIZING LOCAL PUBLIC NOTICE PROCEDURES FOR APPLICATIONS The FCC’s next target in its ongoing Modernization of Media Regulation Initiative appears to be Section 73.3580 of the Commission’s rules—the agency’s current local public notice procedures. We expect the FCC to adopt a Further Notice of Proposed Rulemaking at its open meeting on September 26th that would propose and seek comment on multiple changes to the current local public notice procedures, which are triggered upon the filing of certain broadcast applications. To learn more, please open the attached memo. * * * FCC PROPOSES $272,000 FINE AGAINST CBS FOR DISTRIBUTION AND BROADCAST OF PROGRAM CONTAINING UNAUTHORIZED EAS TONE TRANSMISSIONS In a Notice of Apparent Liability released last week, the FCC proposed a fine of $272,000 against CBS Corporation and several of its subsidiaries for “apparently willfully and repeatedly” violating the FCC’s EAS rules by transmitting or causing the transmission of EAS codes and tones, or recordings or simulations of the tones, in the absence of an actual emergency, an authorized EAS test, or a qualified PSA. To learn more, please open the attached memo. * * * FCC ISSUES PENALTIES, ENTERS INTO CONSENT DECREES AFTER FINDING PURPORTED VIOLATIONS OF CHILDREN’S TV RULES As we’ve previously reported, several (but not all) of the FCC’s revised Children’s Television Programming Rules take effect today, September 16th, 2019. One thing that will not be changing, to be sure, is the Commission’s focus on ensuring broadcasters’ compliance with their Kid Vid obligations. Two recent Orders in which the Commission levied penalties of more than $30,000 and $109,000, respectively, for purported violations of the rules are evidence of that. To learn more, please open the attached memo.  

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2019 FY Reg Fees -- Carriage Election Rules

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FCC RELEASES FY 2019 REGULATORY FEES ORDER; FEES DUE BY SEPTEMBER 24, 2019 The FCC released a Report and Order earlier this week announcing its regulatory fees for fiscal year 2019. The deadline by which broadcasters must pay their FY 2019 regulatory fees is 11:59 p.m. Eastern Time on Tuesday, September 24, 2019. The Commission also announced that it has opened its automated filing and payment system, called Fee Filer, and that the system is operable and able to receive reg fee payments. To learn more, please open the attached file. * * * FCC ORDER MODERNIZING RETRANS CONSENT/MUST-CARRY CARRIAGE ELECTION PROCESS TAKES EFFECT OCTOBER 29, 2019 We now know the effective date for rule changes that significantly modernize the FCC’s carriage election notice rules by moving broadcasters’ carriage election notices to primarily electronic means. The Report and Order in which the FCC adopted the rule changes (back in July) will be published in the Federal Register tomorrow, and the rules will take effect sixty days later, on October 29, 2019. To learn more, please open the attached file.  

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Repack $$ Webinar -- EEO NPRM Comments

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FCC TO HOST WEBINAR ON REPACK REIMBURSEMENT PROCEDURES FOR LPTV, TV TRANSLATOR, AND FM STATIONS ON AUGUST 28 We write with a reminder that the FCC will host a webinar this Wednesday, August 28, 2019, from 11 a.m. to noon ET, outlining procedures for reimbursing low power television, TV translator, and FM broadcast stations that have been affected by the post-incentive auction repack. According to the FCC, the webinar will be accessible here. To learn more, please open the attached file. * * * COMMENTS ON FCC’S NPRM ON IMPROVING EEO COMPLIANCE AND ENFORCEMENT NOW DUE SEPTEMBER 20 Comments on the FCC’s Notice of Proposed Rulemaking seeking comment on how the Commission can improve its equal employment opportunity compliance and enforcement efforts are due September 20. Reply comments are due November 4. As you may recall, last month, a coalition of 82 broadcasters filed comments on the Notice asking, among other things, for the FCC to raise the “small station” exemption from EEO rules from five full-time employees to fifty full-time employees in order to reduce burdens and costs on small broadcast entities. To learn more, please open the attached file.  

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Kid TV - EAS - Repack $$ - FCC Enforcement - and More!

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REVISED CHILDREN’S TV RULES TO TAKE EFFECT ON STAGGERED TIMELINE; QUARTERLY FILING REQUIREMENT REMAINS IN PLACE FOR NOW The FCC recently announced that several of its revised Children’s Television Programming Rules will take effect soon—on September 16, 2019. We discuss which Rules will be taking effect in the attached memo; note that not all of the revised Kid TV Rules are taking effect at that time. To learn more, please open the attached file. * * * OCTOBER 15: INITIAL FILING DEADLINE FOR REPACK-RELATED REIMBURSEMENT OF LPTV STATIONS, TV TRANSLATORS, FM AND LPFM STATIONS, AND FM TRANSLATORS The FCC recently announced the initial filing deadline for reimbursement submissions by LPTV stations, TV translators, FM stations, low-power FM stations, and FM translators that have been affected by the post-incentive auction repack. As set out more fully in the attached memo, a recent FCC Public Notice explains that affected stations must file such reimbursement submissions by 11:59 PM on October 15, 2019, and they must do so using the newly revised FCC Form 2100, Schedule 399, in order to ensure timely reimbursement. To learn more, please open the attached file. * * * EAS “FORM THREE” DUE ON OR BEFORE SEPTEMBER 23, 2019 Broadcasters have one more month, until September 23, 2019, to file the third and final report—called Form Three—associated with the August 7 nationwide test of the Emergency Alert System (“EAS”). To learn more, please open the attached file. * * * MORE EAS NEWS: LPFM STATION RECEIVES NOTICE OF VIOLATION FOR APPARENT EAS DEFICIENCIES While we’re on the subject of the EAS, we want to bring your attention to a recent Notice of Violation issued by the FCC that provides stations with a timely reminder that the FCC is serious about and actively enforces its EAS rules. To learn more, please open the attached file. * * * FORFEITURE ORDER CALLS OUT LICENSEE’S “SHENANIGANS” AND OFFERS REMINDERS REGARDING IMPORTANCE OF FOLLOWING COMMISSION INSTRUCTIONS Citing multiple flawed filings and failures to follow Commission instructions, the Enforcement Bureau recently issued a Forfeiture Order affirming a $25,000 penalty against a Pennsylvania church for lighting, painting, and notice deficiencies related to its radio antenna structures. To learn more, please open the attached file. * * * FCC SEEKS COMMENTS ON WHETHER TO EXAMINE CURRENT CLOSED CAPTIONING RULES; IMMEDIATE FOCUS ON VIABILITY OF “AUTOMATIC SPEECH RECOGNITION” The FCC recently issued a Public Notice seeking comment on a petition filed by a coalition of consumer and academic organizations that asks the Commission to examine its current Closed Captioning Rules. The Petition requests a thorough review of the Commission’s current Closed Captioning Rules in general, but it specifically targets so-called “automatic speech recognition” (“ASR”) for immediate review and potential disqualification as a viable captioning option. To learn more, please open the attached file.  

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Deadline for VA Radio Stations to Upload Post-Filing Announcement Certification

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VIRGINIA RADIO STATIONS MUST UPLOAD CERTIFICATION OF POST-FILING ANNOUNCEMENTS TO OPIF BY AUGUST 23, 2019 We write to remind you that Virginia radio stations must place in their online public inspection file (OPIF) a statement certifying compliance with the FCC’s license renewal post-filing announcement requirement later this week, by no later than August 23, 2019. To learn more about where the statement must be uploaded and what information it must contain, please open the attached file.  

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  • Added On: 8/19/2019

FCC Fines Broadcasters and Cable Companies for Violating EAS Tone Rules

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FCC ISSUES FOUR EAS FINES TOTALING OVER $600,000 FOR FALSE ALERTS On Thursday, August 15, 2019, the FCC’s Enforcement Bureau released four Orders adopting Consent Decrees to resolve investigations into alleged violations of the Commission’s rules prohibiting the misuse of EAS tones, including simulated or false alerts. The Consent Decrees included payments to the FCC totaling more than $600,000 in the aggregate and imposed onerous three-year compliance plans and reporting obligations on the parties involved. These enforcement actions present an opportunity to review with station personnel the seriousness with which the FCC approaches the EAS system and the significant costs of misuse of EAS tones for comedic or dramatic (or even for educational) purposes. To learn more, please open the attached file.  

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FM TX Rules - Modern TV Act - Kid TV Rules to OMB - $233k Sponsorship ID Fine

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NEW FM TRANSLATOR INTERFERENCE RULES TAKE EFFECT ON AUGUST 13 The Commission’s recently overhauled FM translator interference rules have been given final regulatory approval and will officially take effect next week—on August 13, according to an FCC Public Notice. To learn more, please open the attached file. * * * “MODERN TELEVISION ACT” INTRODUCED; BROADCASTERS OPPOSING LEGISLATION Just before adjourning for Congress’s August recess, House Minority Whip Steve Scalise (R-LA) and Rep. Anna Eshoo (D-CA) introduced their long-awaited video marketplace legislation, titled the “Modern Television Act of 2019.” The Bill seeks to blow up the existing retransmission consent framework by, among other things, repealing retrans consent laws and regulations, including the attendant compulsory copyright licenses. The Bill is very MVPD-friendly, and NAB was quick to voice its opposition, stating that the legislation “would undermine America’s world leadership in free and local broadcasting.” To learn more, please open the attached file. * * * CHILDREN’S TV RULES SENT TO OMB FOR APPROVAL; EFFECTIVE DATE STILL UNCERTAIN We’re keeping a close eye on the revised Children’s Television Programming Rules as they make their way through the regulatory approval and implementation process. Although we don’t yet know when the Rules will become effective, several of the Rules are now one step closer to taking effect. To learn more, please open the attached file. * * * COMMISSION PROPOSES $233,000 FINE FOR BROADCASTER’S VIOLATIONS OF SPONSORSHIP ID RULES AND TERMS OF PRIOR CONSENT DECREE A proposed fine of $233,000 is serving as a reminder to broadcasters of the potentially costly consequences that can result from violating the Commission’s sponsorship identification requirements. The Commission proposed the fine in a Notice of Apparent Liability released this week, alleging that the radio licensee named in the Notice violated the sponsorship ID rules, as well as the terms of a prior consent decree. To learn more, please open the attached file.  

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  • Added On: 8/8/2019

EAS Test Two Days Away! - Other EAS Developments - EEO Comment Dates Set

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TWO-DAY COUNTDOWN TO AUGUST 7 NATIONWIDE EAS TEST AND DEADLINE TO FILE FORM TWO We write to remind you that the FCC and FEMA have scheduled a live, nationwide test of the Emergency Alert System to take place in in just two days—on Wednesday, August 7, 2019. In addition, the Form Two EAS Report is due the same day, on August 7. The test is scheduled to occur at 2:20 p.m. Eastern Time. To learn more, please open the attached file. * * * MORE ON EAS: RULES THAT REQUIRE BROADCASTERS TO REPORT FALSE EAS ALERTS, FACILITATE USE OF “LIVE CODE” TESTING NOW IN EFFECT And, with the nationwide EAS test just days away, we also write to report on other recent EAS developments. Specifically, we write to let you know that several EAS-related Commission rules have now taken effect, including rules that (1) require broadcast stations to notify the Commission when and if they issue false EAS alerts, and (2) facilitate EAS officials’ ability to conduct more effective public safety tests and exercises using EAS equipment and provide guidance regarding when stations can participate in such “live code” tests. To learn more, please open the attached file. * * * COMMENT DATES EXTENDED FOR NPRM ON EEO COMPLIANCE AND ENFORCEMENT The FCC has extended the comment dates on its Notice of Proposed Rulemaking seeking input on the Commission’s track record on EEO enforcement and whether the agency should make improvements to EEO compliance and enforcement. Comments will now be due by September 20, 2019, and reply comments are now due by November 4, 2019. To learn more, please open the attached file.  

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  • Added On: 8/6/2019

Two-Week Countdown to EAS Nationwide Test

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TWO-WEEK COUNTDOWN TO NATIONWIDE EAS TEST SCHEDULED FOR AUGUST 7 – ALL BROADCAST STATIONS MUST PARTICIPATE The FCC and FEMA today issued a Public Notice reminding broadcasters that the nationwide EAS test will take place in two weeks, on August 7, 2019, at 2:20 p.m. ET. As discussed in the attached memorandum, the Form Two EAS Report is due the same day, on August 7. Please remember that all broadcast stations are required to participate in the EAS, as the FCC no longer recognizes “non-participating” status for stations in the EAS rules. Stations should ensure that EAS gear is functioning, assign responsibility for the filing of the second and third nationwide EAS test reports, and review the FCC’s EAS Operating Handbook. To learn more, please open the attached file.  

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  • Added On: 7/29/2019

Copyright Royalty - EAS Reminder - Drug Price Disclosures - Foreign Agent Disclosures

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TV STATION COPYRIGHT ROYALTY CLAIMS DUE JULY 31, 2019 It’s again that time of year for television stations to file distant signal copyright royalty claims. Claims for 2018 must be filed no later than 11:59 p.m. EST on July 31, 2019. To learn more, please open the attached file. * * * FCC REMINDS TV STATIONS TO MAKE EAS MESSAGES AVAILABLE TO VIEWERS WITH HEARING AND VISUAL IMPAIRMENTS With next month’s nationwide test of the Emergency Alerts System right around the corner, the FCC issued a Public Notice this week reminding television stations of their obligation to provide accessible EAS alerts. Specifically, the Notice reminds television stations that they are required, under FCC rules, to ensure that individuals who are deaf or hard of hearing and individuals who are blind or visually impaired have full access to EAS messages, including all of the content therein. To learn more, please open the attached file. * * * FEDERAL COURT SETS ASIDE RECENT DHHS DRUG PRICING REGULATION A federal district court recently overturned a rule issued in May by the Department of Health and Human Services that sought to regulate the marketing of prescription drugs by requiring drug manufacturers to disclose the list price of a 30-day supply of a drug when advertising it in certain television spots. Absent the court’s decision, the rule would have taken effect this summer; for now, at least, the rule is on hold. To learn more, please open the attached file. * * * RECENTLY INTRODUCED FEDERAL LEGISLATION WOULD REQUIRE BROADCASTERS AND MVPDS TO DISCLOSE CONTENT THAT IS GENERATED BY FOREIGN AGENTS Recently “re”-introduced legislation in the House of Representatives would require broadcasters and MVPDs to make certain disclosures relating to content generated by foreign entities, with the goal of preventing such entities from clandestinely influencing United States elections. The bill would amend the Communications Act to require broadcasters and MVPDs to disclose when any entity registered as a “foreign agent” under the Foreign Agents Registration Act requests to purchase time from or disseminates content via a broadcaster or an MVPD. To learn more, please open the attached file.  

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  • Added On: 7/22/2019

Next Week at the FCC: Kid TV Rules and Retrans Consent Carriage Elections

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FCC EXPECTED TO REVISE CHILDREN’S TELEVISION PROGRAMMING RULES TO PROVIDE STATIONS WITH REASONABLE FLEXIBILITY The FCC will consider a Report and Order at its July 10th open meeting that, if adopted, would change the Commission’s children’s television programming rules to provide stations with reasonable flexibility (and reduced paperwork burdens). Only a draft of the order has been released at this time. The Draft Order may change before next week’s meeting, and the Draft Order does not constitute official action by the FCC. To learn more about what the FCC proposes in the Draft Order, please open the attached file. * * * DRAFT REPORT AND ORDER WOULD HELP TV BROADCASTERS, MOVE CARRIAGE ELECTION NOTICES FROM SNAIL-MAIL TO ELECTRONIC DELIVERY Also on the agenda at the Commission’s July 10th open meeting is a draft Report and Order and Further Notice of Proposed Rulemaking that proposes to move broadcasters’ carriage election notices to primarily electronic means, significantly modernizing the FCC’s carriage election notice rules. The Draft Order would require broadcasters both (1) to post their carriage elections online and (2) to send notices to covered MVPDs by e-mail, but only when and if they change their carriage election status. To learn more, please open the attached file.  

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Reminder -- EAS Test Form One Due By July 3rd

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NATIONWIDE EAS TEST FORM ONE DUE JULY 3, 2019 – ALL BROADCAST STATIONS MUST FILE We write with a final reminder that all broadcasters have until tomorrow, July 3, 2019, to file Form One, the first of three reports that must be completed in connection with the next nationwide EAS test, which is scheduled for August 7, 2019, at 2:20 p.m. EDT. Note: the FCC recently issued a public notice in which it explained that some EAS participants have encountered filing issues using the FCC’s ETRS (EAS Test Reporting System) and encouraged filers to confirm their submission of Form One through their “My Filings” page in ETRS. If you think that you filed your Form One report but you didn’t receive (or don’t recall receiving) an automated email from the FCC confirming the filing, then your Form One report might not really be filed! To learn more, please open the attached file.  

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  • Added On: 7/3/2019

Locast -- EEO NPRM -- LPTV/TX/FM Repack Reimbursement -- FAA Frequency

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AT&T INVESTS IN FREE INTERNET STREAMING SERVICE “LOCAST”; BROADCASTERS KEEPING WATCHFUL EYE Many television broadcasters are keeping an eye on Locast—an Internet-based streaming service that picks up over-the-air broadcast signals and streams them live over the Internet on Locast’s website and apps as well as on digital media players like Roku. The Locast service is similar in many respects to the now-defunct Aereo and FilmOnX, with one major difference: Locast does not charge subscription fees to users because it is operated by a non-profit advocacy group called Sports Fans Coalition NY. To learn more, please open the attached file. * * * FCC SEEKS COMMENT ON IMPROVING EEO COMPLIANCE AND ENFORCEMENT The FCC recently issued a Notice of Proposed Rulemaking seeking comment on how the Commission can improve its equal employment opportunity (“EEO”) compliance and enforcement efforts. The Notice follows the FCC’s recent elimination of broadcasters’ obligation to file EEO Form 397 (the Broadcast Mid-term Report), which came as part of the Commission’s Modernization of Media Regulation Initiative. Various EEO-related issues were raised by commenters in that EEO Form 397 proceeding, and the Notice tees some of them up for further discussion and inquiry. To learn more, please open the attached file. * * * REPACK REIMBURSEMENT GETTING CLOSER FOR LPTV, TV TRANSLATOR, AND FM BROADCAST STATIONS The wheels of government bureaucracy are continuing to turn (albeit slowly) when it comes to the FCC’s recently adopted rules regarding reimbursement for LPTV, TV translator, and FM broadcast stations that have incurred costs due to the spectrum repack. No, stations cannot yet begin submitting reimbursement requests. But at least we’re now a step closer to that being the case. To learn more, please open the attached file. * * * FAA SEEKS COMMENT ON NEW WEB-BASED FREQUENCY COORDINATION REQUEST SYSTEM Some recent activity at the Federal Aviation Administration (“FAA”) ought to get broadcasters’ attention. The FAA recently issued a Notice and Request for Comments regarding its new Web-based Frequency Coordination Request system (the “WebFCR” system). The WebFCR system is designed to replace means by which the FAA has previously collected certain broadcast frequency information. To learn more, please open the attached file.  

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  • Added On: 7/1/2019

EAS Nationwide Test Scheduled for August 7, 2019

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EAS NATIONWIDE TEST SCHEDULED FOR AUGUST 7, 2019 – ALL BROADCAST STATIONS MUST PARTICIPATE The FCC has announced that the next nationwide EAS test is scheduled for August 7, 2019, at 2:20 p.m. ET. All broadcasters are required to participate in the August 7 nationwide test, and all broadcasters are required to timely file the required Form One, Form Two, and Form Three reports associated with the nationwide test. Stations should mark their calendars, ensure that EAS gear is functioning, assign responsibility for the filing of nationwide EAS test reports—the first of which is due July 3—and review the FCC’s EAS Operating Handbook. To learn more about steps stations are encouraged to take to begin preparing for the nationwide test, please open the attached file.  

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  • Added On: 6/7/2019

Reminder! Virginia Radio License Renewal Applications Due By June 3

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** IMPORTANT RADIO STATION LICENSE RENEWAL REMINDER ** VIRGINIA RADIO STATIONS MUST FILE RENEWAL APPLICATIONS BY MONDAY, JUNE 3 This is a reminder that Virginia radio stations must file their FCC license renewal applications by Monday, June 3. To learn more, please open the attached file.  

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  • Added On: 5/30/2019

License Renewal Reminders -- Pre-Filing Announcement Certification -- Applications and Form 396 -- EEO Reports -- C-Band Certification

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VIRGINIA RADIO STATIONS MUST UPLOAD CERTIFICATION OF PRE-FILING ANNOUNCEMENTS TO OPIF BY MAY 23, 2019 The date by which Virginia radio stations must place in their online public inspection file (OPIF) a statement certifying compliance with the FCC’s license renewal pre-filing announcement requirement is tomorrow—May 23, 2019. To learn more, please open the attached file. * * * VIRGINIA RADIO STATIONS MUST FILE LICENSE RENEWAL APPLICATIONS AND EEO REPORT SCHEDULE 396 BY JUNE 3, 2019 Rest assured that this will not be the last time we remind you, but please keep in mind that license renewal applications for Virginia radio stations are due no later than June 3, 2019. Also due on June 3 for Virginia radio stations, in conjunction with the license renewal application, is the Broadcast Equal Employment Opportunity Program Report on FCC Form 2100, Schedule 396 (formerly known as FCC Form 396). The requirement to file the Schedule 396 in the FCC’s LMS (Licensing and Management System) applies to all radio stations, no matter how many full-time employees they have. To learn more, please open the attached file. * * * EEO PUBLIC FILE REPORTS DUE JUNE 3, 2019, FOR VIRGINIA RADIO AND TELEVISION STATIONS And, as if June 3rd wasn’t already a deadline circled on your calendars, remember that both Virginia radio AND television stations with five or more full-time employees must upload their annual EEO Public File Report in their online public inspection file and post it to their website (if they have one) by June 3, 2019. To learn more, please open the attached file. * * * REQUIRED FILINGS FOR MANY C-BAND EARTH STATION OPERATORS DUE TUESDAY, MAY 28 The FCC recently issued a Public Notice setting a May 28, 2019, deadline for operators of fixed-satellite service earth stations in the “C-band” (i.e., the 3.7–4.2 GHz band) to certify the accuracy of (and, in some cases, provide additional information regarding) currently authorized facilities. The Notice applies both to fixed C-band downlink registrations that were not filed for or modified in last year’s April 19 – October 31, 2018, special filing window, as well as to temporary-fixed or transportable earth stations that specify C-band frequencies on the face of the license. Accordingly, the Notice’s filing requirement applies to many fixed earth station dishes and SNG vans/trucks that have C-band receive capabilities even though they uplink in the Ku-band. To learn more, please open the attached file.  

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  • Added On: 5/22/2019

News From Outside the FCC -- DOJ Looking at Broadcast Advertising Market -- HHS Requires Disclosure of Drug Prices in Some TV Ads

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NEWS IMPACTING BROADCASTERS FROM OUTSIDE THE FCC… DOJ KEEPING CLOSE EYE ON BROADCAST TRANSACTIONS; SEEKING TO UNDERSTAND THE ADVERTISING “MARKET” The U.S. Department of Justice seems to be increasingly keeping an eye on the actions of broadcasters and transactions involving local media ownership, with a focus on potential anticompetitive practices and deals. In particular, the DOJ has focused its increased regulatory scrutiny on alleged harmful impacts to the spot advertising market purportedly caused by media company mergers and acquisitions. Underscoring the fact that the DOJ is paying greater attention in these areas than it has in the past, earlier this month the agency held a two-day Public Workshop on Competition in Television and Digital Advertising in Washington, D.C. To learn more, please open the attached file. * * * NEW HHS RULE WILL REQUIRE DISCLOSURE OF DRUG PRICES IN SOME TV ADS Last week, the U.S. Department of Health and Human Services adopted a final rule that will mandate the inclusion of pricing information in many prescription drug advertisements aired on television. The rule imposes obligations on advertisers—not on the TV broadcasters airing the spots. Still, as is the case with many products whose advertisements are regulated by agencies other than the FCC, broadcasters are generally better served if they are aware of pertinent rules. (Moreover, to the extent that TV stations produce a spot for such an advertiser, stations will need to be familiar with the disclosure rules so that they can adequately serve their advertising client.) To learn more, please open the attached file.  

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  • Added On: 5/16/2019

FCC Releases Propose FY 2019 Reg Fees -- FM TX Interference Rules -- EEO Mid-Term Report

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FCC PROPOSES FISCAL YEAR 2019 REGULATORY FEES; PROPOSAL INCLUDES SIGNIFICANT HIKE IN FEES FOR RADIO & NEW METHODOLOGY FOR CALCULATING TV FEES The FCC recently released a Notice of Proposed Rulemaking in which it proposes regulatory fees for fiscal year 2019. Perhaps of greatest significance to broadcasters, the Notice (1) proposes regulatory fees for radio stations that are substantially higher than they were last year, and (2) seeks comment on the Commission’s new methodology for calculating full-service television stations’ regulatory fees in fiscal year 2019. To learn more, please open the attached file. * * * FCC ADOPTS ORDER TO REVISE FM TRANSLATOR INTERFERENCE RULES AND PROCEDURES At its open meeting earlier this month, the FCC adopted a Report and Order that streamlines the rules relating to FM translator interference vis-à-vis full-power FM stations and should expedite the complaint resolution process. You may recall that we previously reported on a draft of the Report and Order. The final Order adopts most of the proposals included in the draft; it does, however, make some changes, including reducing the number of listener complaints that are needed to sustain an interference complaint in the largest markets. To learn more, please open the attached file. * * * EEO MID-TERM REPORT OFFICIALLY ELIMINATED And, broadcasters now have one less report to worry about, as the Mid-Term Equal Employment Opportunity Report, known as the Form 397 report, is officially gone. You may recall that the FCC adopted a Report & Order in February 2019 to eliminate the Mid-Term EEO Report; the requirement to file the Mid-Term EEO Report was officially eliminated on May 15, 2019. To learn more, please open the attached file.  

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  • Added On: 5/21/2019

Reminder! Final License Renewal Pre-Filing Announcement Must Air Tomorrow for Virginia Radio Stations

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** IMPORTANT RADIO STATION LICENSE RENEWAL REMINDER ** FINAL LICENSE RENEWAL PRE-FILING ANNOUNCEMENT FOR VIRGINIA RADIO STATIONS MUST AIR ON MAY 16 We write with a reminder for Virginia radio stations that the final license renewal pre-filing announcement must be broadcast tomorrow, on May 16, 2019. In addition, within seven days of the broadcast of the last required pre-filing announcement, by May 23, 2019, such stations must place a statement certifying compliance with the pre-filing announcement requirement in the station’s online public inspection file. To learn more about these requirements, please open the attached file.  

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  • Added On: 5/15/2019

FCC Releases Draft Order to Revise FM Translator Interference Rules and Procedures

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FCC RELEASES DRAFT ORDER TO REVISE FM TRANSLATOR INTERFERENCE RULES AND PROCEDURES; FCC EXPECTED TO CONSIDER AT MAY 9, 2019, OPEN MEETING The rules and resolution processes regarding FM translator interference complaints may soon receive a long-awaited overhaul. According to a draft Report and Order released last week by the FCC, significant interference proposals are set to be considered—and almost certainly adopted—at the FCC’s May 9, 2019 open meeting. The recent proliferation of FM translator operations (especially for AM stations) has increased interference, interference complaints, and the need to bring greater structure to the interference resolution process. The Draft Order appears to represent a compromise on the most significant changes to the complaint resolution process. For more information, please open the attached file.  

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  • Added On: 4/23/2019

Reg Fee Enforcement, EAS Test Results, FCC Due Diligence when Buying/Selling Stations

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PAY UP! FCC TAKES EXTREME ACTION AGAINST BROADCASTERS FOR FAILURE TO PAY REGULATORY FEES Two FCC orders issued in just the past week involving broadcasters who failed to pay required regulatory fees serve as a reminder that when it comes to collecting money owed, the Commission does, in fact, mean business. In these two cases, the failure to pay regulatory fees has resulted in the possibility that stations will lose their licenses. To learn more, please open the attached file. * * * FCC RELEASES RESULTS OF OCTOBER 3, 2018, NATIONWIDE EAS TEST The Commission recently released a Report detailing the results of the nationwide EAS test that it conducted with FEMA on October 3, 2018. More information is available in the attached file. * * * FCC’S ENFORCEMENT BUREAU PROVIDES HELPFUL GUIDANCE ON “DUE DILIGENCE” REQUESTS In a Public Notice released recently, the FCC announced that it had reviewed its procedures regarding the station buying/selling due diligence process and wished to provide additional clarification and guidance about that process. To learn more, please open the attached file.  

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  • Added On: 4/11/2019

FCC Reminds All Virginia Radio Stations Regarding License Renewal Process

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FCC REMINDS ALL VIRGINIA RADIO STATIONS THAT LICENSE RENEWAL APPLICATIONS MUST BE FILED THIS SUMMER; ON-AIR ANNOUNCEMENTS MUST BEGIN IN LESS THAN TWO WEEKS! The FCC recently released a Public Notice (“Notice”) reminding broadcasters of the rapidly approaching license renewal application filing deadline of June 1, 2019, for all radio stations licensed to communities in Virginia. The Notice also reminds licensees of Virginia radio stations that the renewal process really begins in earnest much sooner than that – in less than two weeks – with stations’ on-air, pre-filing announcements. To learn more, please open the attached file.  

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  • Added On: 3/19/2019

FCC Adopts Repack Reimbursement Rules for LPTV/TV Translator and FM Stations -- FCC EEO Oversight Moves to Enforcement Bureau

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FCC ADOPTS RULES GOVERNING REIMBURSEMENT PROGRAM FOR LPTV/TV TRANSLATOR STATIONS AND FM STATIONS DISPLACED BY REPACK The FCC voted at its open meeting today to approve a Report and Order that adopts rules for how (i) LPTV and TV translator stations and (ii) FM stations (i.e., full power FM, FM translator, and LPFM stations) will be reimbursed for costs they incur as a result of the post-incentive auction repacking of the 600 MHz spectrum band. This Order will affect hundreds, perhaps thousands, of facilities. According to the Order, more than 2,100 LPTV Stations filed displacement applications during the FCC’s Special Displacement Window, while nearly 500 FM Stations may feel operational effects as a result of repacked full power/Class A TV station construction activities. To learn more, please open the attached file. * * * FCC OFFICIALLY MOVES EEO OVERSIGHT TO THE ENFORCEMENT BUREAU Effective today, the FCC staffers who are responsible for enforcing the Commission’s equal employment opportunity (“EEO”) rules have officially been moved from the Media Bureau to the Enforcement Bureau. Chairman Pai has stated that he hopes this reorganization will improve the FCC’s enforcement of its EEO rules and strengthen the Commission’s commitment to fighting discrimination. More information is available in the attached file.  

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  • Added On: 3/15/2019

Comment Dates for Ownership Proceeding; GMR Interim License Extension Available to Radio Stations; FCC Seeks Comment on TV Ratings System

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COMMENT DATES ANNOUNCED FOR QUADRENNIAL REVIEW OF MEDIA OWNERSHIP RULES The FCC kicked off its 2018 Quadrennial Review of media ownership rules with the adoption of a Notice of Proposed Rulemaking in December 2018. The rules under review in the proceeding are (1) the Local Television Ownership Rule, (2) the Local Radio Ownership Rule, and (3) the Dual Network Rule. The Notice also seeks comment on a few proposals relevant to promoting diversity in the broadcast industry. Comments are due April 29, 2019, and reply comments are due May 29, 2019. To learn more, please open the attached file. * * * GMR (GLOBAL MUSIC RIGHTS) MAKES EXTENDED INTERIM LICENSE AVAILABLE TO RADIO STATIONS; STATIONS MUST TAKE ACTION BY MARCH 31, 2019 Performing rights organization Global Music Rights (“GMR”) is again offering an extension of its interim license. Commercial radio stations wishing to extend their interim license with GMR must take action by March 31, 2019. Please open the attached file to learn important information about how to take action. * * * FCC SEEKS COMMENT ON TV RATINGS SYSTEM In a February 26, 2019, Public Notice, the FCC is seeking comments on the television content rating system, which aims to provide parents both with timely information about the nature of upcoming video programming and with the technical tools necessary to easily block violent, sexual, or other objectionable programming. More information is available in the attached file.  

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  • Added On: 3/1/2019

Political Ad Disclaimers -- Mid-Term EEO Report Eliminated -- Native Advertising Reminder -- Drone Law Developments

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FEDERAL ELECTION COMMISSION SEEKS COMMENT ON CHANGING SIZE OF TV POLITICAL DISCLAIMERS Recent news out of the Federal Election Commission (“FEC”) ought to get broadcasters’ attention, as possible revisions that the FEC may make to its political advertising disclaimer rules could set up a conflict with the FCC’s political broadcasting rules, potentially leading to confusion. We learned this week that the FEC is seeking comment on whether to launch a proceeding that would consider changing the required size (or, really, the required vertical picture height) of disclaimers on television political advertisements. To learn more, please open the attached file. * * * FCC ELIMINATES MID-TERM EEO REPORT Broadcasters will soon have one less regulatory requirement to worry about. That’s because the Commission at its February open meeting adopted an Order eliminating the Mid-Term EEO (Equal Employment Opportunity) report, known as the FCC Form 397 report. To learn more, please open the attached file. * * * FEDERAL TRADE COMMISSION CONSENT ORDERS PROVIDE USEFUL REMINDER REGARDING NATIVE ADVERTISING Two consent orders approved recently by the Federal Trade Commission (“FTC”) serve as a salient reminder for broadcasters about the nature of native advertisements—and to be wary of where the line is drawn between creative advertising and consumer deception. That’s especially true for broadcasters who assist advertisers with the generation of content for non-broadcast platforms such as websites, apps, and social media. To learn more, please open the attached file. * * * DRONE DEVELOPMENTS: FAA REQUIRES EXTERNAL MARKING ON DRONES; COMMENT DEADLINE SET FOR DRONE FLIGHTS OVER PEOPLE Recent Federal Aviation Administration (“FAA”) activity is likely to impact broadcasters who utilize drones in the course of newsgathering, video production, and tower inspections—both in the short term, and potentially, in the long term as well: a new rule regarding external identification/marking of drones takes effect on February 25, 2019; and, the comment deadline has been set on the FAA’s potential relaxation of restrictions on various drone operations (including flights over people). To learn more, please open the attached file.  

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  • Added On: 2/15/2019

Video Description; TV Rescan Help Center; License Posting Requirement Eliminated

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FCC SEEKS COMMENT ON VIDEO DESCRIPTION FOR REPORT TO LAWMAKERS The FCC issued a Public Notice earlier this week seeking comments regarding recent developments in the video description marketplace as it prepares a report that must be submitted to Congress this coming October. The FCC is required by law to let Congress know whether it believes the current video description rules should be extended to additional markets. To learn more, please open the attached file. * * * REPACK UPDATE: COMMISSION CREATES CONSUMER HELP CENTER FOR TV RESCANNING ASSISTANCE The Commission recently announced that it is launching a special call center dedicated to helping viewers of repacked over-the-air TV stations rescan their TVs during the ongoing post-auction repack. To learn more, please open the attached file. * * * FCC ELIMINATES LICENSE POSTING REQUIREMENT Broadcasters can take down and recycle their physical station licenses. That’s because, effective February 8, 2019, the FCC has eliminated the requirement that a station’s physical license, and any other instruments of authorization, must be posted in a conspicuous place at the principal control point of the transmitter (typically by affixing them to the wall or putting them in a binder). To learn more, please open the attached file.  

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  • Added On: 2/7/2019

Four-Month Countdown: All Virginia Radio Stations Must File License Renewal Applications This Summer!

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FOUR-MONTH COUNTDOWN: ALL VIRGINIA RADIO STATIONS MUST FILE LICENSE RENEWAL APPLICATIONS THIS SUMMER! A mere four months from now—i.e., by June 1, 2019—all radio stations licensed to communities in Virginia will be required to file license renewal applications. Each station’s license renewal application (FCC Form 303-S) and Broadcast Equal Employment Opportunity Program Report (FCC Form 396) must be electronically filed with the FCC no later than June 1, 2019. Two months prior to the June 1 filing deadline, stations are required to commence their on-air pre-filing announcements, which will need to be repeated on a schedule dictated by the FCC’s rules (the content of the announcements is also dictated by the FCC’s rules). Thus, the license renewal process really gets underway on April 1. To learn more, please open the attached file.  

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FCC Further Extends Certain Deadlines -- Including OPIF Submissions for Fourth Quarter 2018 Materials

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FCC FURTHER EXTENDS CERTAIN DEADLINES IN WAKE OF REOPENING AFTER GOVERNMENT SHUTDOWN; OPIF FILINGS IMPACTED The FCC is further revising—and extending—some of its filing and other deadlines in the wake of the partial government shutdown. In a Public Notice (“Notice”) released this afternoon, the Commission announced that it is further extending certain deadlines because parties did not have full access to some electronic systems and databases during the suspension of operations due the government shutdown. These new deadlines supersede and replace the previously extended deadlines that we told you about. The Notice provides a new deadline for Online Public Inspection File submissions that would have been due during the shutdown (including fourth quarter 2018 materials), among other revised deadlines. To learn more, please open the attached file.  

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  • Added On: 1/29/2019

OPIF Is Accessible; More to Come on Filing Deadlines When FCC Re-Opens Monday

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WITH THE FEDERAL GOVERNMENT RE-OPENING, WHAT ARE THE IMPLICATIONS FOR FCC DEADLINES? WE DON’T YET KNOW FOR CERTAIN, BUT WE EXPECT THE FCC TO TELL US MORE ON MONDAY While we welcome the development that the partial federal government shutdown has come to an end, it immediately brings to mind questions about the FCC implications for broadcast stations. When are the routine quarterly filings from 4Q 2018 due? Can stations begin filing routine license/license modification applications again? Can stations access their online public files (OPIF) again? Please open the attached PDF file to learn more about these developments.  

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  • Added On: 1/27/2019

FCC Details Impact of Government Shutdown on Commission Operations

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FCC FILING SYSTEMS WILL REMAIN FUNCTIONAL, TV REPACK DEADLINES WILL CONTINUE TO APPLY, AND OTHER DETAILS OF GOVERNMENT SHUTDOWN IMPLICATIONS FOR FCC OPERATIONS AND FILINGS In a Public Notice (“Notice”) released this afternoon, the FCC details the impacts that the continuing, partial government shutdown will have on Commission operations. The Notice explains that the FCC will suspend most of its operations in the middle of the day on Thursday, January 3, 2019. The Notice discusses how the shutdown will impact FCC electronic filing and database systems; filing deadlines; fee payments; STAs; transaction shot clocks; and, crucially, incentive auction-related matters, among other things. For more information, please open the attached file.  

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  • Added On: 1/2/2019

VAB 2019 Regulatory Calendar for Virginia Broadcast Stations

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  • Added On: 1/7/2019

Primer on Music Licensing for Broadcasters

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  • Added On: 8/16/2019

Changes to Your Children's Television Obligations -- What You Need to Know

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YOUR CHILDREN’S TELEVISION OBLIGATIONS WILL SOON BE CHANGING: EXPECT GREATER FLEXIBILITY AND YEARLY (RATHER THAN QUARTERLY) REPORTING As you know, the FCC adopted and released a long-anticipated Order in July revising its children’s E/I (educational/informational) television rules. The attached Special Report describes the newly revised rules and their respective effective dates. Please note: Some of the new rules go into effect soon—on September 16, 2019. Others—such as the change to an annual, rather than quarterly, filing obligation (as well as certain changes to on-air disclosure requirements)—still require approval by the Office of Management and Budget, and although such approval is likely, it is also likely that the OMB approval process will take a couple of months or more. The attached Special Report contains an overview of the new rules followed by a more detailed discussion of the new rules in Question-and-Answer format, designed to address common questions you may have regarding your obligations under the new rules. To learn more, please open the attached Special Report.  

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  • Added On: 9/3/2019

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