Legal Memorandums: 2018
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2018 Regulatory Calendar
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2018 Regulatory Calendar
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Ancillary/Supplementary Services Report Deadline -- Comment Dates on Latest AM Revitalization Item
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DTV ANCILLARY/SUPPLEMENTARY SERVICES REPORT: A DECEMBER "TRADITION” NOW A THING OF THE PAST - FOR MOST TV STATIONS At this time of the year, television broadcasters used to get a reminder (or several!) from us regarding the requirement to file the "ancillary/supplementary” services report (formerly known as "Form 317” and currently known as Form 2100, Schedule G). Thankfully, as you may recall, the FCC adopted a Report and Order in April revising its rules so that only those digital television broadcasters that actually provided feeable ancillary or supplementary services are required to submit the annual report. For such stations, the report is due by December 3rd. To learn more, please open the attached file. * * * AM REVITALIZATION: COMMENT DATES SET ON PROPOSALS TO REDUCE INTERFERENCE PROTECTION TO CLASS A AM RADIO STATIONS Comment dates are set on the FCC's Second Further Notice of Proposed Rulemaking that seeks, among other things, input on several proposals for reducing the extensive interference protections currently afforded to Class A radio stations, in order to enable improvements to local radio service by other classes of stations. The Second Further Notice is part of the FCC's ongoing efforts to revitalize AM service. Comments on the Second Further Notice are due January 22, 2019, and reply comments are due February 19, 2019. To learn more, please open the attached file.
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Annual EEO Reports Due June 1, 2018
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EEO PUBLIC FILE REPORTS DUE JUNE 1, 2018, FOR VIRGINIA RADIO AND TELEVISION STATIONS Virginia broadcast stations—both radio and television—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 1, 2018. To learn more, please open the attached file.
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Biennial Reports Due March 2
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REMINDER: ALL STATIONS MUST FILE 2017 BIENNIAL OWNERSHIP REPORTS BY MARCH 2 Stations are running out of time to draft and file their 2017 Biennial Ownership Reports; they must be filed in the FCC's LMS filing system by March 2. Please open the attached file for more information.
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Children's TV Comment Dates, Copyright Royalties, Audio Programming
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COMMENT DATES SET ON CHILDREN'S TELEVISION PROGRAMMING RULES NOTICE OF PROPOSED RULEMAKING The FCC's Notice of Proposed Rulemaking to examine the children's television programming rules is scheduled to be published in the Federal Register tomorrow, which means comment dates on the Notice are now set. Comments may be filed on or before September 24, 2018, and reply comments may be filed on or before October 23, 2018. To learn more, please open the attached file. * * * ONE-WEEK COUNTDOWN: TV STATION COPYRIGHT ROYALTY CLAIMS DUE JULY 31, 2018 Television stations have just one week left to file distant signal copyright royalty claims for the year 2017. Claims for 2017 must be filed no later than 11:59 p.m. EST on July 31, 2018. To learn more, please open the attached file. * * * FCC SEEKS COMMENT ON STATE OF COMPETITION IN "AUDIO PROGRAMMING” MARKETPLACE The FCC announced in a Public Notice released on July 23, 2018, that it is seeking comment on "the state of competition in the marketplace for the delivery of audio programming,” including the "competition to deliver audio service among broadcast stations, satellite radio, and entities that provide audio content via the internet and to mobile devices.” The Commission is gathering the information in order to use it in drafting its first "Communications Marketplace Report” for Congress. To learn more, please open the attached file.
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Children's TV; ATSC 3.0; New FM Class
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FCC PROPOSES CHANGES TO AND SEEKS COMMENT ON CHILDREN'S E/I TELEVISION PROGRAMMING RULES As we reported previously, at its July 12, 2018, meeting, the FCC adopted a Notice of Proposed Rulemaking ("Notice”) to examine the children's television programming rules. The Notice considers significant changes to the children's television programming rules that would, if ultimately adopted, affect both the E/I programming and reporting obligations of television broadcasters. For a detailed summary of the proposals on which the Notice seeks comment, please open the attached file. * * * ATSC 3.0 SIMULCASTING RULES NOW IN EFFECT - BUT FCC NOT ACCEPTING NEXT GEN TV APPLICATIONS JUST YET The FCC released a Public Notice last week announcing that its ATSC 3.0 rules governing simulcasting and consumer education requirements have now taken effect, but the Commission is still working on the application form that stations wishing to begin using Next Gen TV must complete. In other words, the ATSC 3.0 rules are now effective, but stations cannot yet log onto the FCC's Licensing and Management System (LMS) and apply to start broadcasting in 3.0. To learn more, please open the attached file. * * * COMMENT DATES SET ON FCC'S PROPOSAL TO CREATE A NEW CLASS OF FM STATIONS AND AMEND "SHORT-SPACING” RULES Comment dates are now set on the Notice of Inquiry in which the FCC (1) explores the possibility of creating a new intermediate class of FM radio stations—to be designated as Class C4—and (2) queries whether it should amend its "short-spacing” rules (through which stations can seek to locate transmitters at distances shorter than the FCC's standard separation requirements). Comments may be filed on or before August 13, 2018, and reply comments may be filed on or before September 10, 2018. To learn more, please open the attached file.
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Children's TV; C-Band Spectrum; EAS Form One; EEO Enforcement
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FCC ADOPTS NPRM, OFFICIALLY LAUNCHES PROCEEDING TO EXAMINE CHILDREN'S E/I TELEVISION PROGRAMMING RULES At its July 12, 2018, meeting, the FCC adopted a Notice of Proposed Rulemaking to examine the children's television programming rules. The Notice contemplates significant changes to the children's television programming rules that would, if ultimately adopted, affect both the E/I programming and reporting obligations of television broadcasters. To learn more, please open the attached file. * * * FCC ADOPTS NOTICE SEEKING COMMENT ON EXPANDING USES OF CRUCIAL C-BAND SPECTRUM AND ORDER REQUIRING EARTH STATION INFORMATION Also at its July 12, 2018, meeting, the FCC by a 4-0 vote adopted a Notice of Proposed Rulemaking and Order that puts broadcasters' ongoing battle to guard against "spectrum grabs” front and center, as it seeks comment on various proposals for allowing expanded use of the C-band—the 3.7-4.2 GHz band—for 5G. To learn more, please open the attached file. * * * NATIONWIDE EAS TEST "FORM ONE” DUE AUGUST 27; RUMOR CIRCULATING ABOUT SEPTEMBER 20 NATIONWIDE TEST In a recent Public Notice, the FCC established the deadline (August 27, 2018) for all broadcasters (and other EAS Participants) to file their annual EAS "Form One” via the ETRS (EAS Test Reporting System) filing platform. To learn more, please open the attached file. * * * FCC PROPOSES TO MOVE EEO OVERSIGHT TO THE ENFORCEMENT BUREAU The FCC recently announced a proposal to move the agency staff responsible for enforcing the Commission's equal employment opportunity rules from the Media Bureau to the Enforcement Bureau. To learn more, please open the attached file.
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Deadline to Register Existing C-Band Downlink Earth Station Dishes Extended to October 17
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DEADLINE TO REGISTER EXISTING C-BAND DOWNLINK EARTH STATION DISHES EXTENDED TO OCTOBER 17, 2018 The FCC has extended the window within which broadcasters can register their existing (constructed and operational as of April 19, 2018) C-band receive-only earth stations by 90 days—until October 17, 2018. The Commission announced the 90-day extension in a Public Notice released today in response to concerns raised by many parties over the volume of unregistered earth stations and the difficulties of preparing the information for filing. To learn more, please open the attached file.
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Deadlines for C-Band Earth Station Registration and EAS Form Three
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JUST TWO MORE DAYS! C-BAND DOWNLINK EARTH STATIONS MUST BE REGISTERED BY OCTOBER 17, 2018! We're writing to remind you of a critical deadline: broadcasters have just two more days, until October 17, 2018, to register their existing (constructed and operational as of April 19, 2018) C band receive-only earth stations. To learn more, please open the attached file. * * * DEADLINE: EAS FORM THREE DUE NOVEMBER 19; FORM TWO FILING WINDOW STILL OPEN This is a reminder that broadcasters must file the Form Three EAS Report by 11:59 p.m. on November 19. The Form Three report seeks detailed, post-test data related to the nationwide test of the Emergency Alert System, which took place on October 3rd. To learn more, please open the attached file.
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DEADLINES! EAS Form Two - 3Q Transition Reports - C-Band Station Registration
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This is a reminder that broadcasters must file the Form Two EAS Report by 11:59 p.m. on October 3, just hours after today's live, nationwide test of the Emergency Alert System ("EAS”). To learn more, please open the attached file.
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Displacement Window and Earth Station Deadlines -- 2018 Reg Fees
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10-DAY COUNTDOWN TO SPECIAL DISPLACEMENT WINDOW FILING DEADLINE FOR CERTAIN LOW POWER TELEVISION STATIONS AND TV TRANSLATORS! This is a reminder that the Special Displacement Window during which certain low power television and TV translator stations can file displacement applications closes in ten days—on Friday, June 1, 2018, at 11:59 pm Eastern Time. To learn more, please open the attached file. * * * LESS THAN TWO MONTHS LEFT TO REGISTER EXISTING C-BAND DISHES! Stations have until July 18, 2018 to register their "existing” C-band earth stations. Many broadcast stations use C-band downlink earth stations to receive network and syndicated programming, but since the FCC's rules do not require receive-only earth stations to be licensed or registered, many broadcasters who use such dishes have never registered them with the FCC. To learn more, please open the attached file. * * * FISCAL YEAR 2018 REGULATORY FEES PROPOSED The FCC has released its proposed regulatory fees for fiscal year 2018. In a Report and Order and Notice of Proposed Rulemaking released May 22, 2018, the FCC proposes to collect $322,035,000 from all regulatees, which represents a 9 percent decrease in regulatory fees from fiscal year 2017. To learn more, please open the attached file.
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Earth Station Reimbursement -- EAS Form 3 -- OPIF -- Premature Construction
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NOVEMBER 15: DEADLINE TO SEEK REIMBURSEMENT FOR C-BAND EARTH STATION REGISTRATION APPLICATION FEE Broadcasters hoping to be reimbursed the money they paid to register their existing C-band downlink earth stations must take action by November 15, 2018. You'll recall that satellite operator SES established a program under which it offered to reimburse stations in the amount of the FCC's filing fee incurred in connection with earth station registration. To learn more, please open the attached file. * * * NOVEMBER 19: EAS FORM THREE DUE This is a reminder that broadcasters have less than a week, until 11:59 p.m. on November 19, to file the Form Three EAS Report. The Form Three Report seeks detailed, post-test data related to the nationwide test of the Emergency Alert System ("EAS”), which took place on October 3rd. To learn more, please open the attached file. * * * FCC TO TURN "ON” ANY RADIO STATION ONLINE PUBLIC INSPECTION FILES STILL "OFF” ON NOVEMBER 15 The Commission last week released a Public Notice that provided a not-so-subtle hint to any radio stations that have yet to transition to the Online Public Inspection File: the time to activate the OPIF is now. To learn more, please open the attached file. * * * FCC FINES BROADCASTER $5,000 FOR PREMATURE CONSTRUCTION An FCC fine levied this week against a broadcaster for "premature construction” serves as a good reminder—and cautionary tale—for stations that may be making (or are planning to make) changes to their facilities, whether as a result of the post-auction repack or otherwise. To learn more, please open the attached file.
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EAS Equipment Upgrade - Video Description - Prometheus Denied
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EAS ALERT - YOUR EQUIPMENT MAY NEED AN UPGRADE! From apps on our smartphones to software on our computers, we're all reminded on a near-daily basis about the need for regular upgrades to technology. And broadcasters' EAS (Emergency Alert System) equipment is no exception. To learn more, please open the attached file. * * * EXPANDED VIDEO DESCRIPTION REQUIREMENT TAKES EFFECT JULY 1, 2018 Television stations that are affiliated with Big 4 Networks in the Top 60 DMAs have just a few more weeks—until July 1, 2018—before they must comply with expanded video-described programming rules. To learn more, please open the attached file. * * * FCC REJECTS INFORMAL OBJECTION TO HUNDREDS OF FM TRANSLATOR APPLICATIONS The FCC wasted little time in dismissing and denying an Informal Objection filed in late May by three so-called advocacy groups against almost 1,000 pending FM translator applications. To learn more, please open the attached file.
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Expanded Deadline for Stations Seeking Reimbursement of Earth Station Registration Fees -- Form Three -- and More!
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SES EXPANDS DEADLINE FOR REIMBURSEMENT OF FCC FILING FEES FOR C-BAND DOWNLINK EARTH STATION REGISTRATION We write with good news regarding reimbursement of FCC filing fees incurred by stations in registering their existing C-band downlink earth station dishes: C-band satellite operator SES has extended—by two weeks, until November 15, 2018—the deadline by which stations may seek reimbursement. To learn more, please open the attached file. * * * OCTOBER 31 DEADLINE: JUST DAYS LEFT TO REGISTER C-BAND DOWNLINK EARTH STATIONS Speaking of earth stations, a reminder for broadcasters that the deadline for filing applications to register existing (as of April 18, 2018) C-band downlink earth stations is just days away: October 31, 2018. To learn more, please open the attached file. * * * THREE-WEEK COUNTDOWN: EAS FORM THREE DUE NOVEMBER 19 We also write to remind broadcasters that they have three more weeks to file the Form Three EAS Report, which is due by 11:59 p.m. on November 19. The Form Three report seeks detailed, post-test data related to the nationwide test of the Emergency Alert System ("EAS”), which took place on October 3rd. To learn more, please open the attached file.
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FCC Adopts Notice Proposing Rules for Reimbursement for Displaced LPTV, Translator, FM Stations
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FCC PROPOSES RULES FOR REIMBURSEMENT PROGRAM FOR LPTV, TRANSLATOR AND FM STATIONS DISPLACED BY REPACK As expected, last week the FCC adopted a Notice of Proposed Rulemaking and Order that proposes rules for how (i) LPTV and TV translator stations and (ii) FM stations (i.e., full power FM, FM translator, and, possibly, LPFM stations) should be reimbursed for costs they incur as a result of the post-incentive auction transition of the 600 MHz spectrum band. You may recall that we reported last month on a draft version of the Notice. While much of the Notice mirrors the initial draft, the Commission did, in fact, make several significant changes to the draft, which are reflected in the adopted Notice. Those changes are incorporated into our summary of the Notice, which you can read in the attached file.
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FCC ANNOUNCES TWO-DAY EXTENSION OF REGULATORY FEE PAYMENT DEADLINE FOR STATIONS AFFECTED BY HURRICANE FLORENCE
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In a Public Notice released Friday morning (which is attached to this email), the FCC announced that broadcast stations affected by Hurricane Florence have been given a short, two-day extension of the payment deadline for fiscal year 2018 regulatory fees. That means that the deadline for stations affected by Hurricane Florence to file and pay their FY 2018 regulatory fees is now 11:59 p.m. Eastern Time on Thursday, September 27, 2018. The Public Notice acknowledges that Hurricane Florence has caused substantial damage to the communications network, resulting in service disruptions and outages in several areas, including Chesapeake City, Suffolk City, Virginia Beach City. Broadcasters that have stations in the above-mentioned counties that have been affected by Hurricane Florence may take advantage of the extra two days to pay regulatory fees. Note that we do not expect the FCC to further extend the deadline, however. The FCC Staff has also indicated to us informally that stations in Florence-affected areas that miss the extended deadline for the filing of regulatory fees should contact the FCC staff on a station-by-station basis in order to determine how best to proceed. In the past, the FCC has waived the 25% late fee for such stations when such stations enter into an installment plan to spread their regulatory fee payments over a longer period of time (with a low interest rate on the order of one percent). Stations who believe they may be experiencing exceptional circumstances that warrant a waiver of the regulatory fee filing requirement should contact their legal counsel about filing for a station-specific waiver. For all other stations, the reg fee deadline remains the same, 11:59 p.m. Eastern Time on Tuesday, September 25, 2018. Remember that payment by the deadline applicable to your stations is crucial, as late filing of regulatory fees results in a 25% late payment penalty.
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FCC Kicks Off 2018 Quadrennial Review -- License Posting Requirement Eliminated
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COMMISSION INITIATES 2018 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 at its open meeting on December 12, 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. To learn more, please open the attached file. * * * FCC ELIMINATES LICENSE POSTING REQUIREMENT Broadcasters will soon be able to put away some of their thumb tacks and scotch tape and recycle some old binders. That's because the FCC, on December 11, 2018, adopted a Report and Order that eliminates 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, either by affixing them to the wall or putting them in a binder. To learn more, please open the attached file.
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FCC Launches Proceeding to Examine Children's E/I Television Programming Rules
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FCC LAUNCHES PROCEEDING TO EXAMINE CHILDREN'S E/I TELEVISION PROGRAMMING RULES The FCC has opened a docket for its examination of the children's television programming rules and has released its long-awaited draft Notice of Proposed Rulemaking on the subject. The draft Notice contemplates significant changes to the children's television programming rules that would, if ultimately adopted, affect both the E/I programming and reporting obligations of television broadcasters. The Commission will consider—and likely adopt—this Notice at its July 12, 2018, meeting. As noted, only a draft of the Notice has been released at this time; the draft Notice is subject to change before the July 12 meeting, and the draft does not constitute official action by the FCC. To learn more, please open the attached file.
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FCC Proposes Reimbursement Program for Displaced LPTV -- Translator -- FM Stations
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FCC PROPOSES REIMBURSEMENT PROGRAM FOR LPTV/TX STATIONS AND FM STATIONS DISPLACED BY THE FULL POWER/CLASS A TV REPACK The FCC recently released a draft Notice of Proposed Rulemaking and Order, which represents the first step in implementing the congressional mandate that certain (i) LPTV and TV translator stations and (ii) FM stations (i.e., full power FM, FM translator, and, possibly, LPFM stations) be reimbursed for costs incurred as a result of the post-incentive auction transition of the 600 MHz spectrum band. To learn more, please open the attached file.
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FCC Proposes to Eliminate Broadcast Mid-Term EEO Report -- FCC Form 397
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The Broadcast Mid-Term EEO Report (FCC Form 397) may soon be a thing of the past. The FCC adopted a Notice of Proposed Rulemaking at its February 22, 2018, meeting that proposes to eliminate the requirement that certain broadcast television and radio stations file Form 397 at the midway point of each license term. To learn more, please open the attached file.
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FCC Seeks Comment on Must Carry/Retrans Election Notice Proposal -- EAS Blue Alert
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FCC SEEKS COMMENT ON NAB-NCTA JOINT PROPOSAL TO MODERNIZE AND STREAMLINE RETRANS CONSENT/MUST CARRY ELECTION PROCESS The days of broadcasters tracking down addresses and sending retransmission consent/must carry election notices to MVPDs via certified mail could be numbered if the FCC adopts a joint proposal submitted earlier this month by NAB and NCTA regarding the triennial carriage election process. The FCC is now seeking comment on the joint proposal, which aims to streamline the election process and to make that process less burdensome on, and less worrisome for, broadcasters. Comments are due soon, on January 7, 2019; reply comments are due shortly thereafter, on January 17, 2019. To learn more, please open the attached file. * * * REMINDER: UPCOMING "BLUE ALERT” EAS EVENT CODE COMPLIANCE DEADLINE The FCC's compliance deadline for delivery of so-called "Blue Alerts” over the Emergency Alert System ("EAS”) takes effect in less than a month, on January 18, 2019. To be clear, Blue Alerts are voluntary under the FCC's rules—stations are not required to broadcast them; the January 18 deadline is directed to EAS equipment manufacturers who must make it possible for a broadcaster to upgrade its existing EAS equipment in order to make it capable of processing Blue Alerts if the broadcaster in fact wishes to disseminate Blue Alerts. To learn more, please open the attached file.
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FCC Seeks Comment on Reimbursable Costs for LPTV and FM Stations Affected by Repack
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FCC SEEKS COMMENT ON PROPOSED CATALOG OF REIMBURSABLE EXPENSES FOR DISPLACED LOW POWER TV STATIONS AND FM STATIONS AFFECTED BY THE REPACK Today, the FCC released a Public Notice that seeks comment on a proposed catalog of potentially reimbursable costs that may be incurred by low power TV stations, TV translator stations, and FM broadcast stations that are affected by the post-Auction repacking of the TV band. Comments are due by November 21, 2018, and reply comments are due by December 6, 2018. To learn more, please open the attached file.
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FM Translator Filing Window to Open; Comments Due on Method of Retrans/Must-Carry Election Notices; SoundExchange Royalty Rates Increase; Main Studio Rule Eliminated
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FM TRANSLATOR FILING WINDOW FOR AM STATIONS OPEN JANUARY 25 - 31, 2018; FREEZE ON CERTAIN APPLICATIONS BEGINS JANUARY 18 The FCC's FM translator auction filing window for certain AM stations to apply for new FM translator station construction permits will open from January 25 to January 31, 2018. In connection with this filing window, the Media Bureau will institute a freeze on and will not accept Low Power FM and FM translator minor change applications and FM booster construction permit applications between January 18 and January 31, 2018. To learn more, please open the attached file. * * * COMMENT ON POSSIBLE CHANGES TO MANNER IN WHICH BROADCASTERS NOTIFY MVPDS OF CARRIAGE ELECTIONS ARE DUE FEBRUARY 15, 2018 Comment dates are now set on a Notice of Proposed Rulemaking that considers revisions to several rules requiring broadcast stations and cable providers to provide certain types of notices in writing. Of most interest to broadcasters, the Notice seeks comment on whether and how to update the current requirement that broadcast stations make their triennial retransmission consent/must-carry elections to MVPDs in written notices sent via certified mail. To learn more, please open the attached file. * * * 2018 BRINGS INCREASE IN SOUNDEXCHANGE ROYALTY RATES The Copyright Royalty Board recently announced an increase in the sound recording royalty rates that noninteractive webcasters pay to SoundExchange, effective January 1, 2018. To learn more, please open the attached file. * * * MAIN STUDIO RULE ELIMINATED AS OF JANUARY 8, 2018 The Main Studio Rule was officially eliminated as of January 8, 2018. Although the Rule itself is gone, some related requirements remain. To learn more, please open the attached file.
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FM Translator Interference Proceeding--Silent Station Renewal Warning--License Posting Proceeding
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FCC PROPOSES TO STREAMLINE THE FM TRANSLATOR INTERFERENCE COMPLAINT PROCESS Last week, the FCC adopted a long-awaited Notice of Proposed Rulemaking that proposes to "streamline” and "expedite” the FM translator complaint resolution process. To learn more, please open the attached file. * * * WARNING: FCC CONTINUES TO TAKE HARD LOOK AT SILENT STATION LICENSE RENEWAL APPLICATIONS With the license renewal cycle for radio stations set to get underway in about a year, the FCC continues to signal that it will take a hard, critical look at renewal applications filed by stations that have been silent for significant portions of their current license terms. To learn more, please open the attached file. * * * FCC MAY ELIMINATE BROADCAST LICENSE POSTING REQUIREMENTS Stations might soon be able to put away some of their thumb tacks and scotch tape and recycle some old binders. That's because the FCC, on May 10, 2018, adopted a Notice of Proposed Rulemaking that seeks comment on whether it should streamline or eliminate the requirement that the station license (and any other instruments of authorization) must be posted in a conspicuous place at the principal control point of the transmitter. To learn more, please open the attached file.
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January FCC Filing Deadlines--Implications of the Partial Government Shutdown
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HOW DOES THE PARTIAL GOVERNMENT SHUTDOWN AFFECT FCC QUARTERLY (AND OTHER) JANUARY FILING DEADLINES? As you know, broadcast stations are required to prepare a number of routine FCC filings by January 10, 2019, including the following: (i) All full power and Class A television stations and all full power radio stations must prepare Issues/Programs Lists covering the period October 1 - December 31, 2018, and upload them to their online public inspection files ("OPIF”) by January 10; (ii) All commercial full power and Class A TV stations must complete and file electronically with the FCC a Children's Television Programming Report (FCC Form 398) covering the fourth quarter of 2018; (iii) All commercial full power and Class A TV stations must upload records to the OPIF to demonstrate compliance in 4Q 2018 with the commercial limits in certain children's programming; (iv) Class A TV stations must upload to the OPIF documentation sufficient to demonstrate that the station continued in 4Q 2018 to meet the eligibility requirements to operate as a Class A TV station; (v) Certain noncommercial stations that conducted on-air fundraising for a third party non-profit during 4Q 2018 must upload to the OPIF a report of such activity; and (vi) Full power and Class A transitioning stations that are changing channels in the post-auction transition are required to file a Form 387 Transition Progress Report covering the fourth quarter of 2018. As you may be aware, a portion of the federal government has been shut down since December 22, 2018, and the FCC issued a release on December 22 announcing that it would remain fully operational through at least January 2, 2019. Thus, as of December 31, 2018, the FCC's OPIF system and other filing platforms and databases remain fully functional and available for broadcasters to use to comply with the six filing requirements outlined above. If the government shutdown persists, we do not yet know what the FCC will do after January 2, 2019, i.e., whether the FCC will remain open and operational or whether the FCC will cease its non-essential operations and shutter its website, filing platforms and various online databases. During the 16-day government shutdown in October 2013, the FCC's website, filing platforms, and online databases were all unavailable, which subsequently resulted in the FCC's extension of various filing deadlines after the shutdown ended. Whether the current shutdown will result in a similar outcome remains unknown at this time, and we expect the FCC to make a public statement on or before January 2 to let us know; we will know more at that time and we will share important information with you. Because we don't know when the government shutdown will end or what the implications will be for FCC filing deadlines, our guidance is for stations to continue to proceed apace with their regular quarterly filing protocols and processes in order to be ready for the January 10, 2019, filing deadline. We will provide additional information regarding these issues as we learn more from the FCC in the coming days.
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July 30 1 pm NAB C-band Webcast, C-band Registration Fee Reimbursement
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1 P.M. ET ON JULY 30: NAB HOSTING C-BAND WEBCAST FOR NAB MEMBERS Today, July 30, at 1 p.m. ET, NAB is offering its members an informational webcast about the FCC's C-band proceeding. For further information, including a link to the registration page, please open the attached file. * * * SES ESTABLISHES PROGRAM TO REIMBURSE FCC FILING FEES INCURRED BY BROADCASTERS TO REGISTER C-BAND DOWNLINK EARTH STATION DISHES SES, a C-band satellite operator, is offering to reimburse broadcasters (and others) the $435 FCC filing fee incurred in connection with the filing of new registration applications for C-band downlink dishes. To learn more, please open the attached file.
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July Deadlines -- Tip for LPTV Reimbursement
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SECOND QUARTER "TRANSITION PROGRESS REPORTS” FOR POST-AUCTION TRANSITIONING STATIONS DUE JULY 10, 2018 This is a reminder for all full power and Class A transitioning stations that are changing channels in the post-Auction transition that the next quarterly Transition Progress Report—FCC Form 387—is due July 10, 2018. To learn more, please open the attached file. * * * 30 DAYS LEFT TO REGISTER EXISTING C-BAND DOWNLINK EARTH STATION DISHES! And here's another reminder: Stations have just 30 more days—until July 18, 2018—to register their "existing” C-band earth stations. To learn more, please open the attached file. * * * REIMBURSEMENT TIP FOR DISPLACED LPTV/TRANSLATOR LICENSEES Here's a tip for operators of low power television and television translator stations who have to move to a new channel as a result of the post-Auction transition process: get detailed invoices—and save them. To learn more, please open the attached file.
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LPTV Displacement Window -- MMA Passes House -- Ancillary/Supp Services Rpt
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FOUR-WEEK COUNTDOWN REMINDER FOR SPECIAL DISPLACEMENT WINDOW FILINGS FOR CERTAIN LOW POWER TELEVISION STATIONS AND TV TRANSLATORS This is a four-week countdown reminder for the deadline for filing displacement applications for certain low power television and TV translator stations in the Special Displacement Window. You'll recall that the FCC announced last month that it had extended the filing deadline to Friday, June 1, 2018, at 11:59 pm Eastern Time. To learn more, please open the attached file. * * * HOUSE PASSES "MUSIC MODERNIZATION ACT” - NO PERFORMANCE TAX INCLUDED In a vote seeking to bring sweeping changes to the music licensing ecosystem, the House of Representatives unanimously passed the Music Modernization Act ("MMA”), H.R. 5447, by a 415-0 vote last week. While the MMA modernizes numerous aspects of copyright law, it is what the MMA does not have that is of most interest to broadcasters: the MMA does not include the so-called "performance tax.” To learn more, please open the attached file. * * * FCC ELIMINATES ANCILLARY/SUPPLEMENTARY SERVICES REPORTING REQUIREMENT FOR MOST STATIONS Thousands of digital television broadcast licensees and permittees will be spared the time and resources (and headaches!) associated with filing the Annual DTV Ancillary/Supplementary Services Report (formerly known as "Form 317” and currently known as Form 2100, Schedule G). To learn more, please open the attached file.
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LPTV Special Displacement Window; Auction 99 Singleton Window; Repack Reimbursement Updates; Silent Station Warning
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ONE-MONTH COUNTDOWN TO SPECIAL DISPLACEMENT WINDOW FOR CERTAIN LOW POWER TELEVISION STATIONS AND TV TRANSLATORS This is a reminder that the Special Displacement Window for certain low power television and TV translator stations will open on Tuesday, April 10, 2018, and close on Tuesday, May 15, 2018, at 11:59 pm Eastern Time. To learn more, please open the attached file. * * * MEDIA BUREAU ANNOUNCES MARCH 14 - MARCH 28 LONG-FORM FILING WINDOW FOR MORE "SINGLETON” FM TRANSLATOR APPLICATIONS The Media Bureau released a Public Notice announcing the opening of a filing window—from March 14 to March 28, 2018—for long-form FM translator construction permit applications filed by those AM stations who timely filed "Tech Box proposals” during last summer's Auction 99 filing window and whose mutually exclusivity has been resolved. To learn more, please open the attached file. * * * REPACK REIMBURSEMENT UPDATES: SECOND ALLOCATION OF REIMBURSEMENT FUNDS, AND MORE FUNDING FROM CONGRESS? We have important repack reimbursement news for all broadcasters affected by the post-Spectrum Auction environment. On March 8, 2018, the FCC released a Public Notice that indicates it anticipates making a second repack reimbursement allocation within the next four to six weeks. Meanwhile, the U.S. House of Representatives passed a bill this week that includes language that would establish a "Broadcast Repack Fund” from which reimbursement payments would be made to repacked television stations in the event the $1.75 billion TV Broadcaster Relocation Fund is exhausted. To learn more, please open the attached file. * * * RENEWAL WARNING: FCC SPEAKS LOUDLY ABOUT "RADIO SILENCE” The license renewal cycle for radio stations gets underway in little more than a year, and the FCC is making clear that it will take a hard—and, perhaps, unfavorable—look at renewal applications filed by stations that have been silent for significant portions of their current license terms. To learn more, please open the attached file.
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May 26 Compliance Deadline Extended for TV Stations
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THE FCC HAS DELAYED THE MAY 26, 2018, DEADLINE FOR TV STATIONS TO VIDEO DESCRIBE EMERGENCY GRAPHICS ON SECONDARY AUDIO PROGRAM STREAM We have previously advised that the FCC was considering a petition filed jointly by the NAB and certain disability advocacy groups to extend the May 26, 2018, compliance deadline for the emergency-graphics-to-speech rule for five more years. Today, May 25, the FCC issued an Order that delays the compliance deadline until November 2023. To learn more, please open the attached file.
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Music Copyright News -- Senate Passes Music Modernization Act -- DC Circuit Upholds CRB SoundExchange Rates
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SENATE PASSES "MUSIC MODERNIZATION ACT” - BILL HEADS BACK TO HOUSE, WITHOUT A PERFORMANCE FEE ON BROADCASTERS Last week, by a unanimous voice vote, the Senate passed the Orrin G. Hatch Music Modernization Act, which will bring sweeping reforms to music copyright law for the first time in decades. You'll recall that a version of the MMA unanimously passed the House in April. Because the Senate made several changes to that bill, the legislation now heads back to the House for another vote, which may happen this week. The MMA is supported by many stakeholders within the music industry—and by NAB. To learn more, please open the attached file. * * * MORE MUSIC COPYRIGHT NEWS: COURT UPHOLDS RADIO STREAMING RATES SET BY COPYRIGHT ROYALTY BOARD Also last week, the United States Court of Appeals for the District of Columbia rejected an appeal from SoundExchange and upheld the royalty rates that the Copyright Royalty Board set (way back in 2015) for SoundExchange for the years 2016 through 2020. To learn more, please open the attached file.
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New FM Class? -- FM Translator Interference -- Prometheus
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FCC LOOKS AT CREATING A NEW CLASS OF FM STATIONS AND AMENDING "SHORT-SPACING” RULES The FCC released a Notice of Inquiry ("Notice”) on June 5, 2018, in which it (1) explores the possibility of creating a new intermediate class of FM radio stations—to be designated as Class C4—and (2) queries whether it should amend its "short-spacing” rules (through which stations can seek to locate transmitters at distances shorter than the FCC's standard separation requirements). To learn more, please open the attached file. * * * COMMENT DATES SET FOR FCC'S PROPOSAL TO STREAMLINE THE FM TRANSLATOR INTERFERENCE COMPLAINT PROCESS Deadlines for comments and reply comments are now set on the FCC's long-awaited Notice of Proposed Rulemaking that proposes to "streamline” and "expedite” the FM translator complaint resolution process. Comments on the Notice will be due July 6, 2018, and reply comments will be due August 6, 2018. To learn more, please open the attached file. * * * ADDITIONAL FM TRANSLATOR ITEMS: PROMETHEUS OBJECTS TO HUNDREDS OF TRANSLATOR APPLICATIONS—AND HAS A RECON PETITION DENIED In other news affecting FM translators, we have two items to report on involving the low-power FM station advocacy group called Prometheus Radio Project. To learn more, please open the attached file.
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Online Political Files Unavailable November 3
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STATIONS MAY NOT HAVE ACCESS TO ONLINE POLITICAL FILES ON SATURDAY, NOVEMBER 3 We have been informed by FCC Staff that access to station online public inspection files—including political files—will be compromised on Saturday, November 3. While Saturday access to online political files would not normally be noteworthy, this coming weekend is the final weekend before the mid-term elections, which means that stations may have been planning to upload time-sensitive political file records to their online political files on November 3. To learn more, please open the attached file.
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OPIF Technical Issues; Deadlines: March 1 Radio OPIF; March 2 Biennial Ownership Reports; May 26 TV Emergency Graphics
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STATIONS MAY NEED TO RE-UPLOAD DOCUMENTS TO ONLINE PUBLIC FILE DUE TO RECENT TECHNICAL ISSUES WITH FCC's OPIF SYSTEM The FCC's online public file system has been malfunctioning recently. To learn more, please open the attached file. * * * THE MARCH 1 DEADLINE IS RAPIDLY APPROACHING FOR RADIO STATIONS TO CONVERT TO ONLINE PUBLIC FILE USE All radio stations must use the online public file system by March 1, 2018. To learn more, please open the attached file. * * * ALL STATIONS MUST FILE BIENNIAL OWNERSHIP REPORTS BY MARCH 2, 2018 The FCC delayed the due date for 2017 Biennial Ownership Reports for all broadcast stations—they must be filed by March 2. To learn more, please open the attached file. * * * TV STATIONS MUST VIDEO DESCRIBE EMERGENCY GRAPHICS BY MAY 26, 2018 All TV stations that air emergency graphics during non-news programming must be ready to video describe those graphics by May 26. This requirement is similar to the existing Audible Crawl Rule that TV stations have been complying with for a couple of years. To learn more, please open the attached file.
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OPIF Warning -- License Revocation Proceeding -- Good Faith Complaint Dismissed
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COMMISSION SENDS WARNINGS TO STATIONS WHOSE ONLINE PUBLIC INSPECTION FILES MAY BE MISSING DOCUMENTS On December 6, FCC staff began sending emails to numerous radio stations that, according to the Commission's records, have not yet uploaded all necessary documents to their Online Public Inspection Files. The emails that we have seen are targeted to specific stations, they identify the particular records/documents that appear to be missing from a station's OPIF, and they warn of penalties if the stations fail to take quick action. To learn more, please open the attached file. * * * STATION'S FAILURE TO PAY REGULATORY FEES PROMPTS FCC LICENSE REVOCATION PROCEEDING In what serves as a reminder to all broadcasters about the importance of paying annual regulatory fees, the Commission recently initiated a license revocation proceeding against a station that has repeatedly failed to pay such fees. In an Order to Pay or Show Cause, the Commission explains that the licensee of a radio station in Massachusetts has not paid its regulatory fees for each fiscal year from 2014 to the present, resulting in an outstanding balance of approximately $9,500. Yes, an outstanding debt to the FCC of less than ten thousand dollars can result in a station being subjected to the "death penalty.” To learn more, please open the attached file. * * * COMMISSION'S REJECTION OF "GOOD FAITH” RETRANS CONSENT COMPLAINT OFFERS HELPFUL GUIDANCE FOR BROADCASTERS Last month, the Commission released an Opinion and Order in which it rejected an Alaskan broadcaster's "good faith” retransmission consent negotiation complaint brought against a multichannel video programming distributor. The Order offers insight into the Commission's interpretation of the good faith standard, which may be useful to broadcasters engaging in retrans negotiations. To learn more, please open the attached file.
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Radio Station Music Licensing Deadlines; Changes to Ancillary/Supplementary Services Reporting; Elimination of EEO Mid-Term Report?
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MUSIC LICENSING ALERT: ACTION REQUIRED BY MARCH 31, 2018, FOR COMMERCIAL RADIO STATIONS SEEKING EXTENSION OF GMR INTERIM LICENSE Commercial radio stations wishing to extend their interim license with performing rights organization GMR (Global Music Rights) must take action by March 31, 2018. To learn more, please open the attached file. * * * SECOND MUSIC LICENSING ALERT: MARCH 31, 2018, DEADLINE TO "OPT IN” TO RMLC REPRESENTATION IN SESAC NEGOTIATIONS Commercial radio stations should also be mindful of a second March 31, 2018, deadline having to do with music licensing. Stations have until March 31, 2018, to "opt in” to representation by the RMLC (Radio Music License Committee) in negotiations with SESAC for the license period that runs from January 1, 2019, through December 31, 2022. To learn more, please open the attached file. * * * FCC APPEARS POISED TO ELIMINATE ANCILLARY/SUPPLEMENTARY SERVICES REPORTING REQUIREMENT FOR MOST STATIONS At its April meeting, the FCC is expected to adopt a Report and Order that will spare thousands of digital television broadcast licensees and permittees the time and resources associated with filing the annual "ancillary” or "supplementary” services report (formerly known as Form 317 and currently known as Form 2100, Schedule G). To learn more, please open the attached file. * * * FCC'S BROADCAST MID-TERM EEO REPORTING REQUIREMENT MAY BE ELIMINATED, TOO Another FCC reporting requirement may also be on its way out. Comments are due May 21, 2018, on the Commission's Noticed of Proposed Rulemaking that would eliminate FCC Form 397, the Broadcast Mid-Term Report. To learn more, please open the attached file.
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Reminder -- Rescheduled Nationwide EAS Test Set for October 3
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This is a reminder to broadcasters that the live, nationwide test of the Emergency Alert System ("EAS”) is scheduled to take place in two days—on Wednesday, October 3, 2018. In addition, the Form Two EAS Report is due the same day, on October 3. The test is scheduled to occur at 2:20 p.m. Eastern Time. 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. To learn more, please open the attached file.
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Sensitive but Important Legal Material: How to Handle the Receipt of Certain Illegal Content
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GUIDANCE FOR STATIONS REGARDING RECEIPT OF ILLEGAL PORNOGRAPHIC CONTENT You may already be aware that over the past several days, there were a number of broadcast stations that received illegal child-related files via social media. This memorandum provides some guidance as to what not to do and what to do if your stations find itself in this situation. Please open the attached file to learn more.
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Two April 10th Deadlines! Delay in Video Description Compliance Date? And... another FCC Rule Eliminated.
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DEADLINE EXTENDED FOR SPECIAL DISPLACEMENT WINDOW FILINGS FOR CERTAIN LOW POWER TELEVISION STATIONS AND TV TRANSLATORS The FCC recently announced that the deadline for filing displacement applications for certain low power television and TV translator stations in the Special Displacement Window has been extended to Friday, June 1, 2018, at 11:59 pm Eastern Time. The Window was previously scheduled to close on Tuesday, May 15, 2018. To learn more, please open the attached file. * * * FCC FREEZES C-BAND RECEIVE-ONLY EARTH STATION DISH REGISTRATIONS BUT OPENS 90-DAY WINDOW FOR REGISTERING "EXISTING” C-BAND DISHES; NAB URGES STATIONS TO MAKE REGISTRATION FILINGS BY JULY 18, 2018, DEADLINE On April 19, 2018, the FCC issued a Public Notice announcing a temporary freeze on C band receive-only earth station registrations. The FCC's freeze also applies to fixed microwave licenses for operations in the in the 3.7 - 4.2 GHz band. To learn more, please open the attached file. * * * EAS DEVELOPMENTS: FCC ESTABLISHES NEW "ALERT REPORTING SYSTEM” AND RELEASES RESULTS OF THIRD NATIONWIDE EAS TEST In an effort to increase the effectiveness and efficiency of the EAS, last week the FCC released a Report and Order that establishes a new EAS platform called the Alert Reporting System. Also last week, the FCC released a Report on the results of the Nationwide EAS Test that took place on September 27, 2017. The test was the third of its kind, and while EAS participants—including radio and television stations—showed improvement in several areas, the test results also reveal that more work needs to be done.
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Two-Week Countdown for Radio Online Public Files
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March 1 Is the Deadline for ALL Radio Stations to Convert to the FCC's Online Public File Environment Radio stations are running out of time to convert their paper public inspection files to the FCC's OPIF system. Association members can review the Radio OPIF webcast from December 6 at this link: http://oab.org/Nuts-and-Bolts-of-the-FCCs-OPIF.mp4, and the Association distributed a radio online public file guide in December—please let us know if you need a copy. There are no exceptions to the requirement for radio stations to convert their public files to the online environment. Please open the attached file for more information.
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VAB August 24 2018 Legal Memorandum ETRS Form One Deadline
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DOWN TO THE WIRE! NATIONWIDE EAS TEST FORM ONE DUE AUGUST 27, 2018 Reminder: All broadcasters have just a few more days—until August 27, 2018—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 September 20, 2018, at 2:20 p.m. ET. To learn more, please open the attached file.
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VAB August 27 2018 Legal Memorandum ETRS Form One Deadline Today
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LAST CALL! NATIONWIDE EAS TEST FORM ONE DUE TODAY, AUGUST 27, 2018 Reminder: All broadcasters must file Form One by today, August 27, 2018. Form One is the first of three reports that must be completed in connection with the next nationwide EAS test, which is scheduled for September 20, 2018, at 2:20 p.m. ET. To learn more, please open the
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VAB August 30 2018 Legal Memorandum Reg Fees
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FCC SETS FISCAL YEAR 2018 REGULATORY FEES AND FILING DEADLINE; REGULATORY FEES DUE BY SEPTEMBER 25, 2018 In its recently released Fiscal Year 2018 Regulatory Fees Report and Order, the FCC sets forth the fees it will impose in order to collect $322,035,000 from all regulatees, which represents a 9 percent decrease in regulatory fees from fiscal year 2017. According to a Public Notice released today, the deadline to file regulatory fees is 11:59 p.m. Eastern Time on September 25, 2018. To learn more, please open the attached file.
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VAB August 6 2018 Legal Memorandum -- Countdown -- EAS Form One -- Earth Station Registration
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THREE-WEEK COUNTDOWN: NATIONWIDE EAS TEST FORM ONE DUE AUGUST 27, 2018 All broadcasters have three more weeks—until August 27, 2018—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 September 20, 2018, at 2:20 p.m. ET. To learn more, please open the attached file. * * * UNDER 75-DAY COUNTDOWN: DEADLINE TO REGISTER EXISTING C-BAND DOWNLINK EARTH STATIONS IS OCTOBER 17, 2018 Here's another crucial reminder: broadcasters have until October 17, 2018 to register their existing (constructed and operational as of April 19, 2018) C-band receive-only earth stations. To learn more, please open the attached file.
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VAB Legal Memorandum September 13 2018 -- DEADLINES -- EAS Test Forms Reg Fees Etc
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ONE-WEEK COUNTDOWN TO SEPTEMBER 20: NATIONWIDE EAS TEST DATE AND DEADLINE TO FILE FORM TWO; FORM ONE REVISIONS DUE SEPTEMBER 26 With all eyes on the real emergency that is Hurricane Florence, we write to remind you that the FCC and FEMA have scheduled a live, nationwide test of the Emergency Alert System ("EAS”) to take place in one week—on Thursday, September 20, 2018. The Form Two EAS Report is due the same day, on September 20. Remember that all broadcast stations are required to participate in the EAS. To learn more, please open the attached file. * * * SEPTEMBER 25: DEADLINE TO PAY REGULATORY FEES Another reminder: the deadline for paying regulatory fees is 11:59 p.m. Eastern Time on Tuesday, September 25, 2018. Timeliness is critical; late filing of regulatory fees—even by one minute—automatically results in a 25% late payment penalty (on top of the regulatory fees owed). To learn more, please open the attached file. * * * OCTOBER 17: DEADLINE TO REGISTER EXISTING C-BAND DOWNLINK EARTH STATIONS And yet another crucial reminder: broadcasters have until October 17, 2018, to register their existing C-band receive-only earth stations. To learn more, please open the attached file.
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VAB Legal Memorandum: LPTV Freeze Lifted -- Copyright Royalty Claims -- Comment Deadlines
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FCC LIFTS FREEZE ON LPTV AND TV TRANSLATOR MINOR MODIFICATION APPLICATIONS The FCC has announced that it has lifted its "freeze” on the filing of minor change applications for all low power television and TV translator stations. To learn more, please open the attached file. * * * TV STATION COPYRIGHT ROYALTY CLAIMS DUE JULY 31, 2018 It's again that time of year for television stations to file distant signal copyright royalty claims. Claims for 2017 must be filed no later than 11:59 p.m. EST on July 31, 2018. To learn more, please open the attached file. * * * FCC EXTENDS COMMENT DATES ON ITS PROPOSAL TO STREAMLINE THE FM TRANSLATOR INTERFERENCE COMPLAINT PROCESS The FCC is giving stations and other interested parties an extra month to comment on its Notice of Proposed Rulemaking that proposes to "streamline” and "expedite” the FM translator complaint resolution process. Comments on the Notice are now due August 6, and Reply Comments are due September 5, 2018. To learn more, please open the attached file. * * * COMMENT DATES SET FOR FCC'S PROPOSAL TO ELIMINATE BROADCAST LICENSE POSTING REQUIREMENTS Stations have until next month to ask for the FCC's help in freeing-up wall space. That's because the comment and reply comment dates have now been set—August 1 and August 16, 2018, respectively—for the FCC's Notice of Proposed Rulemaking relating to station license posting requirements. To learn more, please open the attached file.
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VAB September 10 2018 Legal Memorandum -- Hurricane Florence Prep - DIRS Exercise Cancelled
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PREPARING FOR HURRICANE FLORENCE? "FIRST INFORMER” STATUS AND OTHER FEDERAL BENEFITS AVAILABLE TO BROADCASTERS; TV STATIONS REMINDED TO COMPLY WITH ACCESSIBILITY RULES As TV and radio stations along the East Coast continue to watch Hurricane Florence's path and provide their viewers crucial information about the approaching storm, it's time to remind (A) all stations of certain federal "benefits” available to broadcasters during times of weather disasters, and (B) TV stations of their accessibility obligations when providing "emergency information” to viewers. To learn more, please open the attached file. * * * FCC CANCELS "DIRS” EXERCISE AHEAD OF HURRICANE FLORENCE With Hurricane Florence bearing down, the FCC has elected to cancel its voluntary DIRS 2018 exercise that had been scheduled for September 13 - 14, 2018 (it had originally been scheduled for August 23 - 24 but was rescheduled as a result of Hurricane Lane). "DIRS” is the abbreviation for the FCC's "Disaster Information Reporting System.” The FCC is planning to have a DIRS exercise after the hurricane season ends, and we will provide more information about that exercise as it becomes available.
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VAB September 12 2018 Legal Memorandum FCC Reminders re Hurricane Florence
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BRACING FOR HURRICANE FLORENCE - FCC REMINDS BROADCASTERS ABOUT REQUESTING STAS, PROVIDES EMERGENCY CONTACT INFO, AND MORE As Hurricane Florence barrels toward the East Coast, the FCC is providing broadcasters with information they may need to initiate, resume, and maintain operations in the areas affected by the storm. In Public Notices released on September 11, 2018, the Commission (1) detailed how stations affected by Hurricane Florence can make emergency requests for STA (special temporary authority) and (2) provided the FCC's 24-hour emergency contact information. On its website dedicated to Hurricane Florence, the Commission also reminded television broadcasters about their obligations to make emergency information accessible to viewers who are deaf, hard of hearing, blind, or visually impaired. To learn more, please open the attached file.
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VAB September 7 2018 Legal Memorandum DIRS Exercise Sept 13-14
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REMINDER: FCC'S VOLUNTARY "DIRS” 2018 EXERCISE RESCHEDULED FOR SEPTEMBER 13-14 This is a reminder that the FCC has rescheduled its voluntary DIRS 2018 exercise for next week—on September 13-14, 2018. "DIRS” is the abbreviation for the FCC's "Disaster Information Reporting System.” While participation in both DIRS and the September 13-14 exercise is strictly voluntary, we (and the Commission) recommend that stations strongly consider electing to participate in both. To learn more, please open the attached file.
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