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Public File Scrutiny Key FCC Focus as License Renewal Cycle Begins

- Texas Radio Up for Renewal in 2021, TV in 2022

In less than a year, Texas Radio stations will enter their FCC license renewal period; Texas TV stations will follow in 2022. With the online public file a key starting point for the process, it’s never too early for any station to ensure it’s doing everything necessary to avoid a potential fine, or worse.

All stations, except LPFM and FM Translator stations, also must file a Broadcast Equal Employment Opportunity Program Report (FCC Schedule 396) at the same time.

Texas radio stations must file their renewals online with the FCC by April 1, 2021. Pre-filing renewal announcements must be made on Feb. 1, 2021 and again Feb. 16, March 1 and March 16 of next year.

Texas’ upcoming renewal cycle makes a recent FCC public notice on TV license renewals in a few East Coast states and a general radio station license renewal public notice all the more noteworthy.

VIew TV license renewals
View Radio license renewals

Apart from reminders on how and where the renewals must be filed, the FCC put stations on notice that “failure to comply with the public inspection file requirements, including the political file requirements, prior to the deadline for filing a station’s renewal application may result in forfeitures and may impact a station’s renewal application.” 

The FCC recommended stations “review the contents of their file prior to filing their license renewal application.”

Attorney David Oxenford with TAB Associate member law firm Wilkinson Barker Knauer said the FCC’s “encouragement” sends a clear message – stations need to review their online public files now, prior to filing their renewal application. 

What kind of Public Inspection File deficiencies should Texas radio stations be especially vigilant in identifying and correcting? Perhaps the biggest is station programs/issues lists.

Oxenford has written about fines issued in 2019 to radio stations here and here for deficiencies in this component of a station’s Public Inspection File. Reviewing these two articles are instructive.

Stations also should give the political file component of the online Public Inspection File special consideration. The FCC issued an Order in late April that reconsidered certain political file issues addressed in 2019 orders.

Stations looking for a summary and explanation can read Oxenford’s article here about this latest FCC ruling about the political file obligations for all broadcast stations.

View article

Questions? Contact TAB’s Michael Schneider or call (512) 322-9944.

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