TAB’s FCC Legal Counsel Offer Tips on Filing FCC Radio License Renewal
posted on 2.09.2021Attorneys Scott Flick and Lauren Lynch Flick of Pillsbury Winthrop Shaw Pittman, TAB’s FCC legal counsel, briefed TAB member radio stations on Tuesday as to what will be required to renew radio stations’ licenses this year. Renewal forms must be filed with the FCC by April 1.
The attorneys reviewed the FCC’s license renewal Form 303-S, the FCC’s Broadcast Equal Employment Opportunity Program Report Form 396, and the steps broadcasters must undertake to ensure compliance with the FCC’s rules.
Two key differences from stations’ last renewals are the elimination of pre-filing broadcast public notices and the implementation of stations’ Online Public Inspection Files (OPIF).
The FCC still requires post-filing broadcast public notices.
Stations should always be mindful of maintain the station OPIF as it will see severe scrutiny during the license renewal process.
Case in point, the FCC issued several 2020 consent decrees related to the maintenance of the Political File component of the station OPIF.
These arose from certifications made in stations’ license renewal applications.
Other OPIF areas of potential concern noted by the Flicks are the station Quarterly Issues Programs reports and EEO reports including EEO outreach documentation.
The Flicks warned that station technical operations are subject to renewal scrutiny as well.
Additionally, Texas radio stations should take care to file the FCC’s Broadcast Equal Employment Opportunity Program Report (FCC Form 396), before the license renewal application.
There are questions related to it on the license renewal application.
Radio stations, and those TV stations seeking to get a glimpse of their 2022 license renewal process, can still see the full presentation by the Flicks.
Note: session recording and slides are now archived and available to view:
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Questions? Contact TAB’s Michael Schneider or call (512) 322-9944.
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