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Too Early to Prep for FCC License Renewals?  Not in the Era of the Online Station Public Inspection

2021 and 2022 may seem like a long way off, but on April 1 of those years, respectively, Texas Radio and TV stations will begin their license renewal cycles. The next wave of FCC station license renewals in other U.S. states begins in 2019. As such, Texas stations will get some advance idea of what to expect from the FCC in this latest round of renewals.

Of keen interest will be how the FCC uses the online station Public Inspection File in its license renewal application reviews. In the last round of renewals earlier this decade, a significant number of FCC fines were levied as a result of stations’ self-admittance of report filing tardiness when answering the license renewal application questionnaire.

With the advent of the online station Public Inspection File, the FCC will no longer need to rely on the candor of stations in reporting late or missing filings of specific public file reports.  FCC regulators will already know as they can search a station’s online Public Inspection File now.

“Because the public inspection file is now easier to access by any regulator working in Washington, stations need to ensure their public inspection file is complete,” Scott Flick, an attorney with TAB’s FCC legal counsel Pillsbury Winthrop Shaw Pittman, said in a recent interview with Inside Radio.

Pillsbury’s station Public Inspection File advisory is a helpful tool to use when reviewing the file for compliance.  In a Public Inspection File webinar TAB presented in late 2017, Flick noted the FCC is expected to be harsher with violation fines in an era of broadcast deregulation.

View Webinar

Attorney David Oxenford with TAB Associate member law firm Wilkinson Barker Knauer is advising stations in these early license renewal states to start reviewing the station online Public Inspection File to make sure all required information is there.  “Particularly important are the collection of Quarterly Issues Programs reports that date back to the grant of your last renewal,” Oxenford said.  “These lists demonstrate how your station has served the public interest, addressing the needs and issues facing its community.”

Indeed, TAB’s Alternative Broadcast Inspection Program inspectors cite the lack of Quarterly Issues Programs reports as one of the most frequently discovered station deficiencies unearthed in TAB ABIP inspections.  Oxenford said stations should also review their technical operations in preparation for renewals, to make sure that the station is ready when the time comes.

“Assuring yourself that the station has all the licenses it needs for its technical operations, and that there are no problems with matters such as RF radiation at their tower site, are issues that should not be left for the last minute,” Oxenford said.

The FCC’s station self-inspection checklists provide some direction as to what needs to be in the station Public Inspection File, as well as certain FCC technical requirements for station operations.  Some of the checklists are nearly 10 years old, but TAB is told that the checklists are in the process of being revised by the FCC. We’ll alert you when the new checklists are available.

View Checklists

As noted above, another tool at stations’ disposal to review station operations for compliance is the TAB Alternative Broadcast Inspection Program, or ABIP.  TAB inspectors review the station Public Inspection File as part of the review, but also review a station’s physical plant, transmitter site and other types of FCC recordkeeping to ascertain compliance with the FCC’s rules.  It’s a low-cost way to ensure stations’ peace of mind.

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

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