Forgot to File Your Renewal Application?

Posted on April 30th, 2020 by

We don’t mean to cause you panic with that headline, but we recently saw something that seemed worthy of passing along.  Figuring out the deadlines for a station’s various renewal requirements, including the application filing deadline, can be confusing.  But if a station finds itself in a situation where it missed the renewal application filing deadline, all is not lost.

Obviously, step one will be to prepare and get the application on file as soon as possible. Depending on how late you are, your FCC attorney might advise that a request for special temporary authority be filed to allow the station to continue operations.  But it potentially won’t come to that because at some point, the FCC is most likely going to send an email to any email address it has from prior station filings and alert (hopefully you) to the fact that an application was not timely filed.  This email will typically be sent just after the missed renewal application filing deadline.  It will give you the option of not renewing, or of filing the renewal application late.

In an email like this that we were recently privy to for a station that should have filed a renewal application by April 1, 2020, the FCC noted that if the station wants to renewal its license “without adverse action” it should file the application by May 1, 2020.  We thought that to be a kind and generous gesture (i.e., file 30 days late and not be fined).  But it was followed with a warning that if the application was filed after May 1, 2020, a fine would be issued.  And on the off chance that a renewal application was not filed by August 1, 2020, the notice made clear that the license would be cancelled.

But don’t wait on second chances.  Double check dates and facilities.  Don’t forget those translators, whether they’re located in the same state as the primary and will be renewed with the primary, or whether they’re located in a state with different renewal deadlines, and need to file a renewal application on their own.