(Really Important) License Renewal Tidbits

The FCC is trying really hard to avoid having to fine radio stations for failing to follow the new requirement to maintain an online public file and regularly place required items in the file.  One might say they are bending over backwards to get stations to come into compliance with the rules by the time they file their license renewal application.

Through an error by an outside contractor hired by the FCC to create an algorithm that checks online public file folders, several of our clients received emails claiming that items were missing from online public files. We knew that to be inaccurate and brought it to the FCC’s attention, and apology/retraction emails followed.  But our conversations with staffers indicated that the FCC was doing everything it could to get stations to comply by the time they file their license renewal applications.  If stations are not compliant by the time they file for license renewal, the proverbial hammer will drop and fines are likely.  Don’t take our word for it – here is the message the FCC sends to recalcitrant stations:

Our records indicate that the station _____ has not uploaded all required public inspection file material to the FCC’s online public file system.  It was required to do so by March 1, 2018.  Our records indicate that the station has not uploaded the required Issues/Programs Lists and may be missing other information as well.  Please act immediately to correct this problem and upload the required material.  Failure to comply with the online public inspection requirements by the time the station’s license renewal application must be filed will subject the station to a monetary penalty.  If you have any questions about what should be uploaded or how to upload material, please call 1-877-480-3201 or check the Commission’s public file web page at publicfiles.fcc.gov.

That’s a nice and clear warning.  Do you see how nice the Audio Division is trying to be?

We applaud the FCC for its “judicious” approach to public file compliance for radio stations, but we note two things.  First, the FCC’s approach is likely a one-time extension of mercy, so stations are urged to take every action necessary to follow the online public file posting requirements on time, every time, especially if your station has been late in transitioning or posting.  Second, we do not assess that TV stations will receive similar treatment when TV license renewals start this June.  TV stations transitioned to the online public file during the last renewal cycle, and therefore have had sufficient time to get the hang of posting to the online public file.