TV License Renewal Insight

Every broadcast license renewal cycle, there are always a few twists or tweaks in the FCC’s renewal application processing that are different from the prior cycle. But generally speaking, processing of license renewal applications always took about four months, consistent with the requirement that license renewal applications be filed four months prior to the station license expiration date.

But that processing norm seems to have taken a detour, of sorts, for TV station renewals. Unlike radio station license renewals, which are being handled by the Media Bureau’s Audio Division, and are typically being granted this cycle within the four-month period and just prior to the station license expiration date, TV station license renewals, handled by the Video Division, are taking longer. We believe there are a number of factors in play that make processing TV renewal applications a longer process. But we’re still a little perplexed as to why four months isn’t enough. Staff working remotely due to COVID is certainly one factor, as we learned last fall when asking for a status update on a LPTV station license renewal that remained pending past its expiration date.

In another recent case we are aware of, the Video Division staff requested a minor remedial action on a TV renewal application that was still pending almost eight weeks after the license expiration deadline. It was the first contact by the staff on the application, which had been filed nearly six months earlier. The requested remedial action was for the addition of a signature on a single quarterly children’s television commercial limits certification, which had inadvertently been uploaded unsigned years before. In context, it seems a bit trivial to us that a single unsigned certification may have delayed processing for such an extended period of time.

The take-away from that case for TV stations is that the Video Division staff is likely behind in reviewing TV renewal applications, but also that in doing so, it is very carefully reviewing children’s television issues. TV stations that have not yet filed for license renewal should be scrutinizing their compliance on children’s television issues – both commercial limits and core programming – to be sure everything is accurate and fully compliant. If not, and a “no” certification is necessary, an explanation will be necessary.

We also suspect that the transition to annual reporting for children’s television core programming and commercial limits may have caused the staff to delay processing some applications until annual filings were complete and could be reviewed for compliance.