Pre-Filing and Post-Filing License Renewal Announcement Reminder for Radio Stations in Arkansas, Louisiana, and Mississippi

Full power commercial and noncommercial radio stations and LPFM stations licensed to communities in Arkansas, Louisiana, and Mississippi must begin airing pre-filing license renewal announcements on December 1, 2019. 

Full power commercial and noncommercial radio stations and LPFM stations licensed to communities in Arkansas, Louisiana, and Mississippi must begin airing pre-filing license renewal announcements on December 1, 2019.  License renewal applications for these stations, and for in-state FM translator stations, are due by February 1, 2020.  Note that because this filing deadline falls on a weekend, submission of the license renewal application may be made on February 3.  However, the post-filing license renewal announcement for that day (discussed below) must still be made on February 1.

Full power commercial and noncommercial radio and LPFM stations must air four pre-filing announcements alerting the public to the upcoming renewal application filing.  As a result, these radio stations must air the first pre-filing renewal announcement on December 1.  The remaining pre-filing announcements must air once a day on December 16, January 1, and January 16, for a total of four announcements.  At least two of these four announcements must air between 7:00 am and 9:00 am and/or 4:00 pm and 6:00 pm.

The text of the pre-filing announcement is as follows:

On [date of last renewal grant], [call letters] was granted a license by the Federal Communications Commission to serve the public interest as a public trustee until June 1, 2020.  [Stations that have not received a renewal grant since the filing of their previous renewal application should modify the foregoing to read: “(Call letters) is licensed by the Federal Communications Commission to serve the public interest as a public trustee.”]

Our license will expire on June 1, 2020.  We must file an application for renewal with the FCC by February 1, 2020.  When filed, a copy of this application will be available for public inspection at www.fcc.gov.  It contains information concerning this station’s performance during the last eight years [or other period of time covered by the application, if the station’s license term was not a standard eight-year license term].  Individuals who wish to advise the FCC of facts relating to our renewal application and to whether this station has operated in the public interest should file comments and petitions with the FCC by May 1, 2020.

Further information concerning the FCC’s broadcast license renewal process is available at [address of location of the station][1] or may be obtained from the FCC, Washington, DC 20554, www.fcc.gov.

If a station misses airing an announcement, it should broadcast a make-up announcement as soon as possible and contact counsel to further address the situation.  Special rules apply to noncommercial educational stations that do not normally operate during any month when their announcements would otherwise be due to air, as well as to other silent stations.  These stations should also contact counsel regarding how to give the required public notice.

Post-Filing License Renewal Announcements

Once the license renewal application has been filed, full power commercial and noncommercial radio and LPFM stations must broadcast six post-filing renewal announcements.  These announcements must air, once per day, on February 1 and February 16, 2020, as well as March 1, March 16, April 1, and April 16, 2020.  At least three of these announcements must air between 7:00 am and 9:00 am and/or 4:00 pm and 6:00 pm.  At least one announcement must air in each of the following time periods: between 9:00 am and noon, between noon and 4:00 pm, and between 7:00 pm and midnight.

The text of the post-filing announcement is as follows:

On [date of last renewal grant], [call letters] was granted a license by the Federal Communications Commission to serve the public interest as a public trustee until June 1, 2020.

Our license will expire on June 1, 2020.  We have filed an application for renewal with the FCC.

A copy of this application is available for public inspection at www.fcc.gov.  It contains information concerning this station’s performance during the last eight years [or such other period of time covered by the application, if the station’s license term was other than a standard eight-year term].

Individuals who wish to advise the FCC of facts relating to our renewal application and to whether this station has operated in the public interest should file comments and petitions with the FCC by May 1, 2020.

Further information concerning the FCC’s broadcast license renewal process is available at [address of location of the station] or may be obtained from the FCC, Washington, DC 20554, www.fcc.gov.

Public Inspection File Certification of Compliance

Within seven days of the broadcast of the last post-filing announcement (i.e. by April 23, 2020), license renewal applicants should complete the attached Statement of Compliance and place it in the station’s Public Inspection File.

Newspaper Public Notice Requirement for FM Translator Stations

While FM translator stations must file their license renewal applications at the same time as full power stations licensed to communities in the same state, they are not required to broadcast pre-filing or post-filing announcements.  Instead, upon filing a license renewal application for an FM translator, the licensee must publish a public notice of the filing at least once in a daily, weekly or biweekly newspaper published or having circulation in the community served by the translator.  If there is no such newspaper, the licensee must determine an appropriate means of providing the required notice to the general public, such as posting it in the local post office or other public place.

The FCC has indicated that broadcasters who are eligible to file for license renewal of both a translator station and the full power station that it rebroadcasts in a single application can forgo running the newspaper public notice of the translator’s renewal filing.

Otherwise, the notice must contain the name of the applicant, the community served by the translator, the translator’s transmitter site, the station’s output channel and power, a statement that the station engages in rebroadcasting of another station, including the call letters, location and channel of operation of the station(s) rebroadcast, the date the application was filed and a statement advising that the application is for renewal of license and inviting comment from individuals who wish to advise the FCC of facts relating to the renewal application and to whether the station has operated in the public interest.  After publishing the notice, the FM translator licensee should complete and execute a Statement of Compliance regarding that publication.  While FM translator licensees are not required to keep a Public Inspection File, they are required to maintain a station records file available to FCC representatives that contains their current authorization and copies of all FCC filings and correspondence with the Commission.  The completed Statement of Compliance should be included in the station records file.

[1] While the FCC has not updated its rule requiring the use of this text, the information on license renewal it refers to is located in the Public Inspection File, which is now online, and no longer located at the station.

The full article, along with examples of compliance statements, can be found at Pre-Filing and Post-Filing License Renewal Announcement Reminder.