Articles Posted in FCC Enforcement

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Pillsbury’s communications lawyers have published FCC Enforcement Monitor monthly since 1999 to inform our clients of notable FCC enforcement actions against FCC license holders and others. This month’s issue includes:

  • FCC Proposes $34,000 Fine for Interrupting Emergency Communications During Wildfire
  • Late Programs/Issues Lists and Failure to Disclose Violation Causes $15,000 Proposed Fine for North Dakota Noncommercial Licensee
  • License Rescinded for Mississippi Station Not Built as Authorized

Amateur Ham Radio Operator Receives $34,000 Proposed Fine for Transmitting on Radio Frequency Used by Fire Suppression Aircraft

The FCC issued a Notice of Apparent Liability for Forfeiture (NAL) to an amateur radio operator for interfering with the U.S. Forest Service while it and the Idaho Department of Lands were directing aircraft fighting a 1,000-acre wildfire outside of Elk River in northern Idaho. The FCC found that the individual violated Sections 301 and 333 of the Communications Act (the “Act”), and Sections 1.903(a) and 97.101(d) of the Commission’s Rules by operating on government frequencies without a license and causing intentional harmful interference to licensed radio operations.

On July 22, 2021, the FCC received a complaint from the U.S. Forest Service about an individual who had been transmitting on government frequencies, noting that the transmissions had caused interference to fire suppression aircraft operations. The complaint explained that on July 17th and 18th, firefighters working on the “Johnson Fire,” a 1,000-acre wildfire on national forest lands in northern Idaho, received several communications from an individual calling himself “comm tech.” He advised firefighters and aircraft of hazards at a radio repeater sight in Elk Butte and identified his location as the Elk River airstrip. On July 18th, the fire operations section chief drove to the airstrip and found an individual who admitted to transmitting on government frequencies as “comm tech.”

On July 22, 2021, a U.S. Forest Service Law Enforcement and Investigations Branch agent interviewed the individual about the incident. The individual admitted to operating on the government frequency and that he was not authorized to do so. On October 15, 2021, the FCC sent a Letter of Inquiry (LOI) to the individual. In the individual’s response, he again admitted to operating on the government frequency but argued that he was not trying to cause interference and instead was trying to provide information to the firefighters. He suggested a third party may have also been transmitting, and may have continued to do so after he spoke to the fire chief and ceased his own operations.

Section 333 of the Act states that “[n]o person shall willfully or maliciously interfere with or cause interference to any radio communications of any station licensed or authorized by or under the Act or operated by the United States government.” The legislative history of Section 333 describes willful and malicious interference as “intentional jamming, deliberate transmission on top of the transmissions of authorized users already using specific frequencies in order to obstruct their communications, repeated interruptions, and the use and transmission of whistles, tapes, records, or other types of noisemaking devices to interfere with the communications or radio signals of other stations.” Section 97.101(d) of the Commission’s Rules states that “[n]o amateur operator shall willfully or maliciously interfere with or cause interference to any radio communications or signal.” The FCC found that the individual violated Sections 333 of the Act and 97.101(d) of the Rules when he caused harmful interference by making repeated interruptions to the Forest Service’s communications. The unauthorized transmissions impeded legitimate communications and resulted in personnel being diverted away from the fire and to his location at the airstrip.

Section 301 of the Act states that “[n]o person shall use or operate any apparatus for the transmission of energy or communications or signals by radio . . . without a license granted by the Commission.” Section 1.903(a) of the FCC’s Rules requires that wireless licensees operate in accordance with the rules applicable to their particular service, and only with a valid Commission authorization. The FCC found that the individual violated those sections when he made eight separate radio transmissions on the government’s frequency, as he did not have a license to operate on that frequency. According to the FCC, his statements to the U.S. Forest Service and his written response confirmed his actions.

Section 1.80 of the FCC’s Rules establishes a base fine of $10,000 for operating without a license, and $7,000 for causing interference to authorized stations for each violation or each day of a continuing violation. Here, the Commission proposed a total fine of $34,000 – a $10,000 fine for each of the two days of unlicensed operations, and $7,000 for each of the two days of harmful interference. The FCC concluded that there were no mitigating factors supporting any downward adjustment of the proposed fines, and issued the NAL for the full $34,000.

FCC Proposes $9,000 and $6,000 Fines for Minnesota and North Dakota Television Stations’ Late-Filed Programs/Issues Lists

The FCC issued proposed fines of $9,000 and $6,000 in response to allegations that two noncommercial television stations owned by a North Dakota licensee failed to timely upload all of their Quarterly Programs/Issues Lists to the stations’ Public Inspection Files. An FCC staff review of the stations’ Public Inspection Files as part of the license renewal process revealed that during the license term, both stations uploaded numerous Quarterly Programs/Issues Lists late and failed to properly disclose these violations in the stations’ license renewal applications.

Section 73.3527(e)(8) of the FCC’s Rules requires every noncommercial broadcast station to place in its Public Inspection File “a list of programs that have provided the station’s most significant treatment of community issues during the preceding three month period.” The list must include a brief narrative of the issues addressed, as well as the date, time, duration, and title of each program addressing those issues. The list must be placed in the Public Inspection File within 10 days of the end of each calendar quarter. Continue reading →

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Pillsbury’s communications lawyers have published FCC Enforcement Monitor monthly since 1999 to inform our clients of notable FCC enforcement actions against FCC license holders and others. This month’s issue includes:

  • FCC Shifts Battle Against Pirates to Landowners of Pirate Radio Sites
  • Nevada Company Faces $100,000 Fine for Engaging in Prohibited Communications During FCC Auction
  • FCC Proceeds With $17,500 Fine Against Arkansas Broadcaster for Violations Discovered During License Renewal Review

FCC’s Pirate Radio Enforcement Targets Landowners

The Enforcement Bureau recently issued Notices of Illegal Pirate Radio Broadcasting to four property owners in Pennsylvania, Maryland, and Oregon after investigations of unauthorized radio broadcasts found radio signals emanating from their properties. The Communications Act prohibits the transmission of radio signals without prior FCC authorization, as they can, among other things, pose risks to public safety by interfering with licensed operations such as air traffic control.

The FCC has stepped up its efforts to combat illegal broadcast operations, colloquially known as “pirate radio,” in the wake of Congress’s passage of the PIRATE Act in early 2020. Under Section 511 of the PIRATE Act and Section 1.80 of the FCC’s Rules, the Commission may now impose fines of up to $2 million against individuals or entities that knowingly permit pirate radio operations on their property. Additionally, the PIRATE Act permits the FCC, without first having to issue a Notice of Unlicensed Operation, to propose a penalty against any person that “willfully and knowingly does or causes or suffers to be done any pirate radio broadcasting.” The FCC will issue a Notice of Illegal Pirate Radio Broadcasting where it has reason to believe a property owner or manager is permitting illegal broadcasts from its premises. This Notice provides the landowner a chance to remedy the situation before enforcement action is taken.

In response to complaints of illegal FM broadcast operations at four locations in Pennsylvania, Maryland, and Oregon, the Enforcement Bureau issued Notices of Illegal Pirate Radio Broadcasting to the respective landowners. The Notices indicated that FCC investigators had confirmed radio signals were emanating from those properties without an FCC license authorizing such transmissions. The landowners were also warned that they face a fine of up to $2 million if the FCC determines they continued to permit illegal broadcasts from their property.

While the FCC’s rules create exceptions from licensing requirements for certain extremely low-powered wireless devices, the Commission’s agents determined that the transmissions originating from the properties far exceeded those levels. The property owners have ten business days from the date of their respective Notices to (1) respond with evidence demonstrating that pirate radio broadcasts are no longer occurring on their property, and (2) identify the individual(s) involved in the illegal broadcasts. If the parties fail to respond to the Notice altogether, the FCC may still determine that the parties had sufficient knowledge of the illegal broadcasts to warrant enforcement action, including substantial fines.

FCC Proposes to Fine Wireless Company $100,000 for Violating Rules Against Communicating Bidding Strategies During FCC Auction

The FCC released a Notice of Apparent Liability for Forfeiture (“NAL”) proposing to fine a wireless broadband provider (the “Company”) $100,000 for engaging in prohibited communications of bidding and bidding strategies during the FCC’s Rural Digital Opportunity Fund Phase I Auction (Auction 904) and failing to timely report the prohibited communications.

Section 1.21002(b) of the FCC’s Rules forbids FCC auction applicants from conveying certain information to other auction applicants during the “quiet period.” This “quiet period” begins on the deadline for filing a short-form application to participate in the auction and ends on the deadline for winning bidders to submit long-form applications. The rule applies to any communication by an applicant regarding its own, or any other applicant’s, bids or bidding strategies. Continue reading →

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Pillsbury’s communications lawyers have published FCC Enforcement Monitor monthly since 1999 to inform our clients of notable FCC enforcement actions against FCC license holders and others. This month’s issue includes:

  • Felony Fraud Conviction Results in AM Station License Revocation Hearing
  • Dash Camera Retailer Enters $75,000 Consent Decree for Marketing Unauthorized Devices
  • Broadcaster Agrees to $9,000 Consent Decree for Violations Relating to Silent STA Rule, Translator Rebroadcasting Rule, and the Truthful and Accurate Statements Rule

Up in Smoke: Lying to IRS Leads FCC to Question AM Licensee’s Character Qualifications

The FCC recently issued a Hearing Designation Order and Order to Show Cause to determine whether the license of a Tennessee AM station should be revoked.  The licensee’s sole member, a former representative in the Tennessee legislature, purchased cigarette tax stamps in 2007 and sold them for a substantial profit following the legislature’s increase in the state’s cigarette tax.  He failed to include this profit in his 2008 individual income tax return and was convicted in 2016 of fraud and making false statements to the government.  The licensee reported the conviction to the FCC on April 14, 2017 – two weeks after the deadline set forth in Section 1.65(c) of the FCC’s Rules (which requires licensees to report adverse court and administrative findings bearing on character qualifications by the anniversary of their state’s renewal filing deadline).  The licensee also disclosed the conviction in the station’s March 18, 2020 license renewal application, along with failures to file Ownership Reports and to timely upload quarterly Issues/Programs lists.

Section 312 of the Communications Act of 1934 (the “Act”) permits the FCC to revoke a license if it determines that the licensee lacks the requisite character qualifications to remain a Commission licensee.  Key to the FCC’s character inquiry is the question of whether the licensee “is likely to be forthright in its dealings with the Commission and to operate its station consistent with the requirements of the Communications Act and the Commission’s Rules and policies.”  The FCC has previously explained that any violation of the Act or FCC’s Rules may be relevant to a licensee’s character qualifications.  With respect to non-FCC misconduct, the FCC has found that felonies and adjudicated fraudulent representations to other governmental units are relevant to a licensee’s character qualifications because they are indicative of the licensee’s propensity to obey the law or to engage in similar, non-truthful behavior before the FCC.  The FCC relies heavily on the candor of licensees, and therefore deems full and clear disclosure of all material facts as essential to its processes.

In this case, the individual’s felony conviction resulted from dishonest conduct: omission of material financial information resulting in a consequential inaccuracy in the information provided to the IRS.  The FCC concluded that the individual’s willingness to unlawfully conceal information from another federal agency, together with the licensee’s admitted failures to comply with certain FCC reporting requirements, called into question the licensee’s ability to provide complete and accurate information to the FCC.  Accordingly, the FCC commenced a hearing to determine whether the individual (and, by extension, the licensee) possesses the necessary character qualifications to remain a Commission licensee.

Dash Camera Retailer Settles Equipment Marketing Investigation for $75,000

The FCC entered into a consent decree with a Connecticut-based dash camera retailer, resolving an investigation into whether the company unlawfully marketed unauthorized vehicle dash cameras in the United States.  The investigation found, and the company admitted, that the retailer marketed several unauthorized camera models, failed to test its equipment’s radiofrequency (“RF”) emissions, and failed to retain measurement records in violation of the Act and the FCC’s Rules.

Section 302(b) of the Act prohibits, among other things, the sale or offering for sale of devices that fail to comply with the FCC’s RF equipment authorization regulations.  Similarly, Section 2.803(b) of the Commission’s Rules prohibits, with limited exceptions, the marketing of an RF device unless the device has first been properly authorized, identified, and labeled in accordance with the FCC’s Rules.

As detailed in Pillsbury’s Primer on FCC Radio Frequency Device Equipment Authorization Rules, equipment authorization procedures differ depending on whether the device is an “unintentional radiator” (a device that emits signals to other parts of the device or to an attendant device, such as a universal remote control”) or an “intentional radiator” (a device that intentionally emits RF energy outside of the device).  Section 2.906 of the Rules sets forth the relatively simple Supplier’s Declaration of Conformity (“SDoC”) procedures that apply to unintentional radiators.  Section 2.907 of the FCC’s Rules sets forth the more stringent Certification process required for intentional radiators.  Section 2.938 of the Rules requires that manufacturers or other responsible parties retain test measurement records and other data demonstrating that each RF device has been properly tested and authorized under the appropriate equipment authorization procedures prior to marketing. Continue reading →

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Pillsbury’s communications lawyers have published FCC Enforcement Monitor monthly since 1999 to inform our clients of notable FCC enforcement actions against FCC license holders and others. This month’s issue includes:

  • LPTV Owner Pays $250,000 for Abusing FCC’s Licensing Processes
  • FCC Proposes $32,000 Fine for Radio EEO Violations
  • Florida Radio Station Receives $20,000 Proposed Fine for Contest Rule Violations

Abuse of FCC Licensing Processes Leads to $250,000 Penalty

The FCC entered into a Consent Decree earlier this month with an LPTV broadcaster (the “Company”) that held 80 LPTV licenses and more than 120 unbuilt LPTV construction permits, resolving an investigation into whether the Company abused the Commission’s licensing processes. The FCC was investigating whether the Company had filed a series of minor modification applications to construct and license temporary facilities with the intent of relocating stations substantial distances from their originally authorized sites to evade FCC restrictions on filing major modification applications.

In response to a Media Bureau inquiry concerning the Company’s construction and licensing practices and the operational status of its stations, the Company claimed that each licensed station was constructed in compliance with the parameters set forth in the underlying construction permit. It conceded, however, that it had installed temporary transmission equipment that was later removed, and that the stations were never built to provide permanent television service. The FCC recognized that in some instances, the temporary equipment was installed because pandemic-related supply chain issues made it difficult for the Company to obtain equipment. However, the FCC found that at least 30 stations were constructed with temporary equipment as a way to effectuate a series of repeated, short moves with the ultimate goal of moving the stations a large distance – sometimes over 100 miles from the location listed in the initial construction permit.

Under Section 74.787(b) of the FCC’s Rules, any change in an LPTV’s antenna location greater than 30 miles, or a move where the proposed protected contour does not overlap some portion of the protected contour of the existing station, is considered a major change requiring the permittee/licensee to file a major modification application. Major modification applications in the LPTV service are currently frozen and may only be filed upon the opening of a filing window. The FCC has held that the filing of any facility application implies that the applicant is “ready, willing, and able” to construct and operate the facility as proposed. When determining whether a permittee has engaged in an abuse of process based on serial minor modification applications, the FCC looks at several factors, including (1) the nature of the broadcast facilities (i.e., temporary construction); (2) the duration of operations; (3) the purpose of the relocations; and (4) any pattern of relocations.

The FCC explained that the Company undertook the series of short moves by: (1) filing an application for minor modification to relocate the station within 30 miles of its licensed site; (2) building temporary facilities upon grant of the minor modification application with no intent to provide permanent service at the new location; (3) filing a license to cover the temporary location and then applying for special temporary authority to go silent once the license was granted; and (4) removing the equipment from the site and filing for a new minor modification to move the station up to 30 miles again. The Company would repeat this process until the station was moved from a rural unserved or underserved area with low population density to a densely populated urban or suburban area.

While the FCC accepted that some stations were built with temporary facilities due to difficulty obtaining equipment, it found that at least 30 stations were constructed with temporary facilities and operated only a short time. The FCC believed the Company lacked intent to use those facilities to provide a permanent television program service to viewers, and that their plan was instead to undertake a pattern of relocating the stations as a way of circumventing the major change rule and the freeze on major modification applications.

In agreeing to the Consent Decree, the Company admitted that its actions violated the FCC’s rules and agreed to pay a $250,000 penalty along with implementing a comprehensive compliance program. It also agreed to surrender authorizations for nearly a hundred LPTV stations. Due to delays resulting from the investigation as well as supply chain delays, the FCC agreed to toll the construction permit expiration dates for certain of the Company’s other stations for four months, but required that the Company commence operation of all licensed and silent facilities within one year of going silent.

Radio Stations Receive Proposed Fine of $32,000 for EEO Violations

The FCC proposed a $32,000 fine against the licensee of a number of Georgia radio stations for failing to timely upload an Annual EEO Public File Report to the stations’ Public Inspection Files, failing to timely upload the Report to the stations’ websites and, based on those failures, failing to analyze its EEO program.

Section 73.2080(c)(6) of the FCC’s Rules requires every non-exempt broadcast station to prepare and place an Annual EEO Public File Report in its Public Inspection File and on its website, if it has one. The Annual EEO Public File Report contains information regarding a station employment unit’s full-time vacancies during the preceding year, the recruitment sources used to fill those vacancies, the referral source for each of the resulting hires, the total number of interviewees grouped by referral source, and a description of the station’s recruitment initiatives not connected to specific vacancies. Separately, Section 73.2080(c)(3) of the FCC’s Rules requires a licensee to analyze its EEO recruitment program on an ongoing basis to ensure it is achieving broad outreach to potential applicants.

In a recent license renewal application, the broadcaster disclosed that it had not uploaded its 2018 Annual EEO Public File Report to the stations’ Public Inspection Files by the applicable deadline. The Enforcement Bureau issued a Letter of Inquiry in July 2020 and the broadcaster responded, acknowledging that the report was uploaded over nine months late and citing an “administrative change” and loss of a former employee as the reason. Finding that such circumstances do not excuse or nullify a rule violation, the FCC concluded that the licensee violated Section 73.2080(c)(6) of the FCC’s Rules in two different ways: (1) by failing to timely upload the report to the Public Inspection Files of the stations, and (2) by failing to timely upload it to the stations’ websites. The Commission found that failure to timely upload the report denied the public of the ability to participate in monitoring and providing input on the stations’ EEO programs, thereby preventing the stations from analyzing their recruitment program and thus also violating Section 73.2080(c)(3) of the FCC’s Rules.

Section 503(b)(2)(A) of the Communications Act allows the FCC to assess a fine of up to $55,052 per day of a continuing violation, up to a maximum of $550,531 for a single act. When determining the amount of a fine, the FCC considers the “nature, circumstances, extent, and gravity of the violation” as well as the violator’s history of any prior offenses and its ability to pay. The FCC’s base fine for a Public Inspection File violation is $10,000. Here, the FCC noted the broadcaster’s large number of stations across the country, the large number of people it employs, how routinely it fills job openings, and its prior history of both EEO and non-EEO rule violations. In light of these factors, the FCC proposed a $26,000 fine for the failure to prepare and upload the report.

Because there is not an established base fine for failing to analyze a station’s EEO program, the FCC looked to prior Notices of Apparently Liability (NAL) issued to the broadcaster in 2008 and 2017 for various EEO rule violations. In both NALs, the FCC proposed a $2,000 fine. Considering the prior history of EEO offenses, the FCC felt an upward adjustment was warranted and issued a $6,000 fine for the failure to analyze the stations’ EEO program. In total, the FCC proposed a $32,000 fine. The broadcaster has 30 days from release of the NAL to pay the fine or file a written statement seeking reduction or cancellation of it.

FCC Fines Florida Radio Station for Contest Rule Violations

The FCC proposed a fine of $20,000 against the licensee of a Florida radio station for apparent violations of the Commission’s contest rules. Specifically, the FCC found that the licensee apparently failed to fully disclose material contest terms, to conduct the contest as advertised, and to maintain the contest’s rules on the station’s website for at least 30 days after the end of the contest.

Section 73.1216 of the FCC’s Rules requires a licensee to “fully and accurately disclose the material terms” of a contest it broadcasts or promotes and to conduct the contest “substantially as announced and advertised.”  Material terms may be disclosed by either airing those terms or making them available in writing on a publicly accessible website. If the latter, the contest rules must stay on the website for at least 30 days after the contest ends. Material terms include, among other things, eligibility restrictions and the means of selecting winners. Contest rules that are ambiguous or open to interpretation are susceptible to an FCC finding that the station failed to disclose the material terms.

The Enforcement Bureau received a complaint from a person alleging they had been incorrectly excluded from a contest and that the radio station had violated its contest rules. The complainant had won a different station-run contest on March 1, 2019 and attempted to enter the contest at issue in the complaint on May 30, 2019. A station employee applied a “90-day lockout” on prior winners and excluded the complainant. The written contest rules, however, specified that only persons who had won a contest in the prior 30 days were to be excluded.

In response to an FCC Letter of Inquiry, the station admitted that, as a result of human error, it did not conduct the contest “in strict compliance with the written rules” when its employee applied the incorrect eligibility exclusion to the complainant. The station also admitted that it took the rules off the website the day the contest ended, rather than leaving the rules up for 30 days as required. However, the station contended that the complaint was not material because the contest rules not only excluded persons who had won a prize in the 30 days prior to the January 7, 2019 start of the contest, but also excluded anyone who won a prize while the contest was ongoing.

The FCC disagreed, finding that the station’s application of its contest rules was not supported by the plain language of its rules or its standard screening protocol. The FCC noted that even if the contest rules could be interpreted as the station claimed they should be, FCC precedent makes clear that ambiguous rules are to be “construed against the interests of the promoter of the contest.” Further, the FCC clarified that regardless of the complainant’s eligibility to participate in the contest, the complaint was not “immaterial” because a person does not need to be a qualified contestant to have standing to bring a contest rules complaint at the FCC regarding the manner in which a contest was conducted.

The FCC’s base fine for each “violation of requirements pertaining to broadcasting of lotteries or contests” is $4,000. In this case, the FCC noted that it may adjust the proposed fine upward for “violations that are egregious, intentional, or repeated, or that cause substantial harm or generate substantial economic gain for the violator.” Considering the totality of the circumstances, the FCC determined an upward adjustment was warranted, explaining that the licensee’s owner had a history of contest rule violations, and that the station also failed to maintain the rules on its website for the required 30 days after the end of the contest. As a result, the FCC proposed a total fine of $20,000. The station has 30 days from release of the NAL to pay the fine or file a written statement seeking reduction or cancellation of it.

A PDF version of this article can be found at FCC Enforcement ~ March 2022.

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Pillsbury’s communications lawyers have published FCC Enforcement Monitor monthly since 1999 to inform our clients of notable FCC enforcement actions against FCC license holders and others. This month’s issue includes:

  • FCC Orders Dismantling of Unlit Arkansas Tower
  • New York Man Ordered to Cease Operating Interference-Causing Device
  • Louisiana Corporation Fined for Engaging in Prohibited Communications during FCC Auction

FCC Orders Unlit, Unmarked Tower Dismantled

In a recent Order, the FCC directed the owners of a parcel of land where an unlit tower in Arkansas sits to dismantle the structure because it is not lit or marked according to the FCC’s Rules or the Communications Act (the “Act”).  The Federal Aviation Administration had declared the structure to be a “menace to aviation.” Section 303(q) of the Act allows the FCC to require the painting and/or illumination of radio towers where those towers are a menace to air navigation. That provision also requires that when a tower ceases to be licensed by the FCC, the tower owner must continue to maintain the painting and/or lighting of the tower, and the FCC can order it dismantled if the FCC determines the tower is a menace to air navigation.

The tower “owner” may include an “individual or entity vested with ownership, equitable ownership, dominion or title to the [tower] structure.” The FCC has determined that if the title holder of the tower does not own the land where the structure is located (i.e., if the tower owner has leased the land), the title holder of the structure is deemed the owner until the landowner acquires possession of the structure. After that occurs, the landowner will be considered the owner of the structure.

This particular situation was unusual in that the tower owner could not definitively be determined. In 1990, the then-current landowner granted an easement allowing an individual to build the tower structure and required an annual $12,000 payment for the easement. The easement was to run with the land, but the landowner could terminate the easement if the payments were more than 45 days late. In subsequent years, the tower was sold several times. Ultimately, it was registered with the FCC in 1998, given an Antenna Structure Registration number, and required to have a steady-burning obstruction light at the top of the tower.

The tower and associated station were later sold to an entity that is no longer in existence. Through public property records in Arkansas, the FCC determined the identity of the owner of the land and sent a letter to the owner in 2017. In her response, the landowner told the Commission that she jointly owns the land with two other individuals, has never received any payments for the easement, and that the electricity to the tower was disconnected in 2005 at her request. She also expressed interest in quieting title to the structure and indicated a desire to have it dismantled. The FCC sent letters to the two other landowners identified, seeking to confirm that no landowner had received the annual fee for the easement, but received no response.

In the Order, the FCC indicated that the landowners possess the structure for the limited purpose of invoking Section 303(q) of the Act, and ordered them to dismantle the structure. In case another party comes forward to challenge the dismantling of the tower, the FCC held that any person having a “remaining interest in the Structure” is subject to the Order as well. The Commission ordered the structure to be dismantled within 90 days of the release of the Order.

New York Resident Ordered to Cease Operating Interference-Causing Equipment

The FCC recently issued a Citation and Order (“C&O”) directing a New York man to stop operating a device at his home that was causing harmful interference to a wireless provider’s licensed operations. The Commission warned him that he may be liable for fines of up to $22,021 per day if he does not comply with the order.

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Pillsbury’s communications lawyers have published FCC Enforcement Monitor monthly since 1999 to inform our clients of notable FCC enforcement actions against FCC license holders and others. This month’s issue includes:

  • Telecommunications Carrier Pays $3.8 Million To Resolve 911 Outage Investigation
  • FCC Reduces Fine for Late-Filed License Renewal Application
  • Arkansas Radio Station Faces $17,500 Fine for Unauthorized Silence and Public File Violations

77-Minute 911 Outage Results in $3.8 Million Penalty

A large telecommunications provider entered into a consent decree with the FCC last month to resolve an investigation into a one hour and 17 minute 911 service outage that occurred on September 28, 2020. Section 9.4 of the FCC’s Rules states that all “telecommunications carriers shall transmit all 911 calls to a PSAP [Public Safety Answering Point], to a designated statewide default answering point, or to an appropriate local emergency authority…” Additionally, Section 4.9(h) of the Rules requires a wireline communications provider experiencing a network outage that potentially affects 911 service to notify the designated official at the affected PSAP of the outage “as soon as possible but no later than thirty minutes after discovering the outage[.]”  The provider must “convey to that person all available information that may be useful in mitigating the effects of the outage.…”

The 911 outage began when two new Global Traffic Managers (“GTMs”) were introduced into the carrier’s next generation 911 (“NG911”) facilities. A configuration error occurred that placed the new GTMs into the carrier’s existing, operational environment with a “blank” configuration, meaning they contained no routing data. During the outage, thousands of calls to PSAPs in Arizona, Colorado, Minnesota, North Carolina, North Dakota, South Dakota, and Utah were unable to be completed for a period of one hour and 17 minutes, and the carrier failed to timely notify all affected PSAPs of the outage.

The carrier acknowledged that it was responsible for complying with the applicable FCC rules regardless of any alleged failures by its subcontractors, and ultimately entered into a consent decree with the FCC to resolve the investigation.

The terms of the consent decree require the carrier to pay a $3,800,000 civil penalty. Additionally, the carrier must implement a compliance plan “to develop and implement processes in the evolving NG911 environment” to identify risks that could result in 911 service disruptions, protect against such risks, detect 911 outages when they occur, respond to such outages with remedial actions, and recover from such outages as soon as practicable. The carrier is also required to report any material violations of the 911 rules or the terms and conditions of its consent decree within fifteen calendar days of discovering a violation.

Broadcaster’s Fine for Late License Renewal Application Reduced to $5,000

In a December 2021 Forfeiture Order (“Order”), the FCC reduced the fine issued to a Rhode Island broadcaster for failing to timely file a license renewal application for its FM translator station.  As we discussed in September, the FCC originally issued a Notice of Apparent Liability for Forfeiture (“NAL”) proposing a $7,000 fine.

The broadcaster had acquired the translator after its prior owner received only a short-term license renewal for it, meaning that its license would expire earlier than those of other Rhode Island stations. Because of the shorter term, a license renewal application should have been filed by July 1, 2017, the first day of the fourth month prior to the license expiration date.  Unfortunately, the broadcaster did not file a license renewal application until September 11, 2020, and did not request Special Temporary Authority (“STA”) to operate without a license until September 16, 2020.  In its defense, the broadcaster informed the FCC that there was a discrepancy in the FCC’s LMS database, which indicated the translator’s license would expire on April 1, 2022, the same date as all other Rhode Island radio licenses.

The Commission granted the STA on October 2, 2020 for a period of six months, allowing the station to operate while the renewal application was processed.  However, the renewal processing took longer than six months, so the broadcaster timely filed for an extension of the STA in March 2021, which remains pending.

Ultimately, the FCC issued an NAL in September 2021, proposing a fine of $7,000 – $3,000 for failing to timely file a license renewal application and $4,000 for the resulting unauthorized operation. The NAL gave the broadcaster thirty days to either pay the fine or seek reduction or cancellation of it. In response, the broadcaster filed a Petition for Reconsideration asking the FCC to reduce or cancel the fine.

In the petition, the broadcaster argued that: (1) it acted in good faith and was not responsible for the previous licensee’s misconduct resulting in the short-term license renewal; (2) though it operated after the license expired, its broadcast was a public service which did not result in interference to any other station; (3) it has a record of compliance with the FCC’s Rules; (4) the FCC incorrectly discounted the LMS database error because, although LMS did not exist at the time of violation, the incorrect expiration of April 1, 2022 was also listed in the CDBS database which was in use at the time; (5) the violation was over a shorter period of time than was initially thought due to a covering license application being filed; and (6) the broadcaster was unaware the license expired because the station was still assessed regulatory fees and was listed as “licensed” in queries performed in the FCC’s databases.

In its Order responding to the Petition for Reconsideration, the FCC reduced the fine by $2,000, citing the broadcaster’s history of compliance with the Commission’s Rules. It reduced the fine by $500 for each of the two regulations violated (failure to timely file a license renewal application and the resulting unauthorized operation). The FCC then acknowledged that there was “a possibility, albeit remote,” that the incorrect date listed in the databases may have been a contributing factor. The Commission also noted that a Covering License granted in January 2020 also had the short-term license expiration date listed, but again acknowledged that some time after that January 2020 grant, the incorrect April 1, 2022 expiration date would have appeared in searches in LMS and CDBS. As a result, the FCC agreed to further reduce the fine by another $1,000, bringing the total amount down to $5,000.

FCC Fines Arkansas Broadcaster for Silent Radio Station and Public File Violations

The FCC fined an Arkansas radio station $17,500 for (1) discontinuing operation of its AM radio station and FM translator without first requesting authority from the FCC to do so, (2) Public Inspection File rule violations, and (3) failing to update certifications made in its license renewal applications.

In January of 2020, the broadcaster had filed license renewal applications for both stations in which it certified the stations were operating and had not been silent during the license term for more than 30 days. However, on March 6, 2020, the broadcaster’s AM station, and therefore the associated FM translator, went silent due to failure of the AM transmitter.  The FCC was alerted to this fact through an informal objection to the AM station’s pending license renewal application.

Shortly after the informal objection was filed with the FCC, the broadcaster submitted STA requests seeking authority for both stations to stay silent.  The FCC granted the STA requests on May 22, 2020, but noted that the requests had not been timely filed, as the stations were silent for thirty days as of April 6, 2020, and the grant of the STAs did not authorize the stations’ silence between April 6, 2020 and May 22, 2020.

The FCC’s rules require stations to notify the Commission within 10 days of discontinuing operations, and to obtain FCC authorization if the station will be silent for more than 30 days.  Here, both stations went silent on March 6, 2020, with the AM station resuming operations on July 29, 2020 and the FM translator resuming operations on September 25, 2020.  As a result, the broadcaster should have notified the FCC the stations had gone silent no later than March 17, 2020, and sought authority to remain silent by April 5, 2020.  Since the STA requests were not filed until May 22, 2020, the FCC found that the broadcaster had willfully and repeatedly violated Sections 73.1740(a)(4) and 74.1263(e) of its Rules.

Additionally, Section 73.3526(e)(11)(i) of the FCC’s Rules requires every station to place in its Public Files “a list of programs that have provided the station’s most significant treatment of community issues during the preceding three month period.” The list must be placed in the Public Inspection File on a quarterly basis within ten days of the end of each calendar quarter. The FCC’s review of the AM station’s Public File revealed that the Programs/Issues Lists for six quarters were filed late, and eight were missing.

Finally, the FCC noted that under Section 1.65 of its Rules, applicants are responsible for the continuing accuracy and completeness of information furnished in pending applications. In this instance, the broadcaster certified in its license renewal applications that the stations were “currently on the air broadcasting,” that there had been no rule violations by the licensee, and that the stations had not been silent for more than 30 days. The FCC explained that the first certification became inaccurate when the stations went off the air on March 6, 2020 and the second certification became inaccurate when the broadcaster failed to notify the Commission the stations were off the air on March 16, 2020. The third certification became inaccurate on April 6, 2020, the 31st day the stations were silent.

The Commission’s base fine for unauthorized silence is $5,000. The base fine for failure to file required forms or information is $3,000, and the base fine for Public Inspection File violations is $10,000. In determining the amount of a proposed fine, the FCC may adjust its base fine upward or downward based upon the nature, circumstances, extent, and gravity of the violation, in addition to the licensee’s degree of culpability and any history of prior offenses. In this case, the Commission concluded a proposed total fine of $17,500 was appropriate.

Fortunately for the broadcaster, the FCC did not find that the violations constituted a “serious violation” or pattern of abuse preventing renewal of the stations’ licenses. Barring other issues arising, the FCC indicated that both license renewal applications would be granted in separate Commission actions upon conclusion of the stations’ forfeiture proceedings. However, given the importance the FCC places on its Public Inspection File requirements, the FCC stated that any grant of the license renewal applications would be conditioned on the AM station submitting a report regarding its compliance with those requirements.

A PDF version of this article can be found at FCC Enforcement ~ January 2022.

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Pillsbury’s communications lawyers have published FCC Enforcement Monitor monthly since 1999 to inform our clients of notable FCC enforcement actions against FCC license holders and others. This month’s issue includes:

  • FCC Proposes $20,000 Fine for Broadcast of False EAS Alert Tone
  • Mississippi Television Station Fined $18,000 for Late Issues/Programs Lists and Failure to Disclose Violation
  • Illinois High School Agrees to Consent Decree for Violations Relating to Periods of Silence, Late Issues/Programs Lists, and Failing to File a Biennial Ownership Report and EEO Program Report

Nevada Radio Licensee Receives Proposed Fine of $20,000 for Transmitting False EAS Tone

The FCC issued a Notice of Apparent Liability for Forfeiture (NAL) to a radio station licensee for violating the Commission’s Emergency Alert System (EAS) rules—specifically Section 11.45 of the Commission’s Rules, which prohibits the transmission of false or deceptive EAS tones.

The EAS is a nationwide public warning system designed to alert the public in an emergency. In order to maintain the effectiveness of such emergency alerts, EAS tones may only be aired in specific circumstances, such as an actual emergency, an authorized test, or a public service announcement educating the public about EAS. Section 11.45 strictly prohibits airing an EAS tone, or simulations thereof, except in connection with of one of these permitted uses.

In October 2020, the FCC received a complaint alleging that a Nevada radio station had transmitted EAS tones during a talk show that were not connected to an actual emergency. In January 2021, the FCC’s Enforcement Bureau sent a Letter of Inquiry to the broadcaster seeking information regarding the potential violation.

The broadcaster responded that the tones had indeed aired, and included an audio recording of the program in question. The broadcaster indicated it did not review the program containing the EAS tones prior to broadcast as the program was part of a programming block purchased by the talk show’s host.  It noted that the program containing the EAS tones was also simulcast on the digital subchannel of another co-owned radio station and on an FM translator.

Based on the broadcaster’s admissions and the FCC’s review of the audio recording, the Commission found that the broadcaster willfully violated Section 11.45 of the Commission’s Rules. The FCC also noted that while the base fine for violations of the EAS rule is $8,000, it looks at the particular facts of each case and may upwardly adjust that amount based on a number of specific factors, including the number of repetitions, the duration of the violation, the audience reach of the transmission, and the public safety impact.

In this instance, the FCC emphasized the stations’ sizeable audience reach, noting that the violation was exacerbated by rebroadcasts on the digital subchannel and FM translator. Because all three stations are located in Las Vegas, a top 50 market, the audience reach was substantial. The FCC therefore concluded that an upward adjustment was warranted, proposing a total fine of $20,000. The company has 30 days from release of the NAL to pay the fine or file a written statement seeking reduction or cancellation of the proposed fine.

FCC Proposes $18,000 Fine for Mississippi Television Station’s Late-Filed Issues/Programs Lists

The FCC fined a Mississippi television station $18,000 for failing to timely upload all of its quarterly Issues/Programs Lists to its Public Inspection File. The station recently filed a license renewal application, and an FCC staff review of the station’s Public Inspection File revealed that during the license term, the station uploaded twenty-one of the Lists late and failed to properly disclose these violations in its application.

Section 73.3526(e)(11)(i) of the FCC’s Rules requires every commercial television station to place in its Public Inspection File “a list of programs that have provided the station’s most significant treatment of community issues during the preceding three month period.” The list must include a brief narrative of the issues addressed, as well as the date, time, duration, and title of each program addressing those issues. The list must be placed in the Public Inspection File on a quarterly basis within 10 days of the end of each calendar quarter.

The FCC noted that six of the Lists created during the license term were uploaded more than one year late, eleven Lists were uploaded between one month and one year late, and four Lists were uploaded between one day and one month late. The licensee also did not disclose the violations in its license renewal application. When the licensee failed to provide an adequate explanation for the late uploads, the Commission concluded that the licensee willfully and repeatedly violated Section 73.3526 of the FCC’s Rules. The FCC also found that the failure to report the violations constituted an apparent violation of Section 73.3514(a) of its Rules, which requires that applications filed with the Commission be accurate and complete.

Section 1.80(b)(10) of the FCC’s Rules establishes a base fine of $10,000 for Public Inspection File violations and a base fine of $3,000 for failure to file a required form or information. However, the Commission may adjust the amount upwards or downwards based upon factors such as the “nature, circumstances, extent and gravity of the violation,” in addition to the licensee’s “degree of culpability” and “any history of prior offenses.” Taking those factors into account, the FCC proposed a fine of $15,000 for the late-filed Lists and a fine of $3,000 for the failure to disclose those violations in the license renewal application, resulting in a total proposed fine of $18,000. Noting that the violation did not constitute a “serious violation” nor a pattern of abuse that would prevent renewal of the station’s license, the FCC indicated it would grant the license renewal application by separate action if no other issues arose.

Illinois High School Enters Into Consent Decree for Violations Relating to Periods of Silence, Late Issues/Programs Lists, and Failure to File a Biennial Ownership Report and EEO Program Report

An Illinois High School, the licensee of a noncommercial radio station, recently entered into a Consent Decree with the FCC for failing to (i) promptly notify the Commission that the station was silent for more than ten days, (ii) request Commission authorization to remain silent for more than 30 days, (iii) file required Biennial Ownership Reports, (iv) submit an EEO Program Report, and (v) timely upload its quarterly Issues/Programs Lists to its Public Inspection File throughout the license term.

Section 73.561(d) of the FCC’s Rules permits stations to limit or discontinue operation for a period of no more than 30 days, but requires licensees to notify the Commission no later than the 10th day of limited or discontinued operation. If the station needs to remain silent beyond 30 days, a licensee must request Special Temporary Authority (an “STA”) from the FCC to do so. In this case, the station discontinued operations on June 1, 2019 but did not notify the FCC until September 24, 2019, when it sought an STA.

The FCC granted the STA request on October 10, 2019 for a period of no longer than 180 days. The licensee requested an STA extension on March 10, 2020 which was granted on March 17, 2020 for a period ending June 1, 2020.  Citing reasons associated with the COVID-19 pandemic, the licensee filed a final extension request on June 1, 2020 which the FCC granted on July 15, 2020 for a period ending December 1, 2020. During this time, the licensee filed the station’s license renewal application on August 3, 2020. The station resumed operations on November 14, 2020.

In October 2020, an informal complaint was filed against the license renewal application, arguing that the station was silent for longer than 12 months and that granting the application would be unfair to other high school stations in the region. The complaint also pointed out that the application falsely certified that the station had not been silent for any consecutive 12-month period.  Section 312(g) of the Communications Act states that a license shall automatically expire if a broadcast station “fails to transmit broadcast signals for any consecutive 12-month period.”

In response, the FCC noted its discretion under Section 312(g) to extend or reinstate a license “to promote equity and fairness.” The FCC also noted that the station did resume operations on November 14 – prior to the STA expiring on December 1. The Commission agreed that the licensee incorrectly certified compliance with Section 312(g), but indicated it did not believe the licensee’s incorrect certification was intentionally false, as the station had an STA allowing it to remain silent. However, the FCC did conclude that the licensee violated Section 73.3615(d) (failing to file required Biennial Ownership Reports), Section 73.2080(f)(1) (failing to submit an EEO Program Report with the license renewal application), and Section 73.3527(b)(2)(i) (failing to timely upload Issues/Programs Lists to the Public Inspection File).

In light of the Commission’s findings, the licensee elected to enter into a Consent Decree with the FCC to resolve the matter rather than face an extended FCC proceeding. Pursuant to the Consent Decree, the licensee admitted the violations and agreed to pay a civil penalty of $1,000. The Consent Decree also requires the licensee to file an EEO Program Report within 10 days, and implement a compliance program, including appointment of a compliance officer, development of a compliance manual, implementation of a training program, filing of a compliance report with the FCC a year after entering into the Decree, and reporting to the FCC any violation of the Consent Decree, the Silent Notification Rule, the Ownership Report Rule, the EEO Program Report Rule, or the Public Inspection File Rule within 10 days of discovering a violation.

A PDF version of this article can be found at FCC Enforcement ~ December 2021.

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Pillsbury’s communications lawyers have published FCC Enforcement Monitor monthly since 1999 to inform our clients of notable FCC enforcement actions against FCC license holders and others. This month’s issue includes:

  • Florida Broadcaster Pays $20,000 for Unauthorized Tower Construction Work
  • Colorado Broadcaster Issued Notice of Violation for Operating FM Translator on Wrong Frequency
  • Telecommunications Company Receives Cease-and-Desist Letter From FCC for Transmitting Illegal Robocalls

FCC Fines Florida Broadcaster $20,000 for Commencing Tower Construction Prior to Completing Required Environmental Review

The FCC’s Enforcement Bureau and a Florida broadcaster entered into a Consent Decree to resolve an investigation into whether the broadcaster began clearing land for a wireless telecommunications tower before it completed the required environmental review. Environmental reviews are required by the FCC’s Rules, including rules implementing the National Environmental Policy Act of 1969 (NEPA). To settle the matter, the broadcaster admitted violating the FCC’s environmental and antenna structure rules, and agreed to implement a compliance plan while making a $20,000 penalty payment.

The FCC’s Environmental Rules require applicants and licensees to assess whether proposed facilities may significantly affect the environment. Under Section 1.1307(a)(3) of the Commissions Rules, an applicant must prepare an Environmental Assessment for facilities that could have a significant environmental effect. When considering whether an action may have a significant environmental effect, one of the factors an applicant must consider is whether the proposed site may affect threatened or endangered species or designated critical habitats.

Additionally, the FCC’s Antenna Structure Registration (ASR) rules require the owner of a proposed or existing antenna structure to follow registration procedures prior to constructing or altering a tower. If an Environmental Assessment is required by the rules, it must be included in the ASR application.

In July and August of 2020, the broadcaster hired contractors to perform the necessary environmental review and construct a wireless communications tower located within the designated critical habitat of the endangered Florida bonneted bat. When the broadcaster filed its ASR application in November 2020, it included an Environmental Assessment depicting premature clearing and admitted to preconstruction activities.

Although the environmental review was later completed and the FCC authorized construction of the tower, the FCC issued a Letter of Inquiry to the broadcaster in April 2021 asking a series of questions related to its compliance with the Commission’s Environmental and ASR rules. The broadcaster responded in July 2021, admitting that it began construction by clearing vegetation from the tower site around August 3, 2020 – before it prepared an Environmental Assessment and before applying for an ASR.

To resolve the investigation, the broadcaster agreed to enter into a Consent Decree in which it admitted its actions violated the FCC’s Environmental and ASR rules. As part of the Decree, the broadcaster must designate a compliance officer, implement a multi-part compliance plan, including developing a compliance manual and compliance training program, disclose within fifteen days any violations of the Consent Decree or the Environmental and ASR rules, file annual compliance reports with the FCC for the next three years, and pay a $20,000 civil penalty.

FCC Issues Notice of Violation to Colorado Licensee for Operating FM Translator on Unauthorized Frequency

Earlier this month, the FCC issued a Notice of Violation to the licensee of a Colorado FM Translator asserting violations of Sections 1.903(a) and 74.14(a) of the FCC’s Rules by operating a station on a channel for which it wasn’t licensed.

Section 1.903(a) requires stations to be used and operated only in accordance with the rules applicable to their particular service and with a valid authorization granted by the Commission. Pursuant to Section 74.14(a), once an FM Translator has been built in accordance with the terms of its construction permit and a license application has been filed showing the station is in satisfactory operating condition, it may commence service or program tests.

On three different dates between October 2020 and January 2021, an agent of the Denver Office of the FCC’s Enforcement Bureau observed the FM Translator operating on Channel 282 despite being licensed to operate on Channel 272. While the licensee had obtained a construction permit authorizing it to modify the station to operate on Channel 282, at the time of the three separate observations, it had not yet filed an FM Translator License Application. Until a license application is filed, the facility lacked authority to operate with the parameters outlined in the construction permit, and any such operation would violate Section 74.14(a).

The Notice of Violation seeks additional information from the broadcaster concerning these apparent violations. It instructs the broadcaster to submit within 20 days a written response fully explaining each apparent violation and all relevant surrounding facts and circumstances, including the specific actions taken to correct any violations and prevent them from recurring. The Notice also requires the broadcaster to include a timeline for completing any pending corrective actions.

FCC Issues Cease-and-Desist Letter to Telecommunications Company for Transmitting Illegal Robocalls

The FCC’s Enforcement Bureau issued a cease-and-desist letter to a telecommunications company for apparently transmitting illegal robocalls. The letter instructs the company to investigate, and if necessary, cease transmitting any illegal robocall traffic immediately and take steps to prevent its network from being used to transmit illegal robocalls.

The Enforcement Bureau issued the letter after an investigation revealed the company apparently originated multiple illegal robocall campaigns. The Bureau works closely with the USTelecom Industry Traceback Group (“Traceback Consortium”), which is the consortium selected pursuant to the TRACED Act to conduct tracebacks. The Traceback Consortium investigated prerecorded voice message calls that voice service providers and customers of YouMail flagged as illegal robocalls made without consent of the called party.

Between August 24, 2021 and October 15, 2021, the Traceback Consortium conducted tracebacks and concluded that the company originated over 80 calls that appeared to be illegal robocalls, including substantial numbers of government imposter scam calls such as posing as the Social Security Administration and the Federal Reserve, as well as calls threatening utility discontinuation, offering fake credit card rate reductions, and arrest warrant scams. Furthermore, the Traceback Consortium notified the company about the calls and provided access to supporting data identifying each call prior to the cease-and-desist letter being sent.

The FCC noted that in addition to the Traceback Consortium previously notifying the company, the numerous tracebacks to the company as an originator indicated that the company is apparently knowingly or negligently originating illegal robocall traffic. The letter instructs the company to take steps to “effectively mitigate illegal traffic within 48 hours” and inform the FCC and the Traceback Consortium within 14 days of the date of the letter of the steps it has taken to “implement effective measures” to prevent customers from using the network to make illegal calls.

If the company fails to properly take the actions listed in the letter or fails to take sufficient mitigating actions to prevent customers from using its network to make illegal robocalls, downstream U.S.-based providers may block calls transmitted by the company. Additionally, the FCC may find that the company’s certification in the Robocall Mitigation Database is deficient and direct the removal of its certification from the database. If its certification is removed from the Robocall Mitigation Database, all intermediate and terminating voice service providers would be required to immediately cease accepting calls from the company.

A PDF version of this article can be found at FCC Enforcement ~ November 2021.

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Pillsbury’s communications lawyers have published FCC Enforcement Monitor monthly since 1999 to inform our clients of notable FCC enforcement actions against FCC license holders and others. This month’s issue includes:

  • Streaming Service Agrees to Pay $3.5 Million for Violating FCC’s Closed-Captioning Rules
  • FCC Enters Consent Decree with Kentucky Broadcaster for Failing to Timely File License Renewal Application
  • Alabama Television Station Fined for Late Issues/Programs Lists

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Pillsbury’s communications lawyers have published FCC Enforcement Monitor monthly since 1999 to inform our clients of notable FCC enforcement actions against FCC license holders and others. This month’s issue includes:

  • FCC Proposes Largest Robocalling Fine Under TCPA
  • Tennessee Broadcaster Fined for Failing to File License Applications for FM Translators
  • FCC Fines Rhode Island Broadcaster for Late-Filed License Renewal Application

Continue reading →