Items of Note in 2021 -

I. Applications for Renewal of License: The three-year long state-by-state license renewal cycle continues for stations in the television services (full-power television, Class A, TV Translator, and LPTV) and radio services (AM, FM, FM Translator, and LPFM). Stations will file their license renewal applications on FCC Form 2100, Schedule 303-S (“Form 303-S”) along with their Equal Opportunity Employment Reports on Form 2100, Schedule 396 (“Form 396”). The date by which the licensee must file a station’s application for license renewal depends on the state or territory of the station’s community of license. All licensees should familiarize themselves now with the dates associated with this important filing.

II. License Renewal Local Public Notice Requirements: The FCC has modified its rules regarding the local public notice required for certain broadcast applications. With regard to license renewal applications, such modifications include replacing newspaper publication with an online notice, providing broadcasters with more flexibility with respect to when on-air announcements must air, and standardizing the text of on-air announcements. Of particular note, rather than requiring post-filing license renewal announcements to be broadcast on the first and sixteenth of each month, under the new rules, licensees must air six total announcements over four consecutive weeks, beginning within five business days after the FCC has “accepted for filing” their license renewal application. All licensees should familiarize themselves with the modified local public notice requirements, including the dates by which announcements must air and/or be posted online, which applications are subject to the online notice requirement, and how to satisfy the online notice requirement. Additional information can be found in our License Renewal Advisories published on Comm Law Center prior to the state-by-state application deadlines...