February Radio License Renewal and Announcements Reminder: KS, NE, & OK

Wiley Rein LLP

Radio stations licensed in Kansas, Nebraska, and Oklahoma must file license renewal applications by Monday, February 1, 2021. Pursuant to the Federal Communications Commission’s (FCC’s or Commission’s) new public notice rule, which took effect October 30, 2020, a radio station must air post-filing announcements after filing its renewal application. Each station must air a total of six on-air announcements over four weeks. No more than two announcements per week will count towards the total six required. Additionally, the announcements must air between 7:00 a.m. and 11:00 p.m. local time. Pre-filing announcements are no longer required.

For further details about post-filing announcements, please consult Section II of the Wiley Radio Primer. The Primer also contains the mandatory post-filing announcement text required by the Commission (Attachment B). Prior to filing the Form 303-S application for renewal, a station must submit a Schedule 396 Broadcast EEO Program Report. Information regarding filing Form 303-S applications can be found in Section III of the Primer and Attachment E, and information pertaining to filing the Schedule 396 Report can be found in Section IV and Attachment F. 

Additionally, within seven days of broadcasting the final post-filing announcement, stations must upload statements certifying compliance with the FCC’s post-filing notice requirements in their respective online public inspection files. A sample certification form is available in the Primer under Attachment C. Stations should upload these to the “Local Public Notice Announcements” folder in the “More Public Inspection Files” tab. Finally, the FCC now requires that FM Translator stations make a post-filing notice online after filing its license renewal application. To comply with the FCC’s new requirements, which we discussed in greater detail here, the post-filing announcement posting can be accomplished by inserting a tab or link on the station’s homepage conspicuously labeled “FCC Applications” that may link to a separate page containing the text of the notice. The notice should be posted in order of availability, on (1) the website of the applicant station, (2) the website of the applicant station’s licensee, or (3) the website of the applicant station’s parent entity. The notice must be posted for 30 consecutive days at the webpage or link. The required notice text is in Attachment D.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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