June Television License Renewal and Announcements Reminder: MI & OH

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Television stations licensed in Michigan and Ohio must file license renewal applications by Tuesday, June 1, 2021. Pursuant to the Federal Communications Commission’s (FCC’s or Commission’s) new public notice rule, a television 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.

Post-filing announcements must be presented both visually and aurally. The text of the announcement should appear on screen when read by the announcer. Stations should maintain a record of when the announcements aired. For further details about post-filing announcements, please consult Section II of the Wiley TV Primer. The Primer also contains the mandatory post-filing announcement language for full-power television stations (Attachment B) and low power television stations originating local programming (Attachment C).

Within seven days of completing the post-filing announcements, licensees of full power and Class A television stations must upload to each station’s online public file a statement certifying compliance with the FCC’s notice requirements. A sample certification form is available in the Primer (Attachment D). Stations should upload these to the “Local Public Notice Announcements” folder in the “More Public Inspection Files” tab. Finally, the FCC now requires that low power television stations not originating their own programming and TV translator stations make a post-filing notice available 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 should be made by inserting a tab or link on the station’s homepage conspicuously labeled “FCC Applications” and linking 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 E of the Primer.

Prior to filing Form 303-S applications for renewal, stations 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 F, and information pertaining to filing the Schedule 396 Report can be found in Section VI and Attachment I.

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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