Reminder of Post-Thanksgiving Deadlines for Broadcasters

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Wiley Rein LLP

For many, Thanksgiving is a time for some combination of family, food, football, and deal hunting. At the risk of contributing to your heartburn, we want to remind you of three upcoming deadlines that you do not want to wait until after the holiday to address.

First, broadcasters must certify the accuracy of any 13 GHz licenses by November 29, 2023. Many TV stations have licenses in the 12.7 – 13.25 GHz band that they use for studio-transmitter links or ENG. Stations that fail to timely certify the accuracy of their licenses could lose interference protection when the Federal Communications Commission (FCC) opens the 13 GHz band to new (non-broadcast) entrants. If you need to make corrections to the license data, you can do so in the FCC’s ULS system before November 29. Only minor modifications are permitted. Major modifications, including changes in transmit antenna location by more than five seconds and changes in emission type, require waivers, which the FCC will grant on a case-by-case basis. More details are available in this FCC Public Notice.

Second, broadcasters must submit their biennial ownership reports by December 1, 2023. Licensees of commercial and non-commercial full power television, Class A television, LPTV, AM radio, and FM radio stations must file biennial ownership reports.

Third, television stations providing feeable ancillary/supplementary services must file their annual reports by December 1, 2023. The reports should identify the revenue generated from ancillary/supplementary services and be accompanied by payment of the 5% ancillary/supplementary services fee.

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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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