The license renewal cycle, about which we have been warning broadcasters for at least the last year (see, for instance, our posts here, here and here), is now upon us. June 3 is the filing deadline for license renewals for radio stations in Maryland, DC, Virginia and West Virginia. Radio stations (including FM translators and LPFMs) licensed to any community in any of those states should be filing their renewal applications in the FCC’s Licensing and Management System (LMS) by Monday’s deadline. The new FCC forms, as we wrote here, have been available since early May, so the renewal and the accompanying EEO program report should either be on file or ready to be filed in LMS by the June 3 filing deadline. These stations should also be running their postfiling license renewal announcements on the 1st and 16th of June, July and August. Radio stations in the next renewal group, in North and South Carolina, should begin their license renewal pre-filing announcements on June 1st and 16th as well, informing the public about the upcoming filing of their renewals due on August 1. See this article on pre-filing announcements for more information.

In addition, broadcasters in Arizona, Idaho, Maryland, Michigan, Nevada, New Mexico, Ohio, Utah, Virginia, West Virginia, Wyoming, and the District of Columbia that are part of an Employment Unit with 5 or more full-time employees should also be preparing to add to their online public inspection file their Annual EEO Public File Report. This report is due to be added to their online public files by June 1. A link to this report should also be placed on the station’s website, if it has a website.

There are also comment deadlines in an FCC proceeding of interest. The FCC has asked for comments on its proposed regulatory fees for 2019, which will be paid before October 1 at a time that will be set by the FCC after considering the comments on the proposed fees. October 1 is when the government’s new fiscal year begins. The fee proposal, available here, would set radio fees about 20% higher than in previous years, with little apparent explanation as to why the fees have increased. The FCC also proposes to go to a new methodology for computing TV regulatory fees. Eventually, the fees are to be based entirely on the population of the service area of each individual station. This year, however, the fees are proposed to be a blend of last year’s DMA-based methodology and the new population-based determination. For many TV stations, fees would decline or stay relatively flat. However, some TV stations may see very significant increases – especially VHF stations in the northeast that have increased power beyond the normal limits for such stations, in an effort to make up for the inferiority of coverage for these stations when operating digitally. Comments on these proposals are due June 7.

June 11 is the date on which the Court of Appeals will hear oral arguments on the appeal of the FCC’s ownership decision from late 2017 in which the FCC, among other actions, abolished the newspaper-broadcast and radio-television cross-ownership rules and the rules requiring that there be 8 independent owners in a television market before a company could hold two TV licenses in that market. The rules are being challenged by a number of public interest groups who believe that the FCC has not done enough to foster the entry of minorities and other new entrants into broadcast ownership, and that, until an effective plan is implemented to bring about this ownership diversity, the FCC is precluded from changing any ownership rules (these groups argue that the FCC’s incubator program, about which we wrote here, is inadequate). The court will likely take several months after the argument to finally resolve these issues. This resolution is important as, if the court sides with those appealing the 2017 decision, the decision could effectively put on hold the current Quadrennial Review of the FCC’s ownership rules (which, as we wrote here, is targeted principally at radio ownership deregulation) until a more effective diversity plan is devised.

The FCC’s June meeting is light on broadcast matters. The one media issue on the agenda is the FCC’s proposal to review its leased access rules – the rules requiring that cable companies provide some portion of their channel capacity to independent parties who want to lease that capacity to provide their own programming. The FCC is expected to adopt a Notice of Proposed Rulemaking to review these requirements. The draft NPRM is available here. The FCC’s monthly meeting will be held on June 6.

June 21 brings to an end Phase 3 of the television repacking process following the incentive auction, when stations in that window are supposed to have completed their transition to a new channel. Phase 4 begins the next day, when stations in the next stage can begin testing on their new channel for operations.

On June 28, the FCC will host a workshop designed to promote the use of multilingual emergency alerting. The workshop will include presentations covering the multilingual capabilities of the Emergency Alert System (EAS) and Wireless Emergency Alerts (WEA), and alternative methods for delivering emergency information to non-English speakers. The workshop will be held from 9:00 a.m. – 2:30 p.m. EDT and will be webcast. Check the FCC’s website for further information. See the FCC Public Notice about the workshop, here.

Looking ahead to July, July 10 will bring the due date for the next round of Quarterly Issues Programs Lists and the Quarterly Children’s Television Reports. With the renewal cycle having now started, as we have written many times (here, here and here), these quarterly filings take on added significance as the failure to make timely filings will likely lead to FCC fines. So be prepared for the July 10 deadline. July 10 is also the deadline for repacked stations to file their quarterly Form 387 transition status reports (unless the station has already transitioned to its new channel).

As always, these are just the regulatory deadlines on which we happen to be focused. Consult with your own counsel for information about any deadlines we may have missed and any deadlines of particular importance to your own station. To look ahead at some of the other upcoming deadlines, see our Broadcaster’s Calendar, here.