Items of Note in 20191
I. Applications for Renewal of License: The three-year long license renewal cycle for stations in the radio services (AM, FM, FM Translator, and LPFM) will begin on June 1, 2019. 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, including the dates on which public notice announcements must air in advance of the license renewal filing, the filing deadline itself (which is approximately four months before the date of license expiration), and the dates on which post-filing announcements must air. The next license renewal cycle for broadcast stations in the television services (full-power television, Class A, TV Translator, and LPTV) will not begin again until June 1, 2020.
II. Commercial and Noncommercial Biennial Ownership Report: December 2, 2019 is the deadline by which all commercial and noncommercial radio and television stations must file their biennial ownership reports. Commercial stations will file FCC Form 2100, Schedule 323 (“Form 323”), and noncommercial stations will file FCC Form 2100, Schedule 323-E (“Form 323-E”). While these licensees may have filed a biennial report as recently as March 2018, that report fulfilled the reporting obligation for the period that ended on October 1, 2017. The deadline was adjusted to allow for the implementation of revised report forms to be filed using the FCC’s Licensing and Management System (“LMS”). The new filing window opens October 1, 2019, and the information in all ownership reports must be accurate as of that date.
1. The deadlines in the 2019 Broadcasters’ Calendar are based on information known as of the date hereof and may or may not apply to any particular broadcaster. They are provided for general informational purposes only and should be doublechecked for currency close to each pertinent date/deadline. Actions by the FCC, Congress, or the courts could affect any of these deadlines by, for example, eliminating a particular reporting/filing obligation altogether or modifying the form used, content, deadline, fee, or manner of reporting/filing. It should also be noted that, as a general rule, when a deadline for filing a document with the FCC falls on a weekend or a federal holiday, the filing deadline shifts to the next business day. The listing below is not intended to be complete or exhaustive of all regulatory and non-regulatory deadlines that may apply to a given broadcaster year-to-year. Accordingly, broadcasters should seek the advice of communications counsel in each instance to assure timely and proper filing. This edition of our annual Broadcasters' Calendar supersedes all prior editions and accordingly any prior editions should no longer be used.