This is a reminder about two April 1 deadlines for Indiana broadcast stations – (1) the deadline for license renewal for TV and (2) the deadline for radio and TV stations with 5 or more full-time employees to upload an EEO Annual Report to the online public inspection file and station website.
License Renewal
All full-power TV, Class A, low-power TV, and translator stations in Indiana must file their license renewal application by April 1, 2021. To prepare for the license renewal filing itself, stations should review their public file for accuracy (see this article for a link to a video about the public file and links to other articles about other renewal-related FCC paperwork requirements), become familiar with the renewal form (Form 2100, Schedule 303-S), and be sure the person responsible for filing the form has access to and is familiar with the FCC’s License and Management System (LMS) database, which is where the license renewal application will be filed. Full-power TV, Class A, and low-power TV stations filing for renewal, even if they have fewer than five full-time employees, must also file a Broadcast Equal Employment Opportunity Program Report (Form 2100, Schedule 396) before filing their license renewal applications.
In the past, stations had to air pre-filing announcements to alert the public to the upcoming license renewal filing. Those pre-filing announcements are no longer required. As discussed below, post-filing announcements are still required.
After filing the license renewal application with the FCC, full-power TV, Class A, and low-power TV (that originate local programming) stations must air six required post-filing announcements, announcing to the public that the station has filed its license renewal application. The announcements must air at least once per week (Monday through Friday between 7 am and 11 pm) for four consecutive weeks, beginning no earlier than the date on which the FCC releases a public notice announcing that the application has been accepted for filing and no later than five business days after that public notice. No more than two broadcasts may be made in any single week and broadcasts made in the same week cannot air on the same day. The standardized, FCC-required text for the on-air announcements is below:
On [DATE], [APPLICANT NAME], licensee of [STATION CALL SIGN], [STATION FREQUENCY], [STATION COMMUNITY OF LICENSE], filed an application with the Federal Communications Commission for renewal of license. Members of the public wishing to view this application or obtain information about how to file comments and petitions on the application can visit publicfiles.fcc.gov, and search in [STATION CALL SIGN’S] public file.
Public notice of low-power TV (that do not originate local programming) and TV translator station renewal filings must be published online (the requirement for print publication has been eliminated). The online announcement should be posted on the website of the LPTV or that of the translator’s primary station. There should be a link on the homepage of the website that says “FCC Applications” that links to the webpage on which the text of the online notice is posted. The text needs to be on the website for 30 days after the FCC releases a public notice announcing that the translator renewal application has been accepted for filing. The webpage with this online announcement must indicate on what date the page was last updated. See articles about this new requirement here and here. The standardized, FCC-required text for the online announcement is below:
On [DATE], [APPLICANT NAME], [PERMITTEE/LICENSEE] of [STATION CALL SIGN], [STATION FREQUENCY], [STATION COMMUNITY OF LICENSE OR, FOR INTERNATIONAL BROADCAST STATIONS, COMMUNITY WHERE THE STATION’S TRANSMISSION FACILITIES ARE LOCATED], filed an application with the Federal Communications Commission for renewal of license. Members of the public wishing to view this application or obtain information about how to file comments and petitions on the application can visit [INSERT HYPERLINK TO APPLICATION LOCATION IN THE MEDIA BUREAU’S LICENSING AND MANAGEMENT SYSTEM].
EEO Annual Reports
This is a reminder that there is an April 1 deadline for Indiana broadcast stations to upload EEO Public Inspection File Reports to their online public inspection file.
On or before April 1, all commercial and noncommercial full-power radio and television and Class A stations in Indiana with five or more full-time employees (30 hours a week or more) in their station employment unit are required to post in their online public file their most recent EEO annual report. An employment unit is a station or group of commonly owned stations serving the same general area that share at least one employee. A direct link to the EEO Public Inspection File report must also be included on the home page of each station’s website.
This report details a station’s recruitment efforts to identify applicants for full-time positions that were filled from April 1, 2020 through March 31, 2021.It also provides information about the outreach efforts that the station conducted during this period using the FCC’s menu options. These menu options are meant to educate the community about broadcast employment and to train employees to assume greater responsibilities at their stations. Obligations to perform activities listed in the menu options are required for station employment units of 5 or more full-time employees, even if they had no employment openings in the last year.
Stations with fewer than five full-time employees in their station employment unit are not required to post an EEO annual report in their online public file or on their website.
Even though they need not complete an annual report, as noted above, full-power TV, Class A, and low-power TV stations filing for renewal of license, even if they have fewer than five full-time employees in their station employment unit, must file a Broadcast Equal Employment Opportunity Program Report (Form 2100, Schedule 396) before filing their license renewal application.
