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Mandatory FCC Radio Deadlines: Violators Could Face Fines

June 1 Saturday - NC, SC -  Broadcasters start airing pre-renewal announcements

June 3 Monday - Final Day for MD, VA, WV Broadcasters to File REN, their License Renewal

August  7 Wednesday -  EAS NPT (National Periodic Test 2019)

 Christian Community Broadcasters (CCB) has been helping local community groups apply for, construct, and legally operate Low Power FM.  Let us know if CCB can help you with various pending deadlines or in any other way. 

  Phone 770 720-1037 Email JohnBroomall@Yahoo.com  PayPal accepted (even for stations without a PayPal account)

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5/17/19 Update from Al Shuldiner, Chief, Audio Division, FCC  
We have noticed that there has been some confusion in the LPFM community about the applicability to LPFM stations of Rule 73.3580, which mandates that broadcast stations provide local public notice of applications filed with the FCC.  In the case of renewal applications, stations are required to provide on-air announcements of the application starting two months before filing their renewal applications with the FCC.  We have received questions from some LPFM stations that were not sure if this rule applied to the LPFM service.  I agree that 73.3580 is not totally clear about that issue, but we have conducted some research over the past few weeks and concluded LPFM stations need to comply with 73.3580.  Although we have minimized many of the regulatory burdens for LPFM stations, Section 311(a)(1) of the Communications Act mandates that all applicants provide public notice of their applications.  Based on this statutory requirement, we believe LPFM stations are required to provide public notice consistent with the requirements in 73.3580.

We have updated our website to state this explicitly.  One additional question that may come up is that LPFM stations do not have public inspection files so LPFM stations cannot upload to OPIF proof of compliance with 73.3580.  We suggest that LPFM stations keep a record of compliance with 73.3580 with their other station records.  That way a station can provide proof of its compliance if parties file petitions to deny LPFM renewal applications based on claims of noncompliance with 73.3580. 

We recognize there has been confusion about this issue going into this renewal cycle.  Therefore, we will not take action against any LPFM station with a June 3, 2019 filing deadline that failed to complete its pre-filing announcements.  However, we will expect those stations to make post-filing announcements, and we will expect LPFM stations in subsequent filing groups to make all required announcements.

          CCB Pledges to Keep Current on the Latest interpretations of FCC Policy for our Clients

In March CCB sent a letter to LPFMs in MD, VA, and WV about the pending radio renewal cycle based on our understanding then of the renewal process.  We said the FCC was “tweaking” the process but we are wrong!  Everything has changed since the last renewal cycle eight years ago! The FCC is switching renewals from CDBS to the new License Management System. 

LMS Form 2100, Schedule 303-S, contains dozens of pages of complex, confusing “government-ese”. The FCC estimates the “paperwork burden” of the renewal process ranges from 1.25 to 12 hours. Christian Community Broadcasters (CCB) is your “go-to” expert on both the obvious and the obscure aspects of LPFM radio renewals in your state and nationally.  

In an earlier renewal cycle, one LPFM decided to do its own filing. They made a small, but fatal, mistake that could have been corrected in a minute.  Two years later the FCC notified the station that it was operating without a license and ordered it to “cease broadcasting immediately.”  Rather than appealing the decision and face a fine that could have exceeded $3,000, the station complied. 

   LPFM SCORECARD

                2013 LPFM Window 

Applications Filed

2,787

Dismissed/Cancelled/Lapsed

__1245

Net applications

1,542

On Air / Licensed

1451

Unbuilt Construction Permits

91

Net Total

1,632

              2000-2001 LPFM Window 

Applications Filed

3258

Dismissed 

1926

CPs Granted

1328

CPs Lapsed / cancelled

425

Total Licensed

907

License cancelled

129

Licensed and Silent

     15

Licensed / on air

778

     See Recnet.com for detailed scorecard

 

Since LPFM was established in 2000, Christian Community Broadcasters has successfully filed more than 1,000 FCC LPFM applications of all types for churches, ministries, schools, and other community groups.  They range from routine Forms to complex Petitions.   

CCB is “the A.C.E.” – Advocacy, Consulting, and Equipment for LPFM operators throughout the United States.  CCB is noted for its advocacy support of LPFM, its professional consulting, FCC filings, and quality RF equipment on a low power budget.

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Christian Community Broadcasters © 2019 | All Rights Reserved   (770) 720-1037      JohnBroomall @Yahoo.com