Reminder of TV license renewal and October announcements: IA and MO | Wiley Rein LLP



Licensed TV stations in Iowa and Missouri must file license renewal applications by Friday, October 1, 2021. Pursuant to the new Federal Communications Commission (FCC) public notice to reign, a television station must broadcast post-filing ads after submitting its renewal application. Each station must broadcast a total of six on-air announcements over four weeks. No more than two announcements per week will count towards the total of six announcements. In addition, announcements must be shown between 7:00 a.m. and 11:00 p.m. local time. Pre-filing announcements are no longer necessary.

Post-filing announcements should be presented both visually and audibly. The ad text should appear on screen when read by the advertiser. Stations should keep track of when the announcements were broadcast. For more details on post-filing announcements, please see Section II of the Wiley TV Primer. The Primer also contains the mandatory post-filing ad language for full-power television stations (Attachment B) and low-power television stations broadcasting local programming (Attachment C).

Within seven days of the end of post-filing announcements, licensees of full-power and Class A television stations must upload to each station’s online public record a statement certifying compliance with the FCC notice requirements. . An example of a certification form is available in the primer (attachment D). Stations should upload them to the “Local Public Announcements” folder under the “More Public Inspection Files” tab. Finally, the FCC now requires low-power television stations not producing their own programming and television translation stations to make a post-filing notice available online after filing its license renewal application. To comply with the new FCC requirements, which we have discussed in more detail here, the post-filing announcement should be made by inserting a tab or link on the station’s home page ostensibly titled “FCC Applications” and a link to a separate page containing the text of the notice. The notice must be posted, in order of availability, on (1) the website of the requesting station, (2) the website of the licensee of the requesting station or (3) the website of the parent entity of the requesting station. The notice must be posted for 30 consecutive days on the web page or link. The text of the required notice can be found in Attachment E of the primer.

Prior to filing Form 303-S renewal requests, stations must submit an EEO Schedule 396 broadcast program report. Information regarding filing Form 303-S requests can be found in Section III of the Schedule. The primer and Annex F, and information on filing the Annex 396 report can be found in Section VI and Annex I.


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