Countdown to License Renewals--Highlight on the Minimum Operating Schedule Certification

Every eight years, broadcasters-both radio and television-must seek renewal of their Federal Communications Commission (FCC) licenses.  For radio stations, this cycle began in June 2011; for television stations, it begins in June 2012.  Each month, we will highlight a different component of the license renewal process to help you begin to prepare for your station's license renewal filing. 

This month, our highlight is on the Minimum Operating Schedule Certification.

The Commission added a new certification to the renewal application that requires licensees to certify that the station has not been silent for any period of time longer than 30 days (or operating for less than its prescribed minimum number of operating hours).  If the station was silent (or did not broadcast for its prescribed minimum number of operating hours) for 30 days or longer, then the licensee must provide an exhibit listing the dates on which the station was silent or operating at less than its required minimum schedule. 

The Commission's rules provide that a station may go silent or fail to maintain a minimum operating schedule for up to 30 days without receiving prior FCC authorization, provided that notification is provided to the Commission within 10 days disclosing the limited or discontinued operation.  By the 30th day, the station must seek Special Temporary Authority to remain silent or operate at variance from its license.  Therefore, any licensee that has a station that was silent or operating at variance from its minimum operating schedule for 30 days or longer should be able to locate the information required for this exhibit in the application for Special Temporary Authority filed with the FCC.

Now would be a good time to review your files to determine whether your station was off the air or operating at variance from its minimum operating schedule for 30 days or longer during this license term. 

Should you have any questions about this certification or other aspects of the license renewal process, contact one of the Wiley Rein Media attorneys.