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Indian E-music – The right mix of Indian Vibes… » Political Broadcasting

Reminder – 2021 Will Include Some Off-Year Elections for State and Local Office – and FCC Political Broadcasting Rules Do Apply

Delivered... David Oxenford | Scene | Tue 12 Jan 2021 5:51 pm

After this year’s contentious elections, it is with reluctance that we even broach the subject – but broadcasters and cable companies need to be aware that in many jurisdictions there are elections this November. While most broadcast stations don’t think about the FCC’s political broadcasting rules in odd numbered years, they should – particularly in connection with state and local political offices.  There are elections for governor in November in Virginia and New Jersey, and all sorts of state and local elections in different parts of the country.  These include some mayoral races in major US cities.  Some of these local elections don’t even occur in November – and there are even a few that are taking place as early as next month. As we have written before, most of the political rules apply to these state and local electoral races so broadcasters need to be paying attention.

Whether the race is for governor or much more locally focused, like elections for state legislatures, school boards or town councils, stations need to be prepared. Candidates for state and local elections are entitled to virtually all of the political broadcasting rights of Federal candidates – with one exception, the right of reasonable access which is reserved solely for Federal candidates. That means that only Federal candidates have the right to demand access to all classes and dayparts of advertising time that a broadcast station has to sell. As we wrote in our summary of reasonable access, here, that does not mean that Federal candidates can demand as much time as they want, only that stations must sell them a reasonable amount of advertising during the various classes of advertising time sold on the station. For state and local candidates, on the other hand, stations don’t need to sell the candidates any advertising time at all. But, if they do, the other political rules apply.

That means that if a broadcast station decides to sell advertising time to one candidate in a state or local political race, they must sell it to all candidates for the same race – and be prepared to make available equal amounts of time in equivalent time periods. Stations can decide to make available advertising only in certain dayparts (or on certain stations in a cluster) for state and local races. They can even make different dayparts (or stations) available for different political races, as long as all candidates for the same race are treated the same. So, for instance, a station could decide to offer only spots during weekend and overnight time periods to candidates for the city council, while offering candidates for governor time during all dayparts. A station just needs to treat all legally qualified candidates (including independent and fringe party candidates) for the same state or local race in the same way.

Lowest unit rates apply to state and local candidates, if you choose to sell to those candidates.  That means if the time is sold to state and local candidates during the 60 days before the general election (no matter when that election will be held), the time must be sold to the candidate at lowest unit rates. See our summaries of the rules relating to equal time here, and to lowest unit charges here. Similarly, if a station on-air personality decides to run for state or local office (anything from the school board or local planning commission to governor or state legislature), the station needs to consider whether to take that personality off the air, or risk having to provide equal time to all competing applicants – for free – in amounts equivalent to the amount of time that the employee-candidate appeared on the air, even if the employee never mentions his or her candidacy at all. See our articles about this topic here and here.

Political file rules also apply to all advertising by candidates and their authorized campaign committees.  So the FCC’s recent insistence (see our articles here and here) on information about orders for candidate ads – including all price and schedule information – being uploaded to the public file within one business day, applies to these elections just as it does to federal elections.  See my video here, prepared for the Indiana Broadcasters Association, that discusses many of the FCC’s new interpretations of the public file rules.

Ads from non-candidate groups dealing with state and local elections generally do not require price and schedule information to be uploaded (unless those ads also mention a federal issue), but they do require that the public file contain an identification of the sponsor of the ad (address, phone number and contact person should be provided), plus a list of the ad sponsor’s executive officers, members of the Board of Directors or similar governing board.  Under the FCC’s guidance from 2019 (see our article here), the FCC thinks that most of these organizations will have more than one governing board member, so if you are provided with a single name, you are required to reach out to the sponsor or their representative and ask if there are others who should be listed.

For more about the political rules, see our Broadcaster’s Guide to Political Broadcasting here (though note that the political file information has not been updated, so refer to the video and articles linked in the prior paragraph for more information).  Don’t forget about these political advertising rules – even though this is an odd numbered year!


A Broadcaster’s 2021 Regulatory Calendar – Looking at Some of the Important Dates for the Year Ahead

Delivered... David Oxenford | Scene | Tue 5 Jan 2021 6:21 pm

Here we are, in a new and hopefully more “normal” year – wondering what will be ahead.  Each year, at about this time, we put together a look at the regulatory dates ahead for broadcasters – or at least the primary ones that we already know.  This year is no different – and we offer for your review our Broadcaster’s Regulatory Calendar for 2021.  While this calendar should not be viewed as an exhaustive list of every regulatory date that your station will face, it highlights many of the most important dates for broadcasters in the coming year – including dates for license renewalsEEO Public Inspection File ReportsQuarterly Issues Programs listschildren’s television obligations, annual fee obligations and much more.  This year, for LPTV and TV translator operators, there are also dates associated with this summer’s deadline for all such stations to be operating digitally (see our article here).

While this likely will not be a big political advertising year like 2020, there will be some state and local races – so we note the start of the Lowest Unit Charge window for this year’s November election – relevant in states like New Jersey and Virginia where there are races for governor and state legislature, and to the many locations across the country that will have mayor’s races and other state and local political contests.  Look for local information about the dates for any primary elections for these elections – as those primaries have their own LUC windows for the 45 days preceding the primary.  See our article here on how the other political broadcasting rules apply to state and local elections.

Certainly, as the year progresses, there will be plenty more dates to note.  Follow our blog where we weekly post a summary of the prior week’s regulatory actions relevant to broadcasters and a look ahead prior to the start of each month at the regulatory dates in the coming month, read other newsletters and trade publications and consult your own attorney to stay on top of the regulatory obligations that apply to your stations.  We hope that this 2021 Broadcasters Regulatory Calendar will give you a good start on spotting some of the important dates that may be ahead and affect your operations.

December Regulatory Dates for Broadcasters: License Renewals, EEO Filings, DTV Ancillary/Supplementary Fees, Comment Deadlines and More

Delivered... David Oxenford | Scene | Mon 30 Nov 2020 5:23 pm

December is a busy month for broadcasters with routine filings to complete and action on FCC proceedings that will carry over to the next administration.  Keep on top of these dates and deadlines even as your calendar fills up with holiday celebrations.

We start at the beginning of the month, with December 1 being the deadline for the filing of applications for the renewal of license of radio stations in Colorado, Minnesota, Montana, North Dakota, and South Dakota, and TV stations in Alabama and Georgia.  These stations should have already reviewed their public file (as we noted here, stations should pay particularly close attention to their political files) and be putting the finishing touches on their renewal application (see our article about license renewal preparation here).

These December 1 stations are the first group to file license renewal applications subject to the FCC’s new rules for post-filing announcements.  The FCC has eliminated the previous announcement schedule that required announcements on the 1st and 16th of each month during specific time periods for three months and now requires six announcements over a four-week period, beginning on the date the FCC announces that the renewal application has been accepted for filing.  The new rule also requires commercial and noncommercial stations that are not operating when their renewals are filed to post a notice on their websites or, if the station does not have a website, on the website of a parent or affiliated company, or if the station does not have such a site, on some publicly accessible site (like a community bulletin board, local newspaper site, or that of a state broadcasters association).  Stations with translators also need to post online notice about the translator’s renewal its primary station’s website.  Check out all the new local public notice rules, here, and read our posts providing more details about these requirements here and here.

Stations filing for license renewal must also submit FCC Form 2100, Schedule 396, also known as the Broadcast Equal Employment Opportunity Program Report, even if they are not part of a station employment unit with five or more full-time employees.  A station employment unit is one or more commonly controlled stations in the same geographic area that share at least one employee.

On or before December 1, full power radio and TV stations licensed to communities in Alabama, Connecticut, Colorado, Georgia, Maine, Massachusetts, Minnesota, Montana, New Hampshire, North Dakota, Rhode Island, South Dakota, and Vermont with five or more full-time employees in their station employment unit must upload to their online public file an annual Equal Employment Opportunity report detailing the employment unit’s hiring and outreach efforts from December 1, 2019 to November 30, 2020.

By December 1, digital television stations that provided ancillary or supplementary services between October 1, 2019 and September 30, 2020 must submit FCC Form 2100, Schedule G, and pay in fees 5% of the gross revenue derived from any ancillary or supplementary services provided.  Ancillary and supplemental services do not include non-subscription video channels delivered directly to the public but do include any other services provided over the station’s spectrum from which the station receives compensation, including “computer software distribution, data transmissions, teletext, interactive materials, aural messages, paging services, or audio signals, [and] subscription video.”  Stations that provided no such services are no longer required to file a report.

At the Commission’s December 10 Open Meeting, the Commissioners will vote on new rules for Broadcast Internet (ATSC 3.0) services.  The principal changes addressed in the FCC’s draft order are clarifications of the rules on the annual ancillary and supplementary services fee.  The changes in the draft order include reducing the fees to be paid by noncommercial television stations that offer new noncommercial, non-broadcast services through their ATSC 3.0 operations.  Ancillary services are not allowed to “derogate” the broadcast service and, in the draft order, the Commission would retain its current interpretation of “derogate” as meaning that a station must continue to offer at least one standard definition television programming channel.

By December 10, radio stations that entered into a consent decree with the Media Bureau over violations with their online political file in the first round of consent decrees that were released in August and September must submit their first compliance report.  This report documents compliance with the political file rules from October 4, 2020 through Election Day on November 3, 2020.  These stations must email their compliance spreadsheet to the FCC’s political programming staff.  The spreadsheet does not get uploaded to the station’s public file.  Review your consent decree closely for any other requirements applicable to your operations.  We wrote about the consent decrees, here.

Reply briefs in the FCC v. Prometheus Radio Project case are due to the Supreme Court by December 16.  This case is a review of a lower court’s decision to reject the FCC’s 2017 broadcast ownership changes.  These briefs follow the briefs filed in November (you can read them here) by the FCC (through the Solicitor General), the National Association of Broadcasters, and other broadcast industry parties.  The Court is set to hear oral arguments on January 19, 2021 and then issue a decision later in the year.  See our post on this case, here.

Comments are due by December 24 in two FCC proceedings.  The first proceeding is a proposal to enhance and standardize sponsorship identification requirements for broadcast programming that is paid for, or provided by, foreign governments or their representatives.  The proposed rules set out specific disclosure obligations to inform audiences of a foreign government’s influence over the programming to which they are listening or viewing.  Reply comments are due by January 25, 2021.

The second proceeding is an attempt to resolve an open question raised by the NAB about which licensee is legally responsible for the simulcasted programming from another licensee, including programming that airs on a host station’s subchannel as the ATSC 1.0 “lighthouse” signal of another station that has converted to NextGen TV (ATSC 3.0).  See our blog post, here, for more details.  Reply comments are due by January 25, 2021.

We are also expecting a Notice of Proposed Rulemaking from the FCC on the proposal to allow FM boosters to transmit limited amounts of programming different than that being broadcast on their primary station.  This “zonecasting” proposal would allow for different commercials or news reports to be broadcast in different parts of a station’s service area.  See our articles here and here on the initial FCC request for comments on this proposal.

The FCC may also adopt an order on its proposal to expand the use of television distributed transmission systems, as a draft item was circulated among FCC Commissioners for their review last week.  See our article here on the Notice of Proposed Rulemaking on this proposal adopted by the FCC earlier this year.

Be sure to check with your station counsel for more details about these dates and whether there are any other important dates this month applicable to your station’s operations.  We wish you a safe, healthy, and happy holiday season – but keep watching for additional regulatory matters that may arise as we count down the remaining days of this year (and as we anticipate the start of a new administration at the FCC in January).

This Week in Regulation for Broadcasters:  November 14, 2020 to November 20, 2020

Delivered... David Oxenford and Adam Sandler | Scene | Sun 22 Nov 2020 5:22 pm

Here are some of the regulatory developments of the last week of significance to broadcasters, with links to where you can go to find more information as to how these actions may affect your operations.

  • After reviewing comments submitted this summer (we wrote about the rulemaking, here), the FCC will vote at its next Open Meeting, on December 10, on new rules for Broadcast Internet (ATSC 3.0) services. The principal changes addressed in the FCC’s draft order are clarifications of the rules on the annual “ancillary and supplementary services” fee that broadcasters offering non-broadcast services on their television channels must pay.  The changes in the draft order include reducing the fees to be paid by noncommercial television stations that offer new noncommercial, non-broadcast services through their ATSC 3.0 operations.  These services are not allowed to “derogate” the broadcast service and, in the draft order, the Commission would retain its current interpretation that this means that a station must continue to offer at least one standard definition television programming channel.  (Draft Report and Order)
  • The FCC voted this week to update its rules dealing with cable programming disputes, including a clarification as to when a complaint can be made against a cable or satellite operator for alleged program carriage or retransmission consent violations. Under the old rules, such a complaint could be made up to one year after the cable and satellite operator was notified of the complaint.  Now, complaints can be made up to one year after the alleged violation, closing a loophole that potentially allowed complaints to be made for conduct that occurred years in the past.  The new rules will be effective 30 days after publication in the Federal Register.  (Report and Order)
  • The FCC and NAB submitted their briefs this week to the Supreme Court in the FCC v. Prometheus Radio Project case, in advance of oral arguments and a decision in 2021. Reply briefs on behalf of Prometheus Radio Project are due by December 16.  This case is a review of a lower court’s decision to reject the FCC’s 2017 broadcast ownership changes.  See our post, here, about the Supreme Court review.  (Court Docket)
  • In the last 10 days, two lawsuits by the Trump campaign alleging defamation against media entities, including the lawsuit against a Wisconsin television station for airing an attack ad by Priorities USA about the President’s response to the coronavirus, were dismissed. We wrote about those dismissals here, addressing the issues that these actions highlight for broadcasters who run attack ads that are not sponsored by a candidate’s campaign committee.

Expected to be released soon, possibly this week, will be an FCC Notice of Proposed Rulemaking starting a proceeding looking to authorize FM boosters to transmit limited amounts of programming different than that being broadcast on their primary station.  This “zonecasting” proposal would allow for different commercials or news reports to be broadcast in different parts of a station’s service area.  See our articles here and here on the initial FCC request for comments on this proposal.


Two Trump Defamation Claims Dismissed Including Claim Against TV Station for Political Attack Ad – What is the Relevance for Broadcasters? 

Delivered... David Oxenford | Scene | Wed 18 Nov 2020 4:56 pm

In the last few days, two defamation cases filed against media companies by the Trump campaign have been dismissed – one on the merits and one by agreement of the parties.  This includes the suit filed by the campaign against Northland Television, the licensee of a rural Wisconsin television station.  That station was perhaps the smallest TV station to air an ad by a non-candidate group, Priorities USA, that the Trump campaign alleged was misleadingly edited to assert that the President had labeled the coronavirus a “hoax.”  As we wrote here when that suit was first filed, the campaign claimed that the reference to the hoax was not about the virus itself but was actually a reference to “the Democrats’ exploitation of a pandemic and related characterization of the candidate’s response to the pandemic.”  This suit was vigorously opposed by the station and the sponsor of the ad.  The parties have now agreed to voluntarily dismiss that suit with prejudice, meaning that it cannot be refiled.

Another suit was brought by the campaign against CNN alleging that CNN had libeled the President by publishing on its website an article from one of its contributors who alleged that the campaign had assessed the risks of seeking Russian assistance in the 2020 campaign and had “decided to leave that option on the table.”  The campaign alleged that the statement was false and defamatory – and published with knowledge that it was false.  CNN had countered that the statement was protected as it was presented as opinion, not fact, and moreover it was published without “actual malice.”  As we have written before (see, for instance, our articles here and here), under Supreme Court precedent, a claim about a public figure for defamation can only be sustained if it is both false and published with “actual malice” – meaning that the publisher knew that it was false, or acted with reckless disregard as to whether or not it was false and published it anyway.

In considering a motion to dismiss the claim against CNN, the court reviewed both whether the disputed claim from the article was opinion and therefore not subject to being found to be libelous, and the question of actual malice.  The Court first looked at whether the statement was framed as an opinion.  Statements framed as an opinion of the writer, as opposed to a factual assertion, are generally not libelous (see, for instance, our article here).  The court found that the article could be read as making a factual statement that the President’s campaign was still considering seeking Russian assistance in the 2020 election. Moreover, as the statement had not clearly been described as an opinion of the writer, but instead framed more as if it were a statement of fact, the court concluded that there were no grounds for dismissal based on the claim that the disputed statement was merely the opinion of the writer.

However, the court decided to dismiss the suit after concluding that there was no showing in the complaint of actual malice.  The court looked at the allegations made in the lawsuit that CNN and the writer must have known that the statement was false, given the Trump campaign’s unsupported assertion that there was “extensive public information” available at the time of publication to show that it was false.  The court found that there was nothing in the record supporting these conclusory statements as to what public information was available and whether the author had investigated that information.  Mere allegations that the author must have known the statement was false were insufficient to warrant a finding of malice, according to the court.  In addition, the court concluded that the mere fact that the author had, in the past, been a critic of the President did not show that there was actual malice in this case.  Nor did the general allegations that CNN itself was biased against the President constitute any showing of the actual malice needed to sustain the claim.

Without a showing that the claims were made with actual malice as defined by the courts, the case was dismissed.  But the process that the court undertook to review the claims is instructive for broadcasters in dealing with claims made in political issue advertising.  The decision reinforces some of the suggestions that we have made in the past as to how broadcasters need to deal with attack ads from non-candidate groups – and the cease and desist letters that may follow from the lawyers for the person being attacked.  See our articles here and here on this subject.  As a general matter, where a broadcaster has no knowledge of the truth or falsity of an ad when it begins to air that ad, the airing itself may not constitute actual malice.  But when the cease and desist letter arrives at the station pointing out the alleged falsity of statements made in the ad, then the risk generally increases that continued airing of the ad can more easily be alleged as having been done with actual malice.  The cease and desist letter can be seen as putting the broadcaster on notice that the ad’s claims may be false, so that continued airing without further inquiry by the broadcaster could be seen as being done with malice.  Thus, broadcasters must react quickly when such letters arrive and analyze the claims made.  This is a delicate analysis that broadcasters and other media companies must make throughout any political season, so be sure to have your lawyers on call to help you to evaluate such ads and quickly parse the claims as they come in.

Reminder – Lowest Unit Charges Do Apply to Run-Off Elections

Delivered... David Oxenford | Scene | Fri 6 Nov 2020 5:52 pm

Earlier this week, we wrote that the FCC issued a public notice stating that Lowest Unit Charges (or lowest unit rates as they are often called) do not apply to post-election political ads (e.g. ads that urge ballots to be counted in any particular manner).  One important caveat to that advice is that LUC does apply to any elections that are held based on outcomes that were not determinative on Tuesday’s Election Day.  So, for instance, the run-off election (or elections) for the US Senate from the state of Georgia, that will be held on January 5, 2021, have an LUC period that begins today, November 6 – 60 days before that run-off.  The 60-day period applies as the run-off is considered by the FCC to be another general election.  Other states have similar rules for run-offs where no candidate receives 50% of the vote.  So if there are run-offs in your service area in which candidates want to buy political advertising time, LUC will apply to those elections, and you will need to compute the appropriate period for during which candidates cannot be charged more than the lowest unit charge for commercial advertising of the same class that runs in the same time period.

FCC Makes Clear that Lowest Unit Charges for Candidate Ads Ends on Election Day

Delivered... David Oxenford | Scene | Tue 3 Nov 2020 8:59 pm

The FCC yesterday released a Public Notice making clear that lowest unit rates (or lowest unit charges) end on Election Day.  Some broadcasters had asked the question, fearful that there would be political advertising bought after Election Day to take positions on issues about counting the vote and other legal matters that could arise in a contested election and, if that advertising was bought by the campaign committees of those standing for election today, lowest unit rates would still be in effect.  But the FCC made clear that Section 315 of the Communications Act, which requires that these rates be afforded to candidates, means what it says – that these rates apply only in the 60 days before a general election (and the 45 days before a political primary).  In a 1978 decision, the FCC stated that selling political ads on Election Day itself was discretionary by the station (they did not need to sell ads on Election Day – in fact, at least in the past, some states actually prohibited those ads), but if they did, they needed to sell at LUC.  In effect, that added a 61st day to the LUC period.  But, as yesterday’s Public Notice makes clear, the low rates do not extend beyond Election Day itself.

Other questions have arisen as to whether any of the other political rules (e.g., reasonable access, no censorship, equal opportunities) extend beyond Election Day.  While the Public Notice is silent on those questions, it would seem that, consistent with the precedent, they would not.   In one old case, the FCC held that equal opportunities for a person running for the Republican nomination for president ended after the party’s convention has already taken place, seemingly showing that the candidacy ends when the terminal event in an election has taken place.  Similarly, the FCC stated in a public notice in the 1970s that reasonable access clearly applied in the LUC windows before an election (and that other access before those windows would be judged on a case-by-case basis).  The ruling on LUC applying to Election Day seemed to recognize that Election Day sales were discretionary (“where licensees sell time to candidates on election day, the lowest unit charge would be applicable on that day”).  None of these cases suggest that any access would apply afterward.  That would seem to make sense as all of these rules were adopted so that candidates can persuade voters to vote for them.  After an election, any advertising pitches would not be made to persuade voters to vote, but instead would be asking that legislatures, judges or other government agencies act in a particular manner – more typical of an issue ad.  An issue ad on a federal issue does have public file obligations (as yesterday’s Public Notice makes clear – and see our articles here and here on those requirements).  Obviously, while the precedent seems to lead to one conclusion, these questions have not been addressed squarely by the FCC, and we will wait for tonight’s election results to see if any of them become relevant to tomorrow’s reality.

More FCC Consent Decrees for Political File Violations – Issues to Watch in the Last Weeks of the Election

Delivered... David Oxenford | Scene | Fri 16 Oct 2020 5:14 pm

As the campaign enters its final weeks, the FCC has begun to send out the next round of proposed consent decrees to radio broadcasters unable to certify in their license renewal applications, because of perceived deficiencies in their political file, that that every document was placed into their FCC-hosted online public inspection file on a timely basis (see, for instance, this decree released yesterday).  The certification of public file compliance is required of every applicant for license renewal.  As with any other certification, a licensee must review its records and truthfully answer the application’s question, either certifying that it has complied with all of the public file obligations or disclosing any deficiencies.  As we wrote last year, in cases of substantial noncompliance, the FCC has fined stations that essentially ignored the public file rules.  But, until recently, in cases where a station had made a good faith effort to comply but had some minor deficiencies in the public file (as is natural over an eight-year renewal period), the FCC has generally been granting renewals, acknowledging that minor violations do not signal that a broadcaster is not operating in the public interest.  However, in August, the Commission initiated a new policy for stations that reported deficiencies in the political portion of the public inspection file, sending draft consent decrees to virtually all stations unable to certify full public file compliance because of any political file issue.

These consent decrees were modeled on the ones that were sent in July to six large radio broadcast groups as a result of an earlier FCC review of their political files (see our article here on those consent decrees, which also provides a review of a broadcaster’s political file obligations).  The difference is, of course, that the July decrees went to large radio groups for what the FCC described as hundreds of violations at many radio stations.  The new renewal-driven consent decrees were sent to all stations that did not certify political file compliance, even to stations that had only a handful of political advertising sales if those stations determined that they could not certify that all required documents went into the file in a timely fashion.  While the decrees carry no monetary fine, they do require that the signing station enter into a compliance program – appointing a compliance officer, having a written compliance plan, reporting any violations to the FCC as they occur, and providing a report to the FCC at the end of each calendar year for two years cataloging all political sales and when the required documents went into the political file.

After the first round of these decrees were sent in August to over 100 broadcasters from the first year’s radio license renewal groups who could not certify compliance because of political file issues, discussions were held with the FCC about the scope of the decrees.  The FCC recognized that there were some cases where violations were so minor that they did not warrant imposing the compliance burden demanded by the decrees.  The Commission has informally said that where, in the two years prior to the filing of the license renewal application, a station had 5 or fewer instances where political orders were not timely uploaded to the public file, upon request after the receipt of the draft consent decree, a licensee could be excused from having to sign the decree as a condition of their license renewal.  A significant number of smaller stations and larger stations with isolated instances where the uploads were not made on a timely basis, have since been excused from having to enter into these consent decrees.

Even this exception for minor violations does not excuse a station from initially reporting in its renewal that its file was incomplete.  Nor does the Commission’s current policy signal that it will continue to provide in the future this exception for what they term “de minimis” violations.  Instead, these decrees, together with the decrees entered into with the larger radio operators earlier in the year, and the admonitions issued to TV stations for political file violations on disclosures on issue ads (see our articles hereherehere and here), signal the importance that the FCC places on the political file.  Broadcasters should consult their own counsel about any compliance issues that they have in these areas, as this area is particularly complicated with detailed reporting obligations.  Our article on the large radio group consent decrees provides some guidelines for political file compliance, as does this video that I hosted for the Indiana Broadcasters Association on the political file obligations. Do all you can to educate yourself as to the obligations under the FCC’s rules and policies.  The FCC is watching – so take these obligations very seriously.

A Video Summary of the Rules on Lowest Unit Rates and Other Political Broadcasting Resources

Delivered... David Oxenford | Scene | Thu 1 Oct 2020 5:07 pm

Back in August, we highlighted some of the many issues in computing lowest unit charges (or “lowest unit rates”) for political candidates which are in effect during the window for the November elections that went into effect on September 4.  In this last month before the election, as political advertising ramps up and each party fights over those few undecided viewers, we wanted to bring to your attention a video that I did for the Indiana Broadcasters Association discussing the various issues that arise in determining lowest unit rates.  That video summarizes many of the issues that we wrote about back in August and is available here:

At the end of this article, we provide links to other videos produced by the Indiana Broadcasters discussing other political broadcasting issues, and to other articles that we have written on other political broadcasting issues.

As we wrote back in August, lowest unit charges (or “Lowest Unit Rates”) guarantee that, in the 45 days before a primary and the 60 days before a general election, legally qualified candidates get the lowest rate for a spot that is then running on the station within any class of advertising time running in any particular daypart. Candidates also get the benefit of all volume discounts without having to buy in volume – i.e., the candidate gets the same rate for buying one spot as your most favored advertiser gets for buying hundreds of spots of the same class. But there are many other aspects to the lowest unit rates, and stations need to be sure that they get these rules right.

It is a common misperception that a station has one lowest unit rate, when in fact almost every station will have several – if not dozens – of lowest unit rates,with one lowest unit rate for each class of time in each daypart. Even at the smallest radio station, there are probably several different classes of advertising spots. For instance, there will be different rates for spots running in morning drive than for those spots that run in the middle of the night. Each time period for which the station charges a differing rate is a class of time that has its own lowest unit rate. On television stations, there are often classes based not only on daypart, but on the individual program. Similarly, if a station sells different rotations, each rotation that offers substantially different benefits to an advertiser will be its own class of time with its own lowest unit rates (e.g., a 6 AM to Noon rotation is a different class than a 6 AM to 6 PM rotation, and both are a different class from a 24-hour rotator – and each can have its own lowest unit rate). So, in the same time period (e.g., morning drive on a radio station), there may be spots running in that period that have multiple lowest unit rates (such as spots sold specifically for morning drive, as well as cheaper spots that were sold as part of a 6 AM to 6 PM rotation that just happened to fall within the morning drive period).  Federal candidates can buy into any of those classes of time, and they take the same chances as does a commercial advertiser as to where their spots will land (e.g., if a candidate buys a 6 AM to 6 PM rotator, and that rotator ends up in morning drive, another candidate may buy that same rotator the next week and end up at 4 PM. That second candidate can only guarantee that they will end up in morning drive by buying a spot guaranteed in that time period).

Even in the same time period, there can be preemptible and non-preemptible time, each with different costs, thus making them different classes of time, each with its own lowest unit rate. Any class of spots that run in a unique time period, with a unique rotation or unique rights attached to it (e.g., different levels of preemptibility, different make-good rights, etc.) will have a different lowest unit rate. Stations need to review each class of time sold on their station, find the lowest rate charged to a commercial advertiser for a spot of the same class that is running at the same time that the candidate wants to buy a spot, and make sure that lowest rate will be what the candidate is charged.

One question that still comes up with surprising regularity is whether these rates apply to state and local candidates, as well as federal candidates. Indeed they do – so if your station is running advertising for candidates for mayor or city council, or for governor or the state senate, or even for the board of education, municipal court judge, or state attorney general – they and any other candidate in any public election for which your station chooses to accept advertising gets lowest unit rates. See our past articles on this topic here and here.  Stations are not required to sell advertising time to state and local candidates, but if they do, lowest unit rates apply.

In modern political elections, where PACs, Super PACs and other non-candidate interest groups are buying a significant amount of political advertising time, broadcasters need to remember that these spots don’t require lowest unit rates. Even if the picture or recognizable voice of the candidate that the PAC is supporting appears in the ad, spots that are sponsored by an independent organization not authorized by the candidate do not get lowest unit rates (note, however, that spots purchased by independent groups featuring the voice or picture of the candidate may trigger public file and equal opportunities obligations for the station if the station decides to run those spots).  Under federal law, stations can charge these advertisers anything that the station wants for non-candidate ads – no need to stick to lowest unit rates.

From time to time stations may face the one exception to the above paragraph, where political buyers are requesting lowest unit charges and are authorized by a candidate. In these cases, these parties may in fact be entitled to these rates – but only where the spot includes the recognizable voice or picture of the candidate and the message is specifically authorized by the candidate.  Under federal law for federal candidates, these purchases will be by political parties and subject to political campaign donation limitations (known as “hard money”).  To get lowest unit rates, the advertising purchases must be authorized and “coordinated” with a candidate and, in federal races, the spots should make that coordination clear with the “I approved this message” tag.  While the FCC has not formally ruled on it, it appears that some states have similar state laws that allow third parties to buy spots that are authorized by a candidate and may be entitled to lowest unit rates. Talk to your own attorney if you are faced with that issue. Not all third-party spots are entitled to this treatment – only this special class of coordinated expenditures – and stations are entitled to get written confirmation from the candidate that the expenditures are coordinated under applicable election laws. If not coordinated, the parties get charged the same as any other third-party organization.

Various advertising sales packages, and how they are factored into lowest unit rate calculations, also seem to lead to many questions by broadcasters. Candidates cannot be forced to buy single-station packages to get lowest unit rates. Instead, the package must be broken down by the station into a price per spot for each class of spot that is contained in the package. That is done by allocating the package price to the various spots of each class that are contained in the package. Then the allocated rates, on a unit basis, are compared to other spots of the same class that have been sold on the station either on their own or in other packages to determine if the spots from this package have any impact on the station’s lowest unit rates. This allocation is done in an internal station record, which does not need to go into the public file and does not need to be revealed to the candidate. Other than the station, only the FCC will see this allocation if they decide to conduct some sort of audit. We wrote more about this process of allocating spots in a package here.

These are just some of the myriad issues that arise in computing lowest unit rates. Stations need to be familiar with these rules and apply them accurately through the lowest unit rate windows. Check with your own legal advisor to discuss the specifics of these issues as they arise as they are often very difficult to apply in the real world.  Some of the other situations that arise with lowest unit rates, and with other political issues that come up in any election season, are covered in our Political Broadcasting Guide, available here.

There are obviously many other issues that come up in the political broadcasting process.  The Indiana Broadcasters have produced several other videos in which I explain some of the basics of the political broadcasting rules.  These include:

Other articles that deal with other political broadcasting subjects can be found on our blog by clicking on these links:  equal opportunitiesreasonable access, the no-censorship provision that governs candidate ads, and the potential for station liability for untruthful statements made in third party ads.  Also, see our article here about the obligations for the political file required as part of the online public file, and the importance that the FCC puts on that file.  And our articles hereherehere and here on the new requirements for the identification in the public file of all the issues mentioned in any advertising on federal political issues or candidates.  All of these materials are just a summary of the basics in each of these areas.  The laws regarding political broadcasting are extremely complicated and legal conclusions are very fact-dependent so you need to talk to your own attorney for specific advice on situations that arise at your station.

October Regulatory Dates for Broadcasters: License Renewals, EEO Reports, Carriage Elections, Quarterly Issues/Programs Lists and More

Delivered... David Oxenford | Scene | Tue 29 Sep 2020 3:18 pm

In many parts of the country, the air is turning crisp, the leaves are changing color, and kids are back in school (in some form), making it the perfect time to get caught up with regulatory dates and deadlines coming in October.  This is an unusual month where there are several routine regulatory deadlines – renewals, EEO filings, Quarterly Issues Programs Lists, and the must-carry/retransmission consent deadline, but no significant broadcast rulemaking comment deadlines, perhaps as we are nearing the end of the current administration which might not be around to finish any proceeding started now.

The routine deadlines include those for radio stations in Iowa and Missouri and TV stations in Florida, Puerto Rico, and the U.S. Virgin Islands who should be putting the finishing touches on their license renewal applications, to be filed on or before October 1, along with the accompanying EEO program report.  Stations should also have their post-filing announcements ready and scheduled to begin airing on October 1.  Those announcements continue through December 16.  Stations are no longer required to air pre-filing announcements.  The schedule for post-filing announcements and sample announcement language is here for radio stations and here for TV stations.

Also due by October 1 are EEO public inspection file reports for stations in AlaskaFloridaHawaiiIowaMissouriOregonWashingtonAmerican SamoaGuamthe Mariana IslandsPuerto Rico, and the U.S. Virgin Islands that are part of a station employment unit with 5 of more full-time employees.  An employment unit is one or more commonly controlled stations in the same geographic area that share at least one employee.  By October 1, these reports are to be uploaded to the station’s FCC-hosted online public file and a link to that report needs to be placed on the homepage of the station’s website (if the station has a website).  If your station employment unit has fewer than five full-time employees, no report needs to be placed in your public file or on your website.

By October 1, television stations must elect must-carry or retransmission consent for multichannel video programming distributors (MVPD) that carry their signals.  Full-power and Class A TV stations must place in their online public inspection file by October 1 notice of whether they elect retransmission consent or must-carry carriage from their area’s MVPDs for the three-year cycle beginning on January 1, 2021 and ending December 31, 2023.  If the station has decided to change its election, it must notify the MVPD by email, to an address set out in the MVPD’s public file.  We summarized this new rule, here.

On or before October 10all TV and radio stations must upload to their public file their Quarterly Issues/Programs Lists for the 3rd quarter (July, August, and September).  The Quarterly Issues/Programs Lists are a station’s evidence of how it operated in the public interest, demonstrating its treatment of its community’s most significant issues.  As we have written previously, the FCC takes this requirement seriously and will fine stations, hold up granting license renewals, or both if it finds problems with a station’s compliance.  For a short video on complying with the Quarterly Issues/Programs List requirement, see here.

In advance of the FCC’s October 27 Open Meeting, we will be tracking any broadcast items that make it on the agenda.  Stay tuned to the blog throughout October for updates.

Looking ahead to early November, we note the closing of the general election lowest unit charge (LUC) window on November 3.  There has been a lot of media reporting suggesting that certain races—the presidential race being the highest profile—may not be decided by the 3rd or even the early hours of the 4th.  This situation could lead to campaigns continuing to advertise past November 3 to, for example, try to persuade state election officials to certify results, but there is no mechanism in federal law or the FCC’s rules to extend the LUC window past election day.  The only exception would be in those races that may have runoff elections occurring after November 3, which are considered new elections so that they would have their own 60-day LUC window.

These are just a few of the regulatory dates we are tracking for October and early November.  As always, read the blog and keep in close touch with your station’s counsel to be sure you are staying on top of the dates and deadlines that apply to your operation.


Noncommercial Broadcasters and the Political File

Delivered... David Oxenford | Scene | Fri 25 Sep 2020 12:43 pm

What are a noncommercial broadcaster’s obligations with respect to the political file and the rest of the FCC’s political broadcasting rules?  That is a question that I have heard asked several times in the last few weeks as we approach this most important, and contentious, election.  In short, I think that the answer to this question is that, in most cases, a noncommercial broadcaster will have few if any political file obligations.  Why?

Broadcast stations that are licensed as noncommercial do not have any reasonable access requirements.  What that means is that noncommercial stations do not have any obligation to sell time to political candidates or to make any free time available to the candidates for their messages.  Years ago, reasonable access did apply to noncommercial stations, but when a DC-area congressional candidate used the statutory reasonable access requirements to force a local NPR affiliate (to which many on Capitol Hill listened) to air political commercials, Congress acted to abolish the reasonable access requirement as it applied to noncommercial stations.  So, as noncommercial stations do not need to sell political time to candidates, they are not faced with the political file obligations which have triggered scrutiny from the FCC in recent months.  But that is not to say that there could never be a political file obligation for a noncommercial station.

Where an obligation could arise is when a candidate appears on a noncommercial station in a program that is not an “exempt program.” Exempt programs are programs that are not subject to the equal opportunities (or “equal time” as some call it) rule.  Broadcast stations must provide equal time to a candidate when an opposing candidate appears outside of an exempt program.  But that should rarely, if ever, occur on a noncommercial station.  Bona fide news and news interview programs are exempt programs and thus are exempt from equal time requirements – and the FCC has broadly construed those exemptions.  On-the-spot coverage of a news event is also exempt(see our articles here, here and here for more on these exemptions).  Candidate appearances on these exempt programs do not trigger equal opportunities, and they also do not require any political file entries.

Theoretically, the appearance of a candidate on a non-exempt program could trigger equal opportunities and require public file disclosures.  For a noncommercial station, it would seem like that is most likely to occur when an on-air station employee or volunteer decides to run for political office.  Just as with commercial stations, when an employee becomes a legally qualified candidate for office, every time they appear on the air (even if they are performing their regular on-air duties and not mentioning their campaign), their appearance is a “use” by a candidate subject to equal opportunities and political file obligations.  See our article here about employee-candidates and what can be done if a station’s employees decide to run for office.

Similarly, if a candidate appears in other programming on the station that is not “exempt,” then political file obligations could occur.  Watch for PSAs that feature local government officials who are running for re-election or for other offices, as these can give rise to public file and equal opportunities requirements (see our article here that expands on this warning).  A candidate appearance on some enhanced underwriting spot – even if the spot has nothing to do with their campaign – could also trigger the political rules (see our article here about how commercial stations should treat appearances by candidates in advertising for their businesses).  Or candidate appearances on some purely entertainment programs could trigger equal opportunities (e.g. when Ronald Reagan and Arnold Schwarzenegger ran for political office, their movies could not be shown on television without triggering equal time and public file obligations).

These situations are likely to be few – but be alert and make sure that your noncommercial station does not inadvertently trigger one of these situations where it needs to make entries in its political file about candidate appearances on the stations.

A TV Broadcaster’s Guide to Washington Legal Issues – An Update on Where Things Stand

Delivered... David Oxenford | Scene | Tue 22 Sep 2020 4:12 pm

Where do all the Washington DC legal issues facing TV broadcasters stand? While we try on this Blog to write about many of those issues, we can’t always address everything that is happening. Every few months, my partner David O’Connor and I update a list of the legal and regulatory issues facing TV broadcasters. That list of issues is published by TVNewsCheck and the latest version, published today, is available on their website, here. It provides a summary of the status of legal and regulatory issues ranging from the adoption of the ATSC 3.0 standard at one end of the alphabet to White Spaces and Wireless Microphones on the other – with summaries of other issues including the many actions that the FCC took in response to the pandemic to the more traditional issues including Ownership Rule Changes, Children’s Television, Media Regulation Modernization, EEO CompliancePolitical Advertising, Sponsorship Identification and dozens of other topics, many with links to more detailed discussions here on the Blog. The article is an easy place to go to see where, as of last week when we finished writing the article, legal matters related to TV broadcasting stand.  Of course, the status of these issues changes almost daily, so watch this Blog and other trade publications, and consult your own legal counsel, for the latest Washington news of interest to broadcasters.

This Week in Regulation for Broadcasters: September 12, 2020 to September 18, 2020

Delivered... David Oxenford | Scene | Sat 19 Sep 2020 7:41 pm

Here are some of the regulatory and legal actions and developments of the last week of significance to broadcasters, with links to where you can go to find more information as to how these actions may affect your operations.

  • Political advertising will continue to blanket the airwaves for the next month and a half and broadcasters need to remain vigilant in complying with all political advertising rules and obligations. We wrote on the blog this week about some of the sponsorship identification issues broadcasters should look out for, especially as busy station staffers are dealing with more orders and more ad copy.  (Broadcast Law Blog)
  • President Trump nominated Nathan Simington to fill FCC Commissioner Michael O’Rielly’s soon-to-be vacated seat. Simington currently serves as senior advisor at the National Telecommunications and Information Administration (NTIA) and is said to have worked on NTIA’s petition asking the FCC to review Section 230 of the Communications Decency Act of 1996, which gives online platforms broad immunity from what users post on those platforms.  O’Rielly’s re-nomination is believed to have been withdrawn over his public comments expressing legal concerns over the President Trump’s desire that the FCC take steps to limit this immunity.  O’Rielly can serve through the end of this year or until Simington is confirmed by the Senate, whichever comes first.  We wrote about O’Rielly’s nomination troubles and Section 230, here.  O’Rielly testified before the House Communications Subcommittee and used his opening remarks to reflect on his time at the Commission.  (O’Rielly Remarks).
  • Chairman Ajit Pai circulated among his fellow Commissioners a Notice of Proposed Rulemaking that would, if adopted, require more specific disclosure when a broadcast station is airing programming that is directly or indirectly provided or sponsored by a foreign governmental entity. The new rules would include standardized disclosure language that specifically identifies the sponsoring foreign entity.  (News Release)
  • A recent consent decree serves as a reminder that changes to ownership and control of broadcast licenses require prior FCC approval. The licensee of two Nevada stations failed to request approval of a buy/sell and stock purchase agreement that gave another party control of the stations.  Under the terms of the consent decree, the transaction will be approved, but the licensee must pay an $8,000 penalty and follow a compliance plan for three years.  (Order)
  • The FCC denied an Application for Review that sought to reverse the Media Bureau’s ruling that eighteen stations had failed to negotiate in good faith with DirecTV for retransmission consent. Each station faces a $512,228 penalty.  We wrote about the earlier stages of this case and generally about the good faith negotiation requirement, here. (Memorandum Opinion and Order and Notice of Apparent Liability for Forfeiture)

This summary of the week’s regulatory news for broadcasters comes from the attorneys at Wilkinson Barker Knauer, LLP in Washington, DC. (https://www.wbklaw.com/).

Sponsorship of Political Advertising On-Air and On-Line – A Video Presentation and a Congressional Research Service Study

Delivered... David Oxenford | Scene | Fri 18 Sep 2020 4:28 am

Now that we are immersed in the heart of the political broadcasting season, issues of sponsorship identification regularly arise.  For on-air broadcasts, any paid advertisement that conveys a message dealing with any controversial issue of public importance (state or federal) requires at a minimum an on-air sponsorship identification stating that the ad was “paid for” or “sponsored by” the person or organization that paid for the time.  Federal candidates have a more extensive obligation for identifying themselves in their ads, particularly if they mention an opposing candidate.  These identification rules come both from the FCC (which stations need to enforce) and from the Federal Election Commission, which are the responsibility of the candidate and their campaign committee.  To help sort out some of these obligations, and the requirements for political disclosure statements and federal candidate certifications that entitle them to lowest unit rates, check out this video that I prepared for the Indiana Broadcasters Association as part of a series on political broadcasting topics:  https://www.indianabroadcasters.org/iba-news/political-advertising-requirements-with-iba-washington-counsel-david-oxenford/

The video covers the requirements of broadcasters to ensure that the proper sponsorship identification is contained in political advertising.  Online political advertising, however, is much more complicated as there is no single body of law that governs those responsibilities.  As we wrote here, the FEC has general requirements providing that online political advertising must have sponsorship identification. The FEC also has an open proceeding to mandate more stringent sponsorship identification obligations akin to those required on broadcast and local cable political advertising.  Last week, the Congressional Research Service issued a study on the state of the law regarding online political advertising, highlighting the many issues involved in providing more robust political disclosures.  These issues are at least partially triggered by the many players involved in online advertising sales.  There is a very readable outline on pages 16-19 of the report on all the players in the digital advertising ecosystem – with intermediaries, including demand- and supply-side platforms, that complicate the usual direct interaction between the media outlet and the advertising buyer, which in turn complicates the political compliance process for sponsorship identification.  The study, on page 18, even cites to the article that I wrote discussing the concerns about sponsorship identification in any programmatic political advertising.

The CRS report covers many of the pending federal legislative proposals to address concerns about political advertising disclosures.  While it is a very readable and comprehensive review of the current federal sponsorship identification obligations (and of some of the ambiguities in federal rules for online political advertising), the CRS report does not provide a review of some of the industry codes of practice and state regulations that have attempted to address the lack of uniform federal obligations for online political sponsorship identification.  We wrote here about the early days of the New York and Washington State political advertising regulations that govern online political advertising, and these state regulations have become even more detailed in recent years as implementing regulations have been adopted.  California, Virginia, Nevada and several other states have also adopted rules requiring that political sellers know their customers and provide some public disclosure about the sponsors of online political messages.  So, too, have various trade organizations adopted voluntary principles governing online political advertising sponsorship disclosures, including the Digital Advertising Alliance’s Application of Self-Regulatory Principles of Transparency and Accountability to Political Advertising and the Network Advertising Initiative’s Code of Conduct.

In advising clients during this busy election year, we have discovered that these voluntary codes of conduct and state regulations have made for a very confusing legal landscape for digital political advertising.  None of these rule and laws are the same – they do not even work off the same models.  All of them place burdens on political advertisers, and some impose burdens on the media platforms (although see the decision we wrote about here where a Maryland statute putting disclosure burdens on the platforms was declared unconstitutional).  Other laws are ambiguous as to where the legal obligations lay.  This may be why we have seen calls by some of the biggest online platforms, including Facebook, for federal legislation to make the rules of the road uniform and transparent.  Given the current legislative climate and the short timeline before the election and the end of the current Congressional session, the prospects of such federal legislation being enacted soon are probably dim. Until then, digital platforms selling online political advertising need to study these differing regulatory schemes to avoid becoming part of some controversy over hidden political persuasion taking place on their services.

This Week in Regulation for Broadcasters: August 29, 2020 to September 4, 2020

Delivered... David Oxenford | Scene | Mon 7 Sep 2020 4:08 pm

Here are some of the regulatory and legal actions and developments of the last week of significance to broadcasters, with links to where you can go to find more information as to how these actions may affect your operations.

  • The FCC released its Report and Order on annual regulatory fees for fiscal year 2020 and, over objections from the NAB, declined to substantially reduce radio regulatory fees, keeping in place its calculation methodology that results in a net increase from 2019 in fees assessed to radio broadcasters (a computational error led to a minor downward adjustment in radio fees from what the FCC set out earlier in the 2020 fee process). The FCC also declined to change its methodology for calculating television fees, transitioning fully to a population-based methodology.  The Commission did acknowledge the hardships stations are facing during the pandemic and has taken steps to provide relief.  That relief for stations that can demonstrate financial hardship includes allowing stations to submit one request seeking a fee waiver and deferral of payment for hardship reasons instead of two separate requests as generally required by the Commission rules; allowing stations to submit by email a request to pay their fees in installments over time at a low interest rate; and directing Commission staff to work closely with and help stations finding it difficult to produce supporting documents that prove financial hardship caused by the virus.  See our post at the Broadcast Law Blog for a deeper look at the Report and Order and see below for links to Public Notices with details about how to pay your fees and how to seek relief, all due by 11:59 p.m. on September 25.  More information and specific fact sheets for the Media Bureau payees will be posted at gov/RegFees.
  • In what could be one of the last steps before opening a noncommercial FM filing window, the FCC denied a Petition for Reconsideration asking it to reexamine the criteria it uses to determine which noncommercial FM application should be granted. Under the current system, when more than one application is submitted, points are awarded to applicants based on certain favored criteria and the applicant with the most points wins.  In the Order, the FCC refused to consider “secondary” grants after the first one is awarded.  For more on how the points system and the “secondary” grants idea would play out and why the FCC declined to change its application evaluation and selection process, read our blog post here.  (Order on Reconsideration)
  • Over the last few weeks, the FCC’s Media Bureau has proposed consent decrees with a large number of radio licensees over their inability to certify on their license renewal applications that they timely uploaded to their online public file all of their political advertising documents (we wrote about the first six of these consent decrees, that were with large companies, here). This coming week watch for an article on our blog about these new consent decrees, and what it means for stations that have not yet filed their license renewal applications.
  • On September 4, the lowest unit charge window opened for the November 3 general election. For more on complying with and calculating lowest unit charges, see our blog post.
  • Comments were due this week on the National Telecommunications and Information Administration’s (NTIA) Petition for Rulemaking asking the FCC to review its interpretation of Section 230 of the Communications Decency Act.  Section 230, which gives online platforms legal protections from liability for content that third-party users post on those platforms, has drawn intense scrutiny from President Trump.  Reply comments are due by September 17.  You can read more about this in our monthly feature of regulatory dates.  (Comments)

Next week, we will be watching for the following to see if any actions affecting broadcasters will be on the agenda at the next FCC meeting:

  • On September 8, we expect Chairman Pai to publish a blog post outlining what the FCC will consider at its September 30 open meeting. Drafts of the items to be considered should be posted September 9 on the meeting webpage.


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