Broadcast renewal form still in flux following OMB approval
In reporting on the OMB’s approval of the New and Improved Form 303-S, we mentioned that, according to the FCC, the certification concerning non-discrimination in advertising would not appear when the form was being filled out by a noncommercial licensee. The form would be smart enough to know not to bother to present the certification option to a noncom applicant, since that option would theoretically be irrelevant to noncoms. Schweet!!!
Oops. It turns out that, even though that’s what the Commission told OMB, that’s not the way it’s going to work. The Commission has instead chosen to do it the old-fashioned way, i.e., by providing an “N/A” (for “not applicable”) option for NCE respondents. It seems that the fancy now-you-see-now-you-don’t approach to the certification would have required more tinkering with CDBS than the Commission was willing to undertake . . . particularly in view of the fact that the Commission is looking to phase CDBS out as part of a wholesale overhaul of its electronic systems over the next couple of years. No need to trick out the old Datsun if you're going to be trading it in on a Volt pretty soon.
So despite what the Commission told OMB in the initial go-around, the new form (when it’s unleashed in the near future) will include the classic “N/A” option relative to noncommercial applicants.
Look for a public notice from the Commission addressing the overall renewal process (including the New and Improved Form 303-S) in the near future.