Harry Cole

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The primary focus of Mr. Cole’s practice is broadcasting, including transactional, regulatory and appellate work. He has represented clients before the FCC and in various courts, including the U.S. Supreme Court.

Articles By This Author

Finally Bringing Broadcast Contest Rules into the 21st Century?

Three years in the making, a notice of proposed rulemaking would give the thumbs up to online contest rules.

Big News! The Commission has taken the unusual step of proposing a rule revision requested by broadcasters and of potential benefit to broadcasters, both TV and radio! The on-air contest rule – Section 73.1216 – is up for a long-overdue overhaul. And while there may be plenty to criticize in the FCC’s less-than-prompt attention here, let’s not focus on that just now. Instead, let’s take a look at how the Commission figures to make broadcasters’ lives a little better.

As we have reported previously, the contest rule requires (among other things) periodic on-air disclosure of all material elements of the contest. You can find some examples of the rule in action here, here and here. For many contests, that imposes a considerable burden on both stations (who must be sure to intone the rules on the air, often at auctioneer speed – or scroll them in infinitesimal print – regardless of how much that can interrupt program flow) and audience members (who have to suffer through the interruptions).

Nearly three years ago, Entercom filed a petition for rulemaking advancing an unquestionably reasonable proposal: instead of the over-the-air requirement, why not let broadcasters post contest rules on their websites (or, if a broadcaster doesn’t happen to have a website, on a state broadcast association site) for all the world to read whenever all the world happens to want to read them? As Entercom put it, this would be consistent with “how the majority of Americans access and consume information in the 21st century.”

The Commission is now on board with the idea.

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New Fast Lane in Open Internet Proceeding

FCC provides “bulk upload” option for adding even more comments to the million-plus already on file – now who’s going to read them all?

When last we took a sounding of the rising floodwaters of net neutrality comments, they were 1.1 million deep and more were pouring in. That was a month ago and, we’re pleased to report, the levees have apparently held. At least we assume that to be the case because the FCC has just announced, in effect, that it’s opening the dam upstream in an apparent effort to increase the flow of incoming comments.

In a blog post on the FCC’s website, the Commission’s Chief Information Officer advises that

[i]n the Commission’s embrace of Open Data and a commitment to openness and transparency throughout the Open Internet proceedings, the FCC is making available a Comma Separated Values (CSV) file for bulk upload of comments given the exceptional public interest.

If we’re understanding that correctly, the Commission is offering an express lane for the simultaneous submission of multiple comments (i.e., “bulk uploads”) to get them in the door even faster than might otherwise be the case. The need for that express lane isn’t immediately obvious: a quick spot-check in ECFS indicates that, since mid-August, comments have been flowing in smoothly, generally several thousand (occasionally more than 10,000) a day. With bulk uploads now available, we can look for that to increase.

But necessary or not, this development brings us back to something we have addressed before.

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Issue-Oriented Spots: Who's The REAL Sponsor?

Bureau tosses two complaints alleging inadequate sponsorship IDs – but that may not be good news in the long run.

Several months ago we reported on complaints filed against a dozen or so TV stations with respect to the stations’ alleged failure to include in their online political files all of the various detailed information required by applicable political advertising laws. We expected that that was just an opening salvo.

Turns out we were right.

The same two complainants (this time joined by a third compadre) have since filed a couple more, based not on the political rules, but rather on the more general sponsorship identification requirements of Section 317 of the Communications Act.

The Media Bureau has already turned away those two complaints. BUT it left the door wide open for more. And, unfortunately, in so doing the Bureau provided little if any useful guidance for broadcasters, but considerable encouragement for complainants. As a result, we can expect to see more such complaints rolling in.

The recently-tossed complaints were filed by the Campaign Legal Center and the Sunshine Foundation (the folks who had filed the complaints we reported on last May), along with Common Cause. One was directed to Station KGW(TV), Portland, Oregon, the other to WJLA-TV, Washington, D.C. In each case the station had run a flight of spots paid for by a “Super PAC”. (In KGW’s case, the PAC was the American Principles Fund; in WJLA’s it was the NextGen Climate Action Committee.) The spots all included sponsorship ID’s identifying the respective PAC.

But, according to the complainants, that wasn’t enough.

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2014 Reg Fees Set, Payment Deadline Announced

 Fire up your computer, free up some space on your credit cards and get your FRN information ready – you’ve got until SEPTEMBER 23, 2014 to get your reg fees paid … and they must be paid electronically.

Apparently intent on re-defining the terms “last minute” and “eleventh hour”, the Commission opted to wait until late on the afternoon of August 29 before it announced the final 2014 regulatory fees. For those of you anxious to cut to the chase, here’s a link to a convenient table setting out the new fees for broadcast-related services. (The table also provides, for TV-related services, comparisons of the 2014 fees against last year’s fees.)

Presumably because its adoption of the 2014 fees has come so late in the government’s fiscal year, the Commission has also taken the unusual step of simultaneously announcing the deadline for reg fee payments. That would be 11:59 p.m. (ET) on September 23, 2014.

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Update: Reply Comment Deadline Extended in Net Neutrality Proceeding

The comment total is already past 1,100,000, but who’s counting?

Really, would it be possible to get too many net neutrality comments? As if.

So we’re pleased to report that the FCC has extended the deadline for filing reply comments by five days. The new deadline is September 15, 2014.

The original reply deadline was September 10, but the Commission was concerned because, as we all remember, the initial comment deadline got extended from July 15 to July 18 (because the Commission’s online filing system was, um, choking a bit on the volume of comments being filed). Since initial commenters got an extra three days, figured the FCC, reply commenters should get the same. And since a three-day extension would plunk the deadline onto a Saturday, everybody gets an extra two days, taking the deadline to the following Monday.

So if you were sweating about getting your reply wrapped up in time, you can totally chill.

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Coming Soon: Online Public File Obligations for Cable, Satellite . . . AND Radio?

Media Bureau solicits comments on very recent petition for rulemaking – and expands inquiry beyond the petition.

Well, that didn’t take long . . . on a couple of levels. The Media Bureau has requested comments on a proposal to impose online public file requirements on cable and satellite operators. And the Bureau has gone the proponents one big step further by suggesting that radio stations as well should be posting their public files online.

The notion of online public files is, of course, of relatively recent vintage. Since August, 2012, TV stations have been required to post most of their public files to the FCC-maintained online system. Political file information was initially required to be posted only by Top Four network licensees in the top 50 markets . . . until July 1 of this year (yes, just a tad more than a month ago), at which time all commercial TV licensees joined the club. If you’re at all fuzzy on the history of the online public file, click here and just keep scrolling – we followed the whole process pretty closely.

Given the long gestation of the TV online public file, some observers (well, us, at least) expected that the FCC might let things settle down for a minute or two.

Surprise, surprise.

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What a Drag It Is . . .

Nearly 50 years I sat in my dorm room at Smith College (yes, Smith – it’s a long story), writing history papers while listening to Let It Bleed cranked up to 11 through my headphones.

Those were the days.

So it was more than a little sobering to read the first paragraph of a recent D.C. Circuit opinion. Written by Judge Janice Rogers Brown, the opinion in Stop This Insanity, Inc. v. FEC begins:

What does it say when your enfant terrible role model – Mr. Let’s Spend the Night Together, Mr. Sympathy for the Devil, Mr. “Let’s hire Hell’s Angels to be our security guards for $500 worth of beer” – has become source material for the D.C. Circuit, and “iconic” source material, at that?

For sure, it says that, as Mick knew all along, time was on his side.

For the rest of us, it says that getting old is . . . well, to borrow another Mick-ism, it’s a bitch.

But let’s put our hands together for Judge Brown. By dipping into the Stones songbook for a right-on reference that is immediately accessible, she demonstrated that effective legal writing does not require arcane Latin phrases or erudite polysyllables to get the point across. To the contrary, sometimes you need look no farther than your vinyl collection to come up with a righteous, and comprehensible, turn of phrase.

So here’s to you, Your Honor – you may not have blown our noses, but for sure, you blew our minds.

Aereo Loses First Round in Copyright Office, While Dish Wins its Next Round in the Ninth Circuit

More developments in the realm of Internet retransmission of OTA signals.

Aereo – the gift that keeps on giving, at least when it comes to blogworthy content. As we reported, after it got its clock cleaned at the Supreme Court, Aereo bounced back with Plan B, which amounted to declaring itself (a) a cable system and, thus, (b) eligible for the compulsory copyright license granted to cable systems. But you can’t just say “I’m a cable system” and expect anybody to believe you. So Aereo went ahead with some of the paperwork required of f’real cable operators; among other things, it filed a bunch (14, to be exact) of Statements of Accounts with the U.S. Copyright Office, along with some royalty and fee payments amounting to the princely sum of $5,310.74.

A nice gesture, but wouldn’t you know it, the Copyright Office (CO) was not inclined to play along with the gambit. In a brief letter dated July 16, 2014, the CO let Aereo know that, as far as the CO is concerned, Aereo is not a cable system entitled to the compulsory license. As it turns out, more than a decade ago the CO had concluded that “internet retransmission of broadcast television fall outside the scope” of the compulsory license. That’s bad news for Aereo, whose system is firmly – indeed, exclusively – based on Internet retransmission.

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INCOMING! Commission's Net Neutrality Comment Conundrum

As comments pile up in the Open Internet proceeding, straining the FCC’s systems, a post on the Commission’s blog got us thinking about transparency.

On July 14, 2014 – the day before the original deadline for initial comments in the Open Internet (a/k/a Net Neutrality) proceeding – in the spirit of transparency the FCC’s Chief Information Officer took to the Commission’s blog to tout the agency’s ability to track the numbers of comments flooding in over the transom. According to a couple of files linked in his post, the Commission had received nearly 170,000 Net Neutrality comments submitted electronically through ECFS (the FCC's online filing system), and another 442,000 or so by email. Those numbers are a moving target, though, and the target is only moving up: according to a post on ArsTechnica, by 11:00 a.m. on July 15, the tally was up to about 670,000.

It will doubtless go well beyond that, once ECFS comes back to life. The ArsTechnica post indicates that ECFS had crashed; our own observations here in the CommLawBlog bunker lent credence to that report, although the FCC conceded only that the “overwhelming surge” in traffic has “ma[de] it difficult” for some folks to file. As a result, the deadline for filing Net Neutrality comments has been extended to “midnight Friday, July 18”. (BTW – we confirmed with the FCC that they mean 11:59 p.m. (ET) on July 18.)

Keeping track of the influx of comments is presumably useful at some level, and the FCC’s ability to do so – apparently even on an hour-by-hour basis – is to be commended. But that ability is of, at best, secondary interest. When Katrina struck New Orleans, local residents may have been interested in precisely how much water was coming over the levees, whether by the minute or the hour or the day. But they were certainly more interested in how that water, however much water there was, was going to be disposed of.

Which brings us to some back-of-the-hand calculations.

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It's ALIVE!!!! Aereo Lurches Back to Life, Sort of

Trying to make lemonade out of the lemon handed to it by the Supreme Court, Aereo has come up with Plan B.

The best stories never really end when you think they’re going to, do they? There’s always a nifty twist that keeps the plot chugging along.

So we really didn’t expect that the Supreme Court’s decision was the last word in the Aereo case, did we?

And right we were.

After pulling the plug on its service within a couple of days after taking a seeming knock-out punch from the Supreme Court, Aereo has come up with a plan. According to a letter filed by Aereo with Judge Alison Nathan of the U.S. District Court for the Southern District of New York (where the Aereo saga first got our attention back in 2012), Aereo is now a cable company that is entitled – by Congress, thank you very much – to retransmit over-the-air broadcast programming. As long, that is, as Aereo files the necessary “statements of account” and “royalty fees”required of cable systems. And in its letter Aereo advises that it “is proceeding” to file just those items.

Following the adage about making lemonade when handed lemons, Aereo has taken the Supreme Court’s decision and tried to turn it to Aereo’s advantage. Since the Supremes said that Aereo is “highly similar” to a conventional cable company, well then (according to Aereo), Aereo is a cable system and, therefore, “is entitled to a license” under Section 111 of the Copyright Act.

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Older Entries

July 6, 2014 — FCC Seeks Input on EAS Fixes

June 25, 2014 — Aereo Update: Supreme Court Rules for Broadcasters!

June 14, 2014 — 2014 Reg Fees Proposed: Good News for Radio, VHF TV; UHF TV, Not So Much

June 4, 2014 — Update: Revised CALM Act Rules Adopted

May 14, 2014 — An Anchor's Reminder About the Importance of Broadcast Emergency Alerts

May 6, 2014 — Drone Update: While FAA Continues to Swat at Drones, an Appeal of its Policy Takes Off

April 4, 2014 — TV Online Public File Update: Political File Exemption Set to Expire as of July 1

March 25, 2014 — Pursestrings 2014: New Application Fees Announced

March 20, 2014 — Non-English EAS? The FCC Wants to Hear From You!

March 3, 2014 — R.I.P.: Critical Information Needs Study

March 3, 2014 — This Should Get Your Attention II: Nearly $2 Million in Fines to Three Cable Companies for Fake EAS Attention Signals

February 19, 2014 — Utah Judge to Aereo: Not in this Circuit!

February 13, 2014 — OSHA to Tower Industry: Protect Your Workers

February 4, 2014 — Zombie Alert Redux

January 26, 2014 — Aereo Update: And the Question is . . .

January 10, 2014 — Aereo: Supreme Court Bound!

January 1, 2014 — Aereo Cert Day - January 13, 2014?

December 27, 2013 — D.C. Circuit Rejects Challenge to Sunsetting of Viewability Rule

December 26, 2013 — FCC Looking to Expand Closed Captioning Requirement for IP-Delivered Programming

December 6, 2013 — Incentive Auction Update: Projected Auction Date Moved into 2015

December 5, 2013 — Ghost in the Machine?

December 3, 2013 — LPFM Update: Audio Division Issues Progress Report, Road Map

November 22, 2013 — Low Numbers for Low Power

November 19, 2013 — Key Bridge Global LLC Becomes Fourth "White Space" Coordinator to Win Approval

November 14, 2013 — Discount Daze Update: Comment Deadlines Announced in UHF Discount Proceeding

November 4, 2013 — Less Than a Year After Initial CALM Act Effective Date, a New CALM Act Standard Has Been Proposed

October 22, 2013 — LPFM Update: Finding Translator Input Info in the CDBS Database

September 29, 2013 — Biennial Form 323's: The filing window opens October 1

September 27, 2013 — Discount Daze! FCC Proposes Tossing UHF Discount, Creating VHF Discount

September 23, 2013 — Incentive Auction Update: Bureau Looks For Input on What Auction-Induced Reassignment Expenses Should be Reimbursable

September 9, 2013 — Net Neutrality 2013: The D.C. Circuit Hears the Arguments

September 6, 2013 — AereoKiller Cuffed Nationwide

August 28, 2013 — Aereokiller in the Ninth Circuit

August 15, 2013 — Update: CDBS Still Clutching the Same Old NADs

August 12, 2013 — 2013 Reg Fees Set

July 31, 2013 — Media Bureau to Singleton FM Translator Applicants: NOW you can file

July 16, 2013 — Aereo Update: Second Circuit Nixes En Banc Review

July 8, 2013 — Will LPFM Applications Have to Protect Amended FM Translator Applications?

July 7, 2013 — The CALM Act - Six Months and Counting

July 3, 2013 — Did Verizon Short its Customers - and the FCC - $250 million (or More)?

June 17, 2013 — FCC to LPFM Applicants: Let the Uploading Begin!

June 9, 2013 — Quad Erat Demonstrandum? FCC Seeks Comment on MMTC Study

June 1, 2013 — FEMA WEA PSA's 'R' OK!

May 24, 2013 — 2013 Reg Fees: The FCC Proposes a Couple of Alternatives

May 23, 2013 — FM Translator Application Update: Last Chance Settlement Window Opened

April 24, 2013 — Broadcast Renewal Trifecta: Improper "Menu" Underwriting Announcements, "Renewal Expectancy" . . . and Chesterfields!

April 10, 2013 — Cellular Wars: The Employees Strike Back!

April 10, 2013 — Aereo in the Second Circuit: Wha' Happened?

April 9, 2013 — Regulation in Retrospect: "New" FCC Rule Books Now Available

April 2, 2013 — Indecency Alert: New Unannounced "Egregiousness" Standard Now Apparently in Effect, But More Changes May Be On the Way, Eventually

March 15, 2013 — FM Translator Application Update: Bureau Announces Window for Filing of Preclusion Showings

March 10, 2013 — Audio Division to Permittees: Get License Applications Filed Within 30 Days of Permit Expiration . . . Or Else!

March 4, 2013 — Revised Form 323 Out for Comment at OMB

February 24, 2013 — The Five-Year Enforcement Shot Clock: Has the FCC Finally Begun to Acknowledge It?

February 15, 2013 — More FM Translator Applications Down the Tubes

February 11, 2013 — TVStudy: Changes in TV Coverage Calculations Devised For Incentive Auctions

February 7, 2013 — GAO Report: In Wake of Successful Hack of FCC Computer Systems, $10 Million Fix Ineffective

February 5, 2013 — Bureau Disposes of FM Translator Applications

January 31, 2013 — Some TV Broadcasters Relieved of Obligation to Upload Some (But Not All) Issues/Programs Lists to Online Public Inspection File

January 25, 2013 — Explosive Proposal: C4 for FM's?

January 15, 2013 — Form 323 - Kissing the SUFRN Good-bye?

January 3, 2013 — FM Translator Application Dismissal Lists - A Clarification

December 21, 2012 — Update: Deadline for FM Translator Dismissal Lists Announced

December 19, 2012 — Incognito Incentive Auction Input Encouraged

November 29, 2012 — Commissioner Pai: The Dude Abides.

October 27, 2012 — As Sandy Nears, FCC Provides Emergency Response Information

September 30, 2012 — More Online TV Public Inspection File How-To's: The Issues/Programs List

September 28, 2012 — Online TV Public Inspection File - Some How-To's

August 28, 2012 — ivi TV Loses Round Two

August 23, 2012 — Update: USPTO to Take Another Look at Mission Abstract Patent

August 1, 2012 — Another Day, Another Online Public File Demonstration

July 18, 2012 — FCC Still Clenching Improperly Collected Application Fees

July 12, 2012 — Update: Aereo Allowed to Continue Operation During Copyright Challenge

July 6, 2012 — The CRB Dodges an Appointments Clause Bullet

July 3, 2012 — Effective Date of Revised TV Public File Rule Announced

June 29, 2012 — Update: Supremes Shut Down FCC Appeal in Janet Jackson Case

June 21, 2012 — FCC v. Fox: Heading Back to the Second Circuit, Again

May 28, 2012 — Audio Division Re-Affirms Ruling: Studio Site Moves Based on Longley-Rice Must Be Approved in Advance

May 17, 2012 — Don't Touch That REC button . . .

May 16, 2012 — Media Access Project Exits Stage Left

May 4, 2012 — 2012 Reg Fees Proposed: Up, Up and Away!

April 17, 2012 — "What a Beautiful Sight!"

April 13, 2012 — LPFM Tool Time!

April 6, 2012 — LPFM - The Next Generation: FCC Invites Comment on Post-LCRA Regulation of LoPos

April 5, 2012 — Third-Adjacent LPFM Spacings Eliminated (Almost)

April 2, 2012 — Translate This! FCC Breaks LPFM/FM Translator Logjam

March 8, 2012 — Net Neutrality Update: The D.C. Circuit Goes Through the Motions

February 6, 2012 — In Memoriam: Nai Tam

January 20, 2012 — FCC STILL Applies Over-the-Air Contest Rules to On-Line Contests

December 22, 2011 — Reminder: EAS Nationwide Test Form 3's Are Due December 27

December 5, 2011 — Commission to Contest-Conducting Stations: Present Prizes Pronto!

November 7, 2011 — Update: FCC Tweaks Nationwide EAS Test Reports, Again

November 3, 2011 — Update: The Incredible Shrinking Nationwide EAS Test

November 2, 2011 — Indecency 2011: Third Circuit Sides With CBS, Again

November 1, 2011 — Update: FCC Tweaking Nationwide EAS Test On-Line Reporting System

November 1, 2011 — Nationwide EAS Test Reports - Some Questions Raised, Some Answered

October 25, 2011 — Preview: Electronic Report Form for Nationwide EAS Test Participants

October 13, 2011 — Reefer Madness III: Feds Looking to Bust Broadcasters?

October 9, 2011 — Reefer Madness II: Update on "Joint" Sales Advertising

October 6, 2011 — Net Neutrality: The Circuits are Jammed!

September 30, 2011 — Form 323 - The Fun Begins Again

September 25, 2011 — Media Bureau Green Lights MDCL Technology for AM Stations

August 23, 2011 — Form 323 Deadline Extended to December 1, 2011

August 17, 2011 — Update: Public Inspection File Inquiry Arrives at OMB

August 2, 2011 — Spectrum Quest (Home Edition)

July 22, 2011 — 2011 Reg Fees Set

July 18, 2011 — New CALM Act Standard Coming! (Take an Extra Six Days for Those Reply Comments)

June 28, 2011 — For Years FCC Ignores Own Rule, Pockets Filing Fees

June 27, 2011 — First Amendment Face-off: Supremes To Consider Constitutionality of FCC Indecency Regime

June 20, 2011 — "I See Dead Proceedings."

May 30, 2011 — The CALM Act: The Next Step

May 26, 2011 — Field Office: Public File Faux Pas Not Fixed? Forfeiture Figures To Be Higher!

May 17, 2011 — Court To FCC: OK To Defer To State Rate Determinations Re Intrastate Call Terminations

May 13, 2011 — Consent Decree Is Beginning, Not End, Of Licensee's Troubles

May 11, 2011 — LPFM Impact Inquiry Initiated

May 3, 2011 — 2011 Reg Fees Proposed: Going Up!

May 2, 2011 — LPFM Cheerleader to FCC: Let Translators Originate

April 22, 2011 — Shut Up And Deal

April 17, 2011 — Public Inspection File Rule: FCC Asks If It's Really Necessary

April 9, 2011 — Spectrum Inventory Tools: Touts And Doubts

April 7, 2011 — Update: Effective Date Of New Rural Radio Rules Set

April 5, 2011 — Verizon v. FCC: On To Plan C?

March 4, 2011 — Pursestrings 2011: New Application Fees Announced

March 1, 2011 — To Serve Broadcasters*

February 21, 2011 — Old Complaints Never Die . . . And They Apparently Don't Fade Away, Either

February 13, 2011 — Coming Attractions: FCC Webinars Touting Spectrum Re-Purposing

February 11, 2011 — Striving For Perfection

February 9, 2011 — Net Neutrality Update: Coming soon - OMB Review!

February 7, 2011 — Time To Doublecheck Your BAS Data In ULS?

February 3, 2011 — Verizon v. FCC: On To Plan B?

January 21, 2011 — Net Neutrality: Verizon Looks For A Home Court Advantage

January 17, 2011 — . . . and statistics."

January 5, 2011 — Local Community Radio Act - It's The Law!

January 4, 2011 — NYPD (Not Too) Blue Moon

December 27, 2010 — Bootstraps Auction Preference Under Consideration

December 20, 2010 — Christmas Comes Early For LPFMs

December 4, 2010 — Auction 91 - The Dates Are Set

November 23, 2010 — FCC Doffs CAP Requirement . . . For Six Months, At Least

November 12, 2010 — Some Fine Points About Fining

November 7, 2010 — "Our Survey Said . . . " - Update

November 5, 2010 — "Our Survey Said . . ."

October 22, 2010 — S. 592, Where Are You?

October 13, 2010 — FCC Takes Wraps Off Revised Broadcast Renewal Form

October 5, 2010 — Longley-Rice Dependent Studio Site? No Prior Authorization? $7K, Please!

September 13, 2010 — Broadcasters Beware: Non-Operation Could Lead To Non-Renewal

August 24, 2010 — Contest Faux Pas: A Day Early, $4K Short

August 9, 2010 — STELA NPRMs On Fast Track

August 6, 2010 — S. 3756: Another Thumbs Up For Auction Proceeds Sharing

August 3, 2010 — FAA Backs Off Proposal To Expand EMI-Based Review Of Radio Applications

August 1, 2010 — H.R. 5947: Another Order Of Carrot, Please - This Time Hold The Stick

July 20, 2010 — S. 3610: The Carrot And The Stick Make Their Appearance

July 16, 2010 — Indecency In A Post-Fox World: What's Up Next?

July 12, 2010 — Form 323: SSN Disclosure Requirement Largely Written Out Of Form In Last-Minute Revision

July 9, 2010 — 2010 Reg Fee Surprise

July 5, 2010 — Form 323: The Court Weighs In

June 25, 2010 — Form 323: Point/Counterpoint

June 15, 2010 — Form 323 Update: FCC Has Some 'Splaining To Do

May 19, 2010 — Compromise Tower Agreement - For The Birds

May 18, 2010 — Supreme Court Mum On Must-Carry Market Mod

April 8, 2010 — Revised Form 323 Available - April 9, 2010

March 31, 2010 — Turn-Of-The-Century NCE Translator Applications Dismissed

March 14, 2010 — Cable Programming Exclusivity Ban Survives Appeal . . . But For How Long?

March 12, 2010 — Retransmission In Transition?

February 19, 2010 — A Complaint Process Is Born!

February 4, 2010 — Extreme Makeover (Not!) - Radio Edition

February 1, 2010 — Help Wanted? Help Needed?

January 13, 2010 — The Good Kind of Snowe Job

December 24, 2009 — Court Review Of Revised Form 323 Is Sought As Bureau Suspends January 11 Deadline

December 9, 2009 — Presenting The New Form 323!!!

December 3, 2009 — Wireless Broadband vs. Over-The-Air TV: The Bell Rings For The Main Spectrum Event

November 30, 2009 — FHH to FCC: Think Again

November 19, 2009 — MMTC To FCC: Rethink Form 323

November 17, 2009 — FHH To FCC: "Stay"

October 30, 2009 — Deadline For Filing New Form 323: December 15

October 29, 2009 — Moment Method Modeling: Update V

October 26, 2009 — Power To The Parents Redux

October 23, 2009 — Vacant NCE-FM Reserved Channel Window Postponed Two Months

October 21, 2009 — Revised 323 Approved By OMB

October 18, 2009 — Brrrrrrr - The Chill Is On

October 18, 2009 — FCC Announces Window For Vacant NCE-Reserved Channels

October 2, 2009 — Biennial Ownership Report (Form 323) Deadline Extended

September 21, 2009 — Coming Soon: Mobile Spam?

September 9, 2009 — FCC Invites Comments On "Ratchet Rule" Proposal

September 4, 2009 — Rackley/Dawson Propose Deep-Sixing The "Ratchet Rule"

September 2, 2009 — "Contrarian"? Au Contraire!

September 1, 2009 — Update: AM on FM Translator Rules Become Effective October 1, 2009

August 30, 2009 — Court Kiboshes Cable Cap

August 19, 2009 — Revised Form 323 Revealed

August 17, 2009 — Meanwhile, Back At The Second Circuit . . .

August 12, 2009 — Impaired Transparency?

August 10, 2009 — Responding To A False Alarm?

July 31, 2009 — 2009 Reg Fees Set

July 24, 2009 — 8th Floor Access Control

July 22, 2009 — Auction 79 - Up-Front Payments Due July 31

July 9, 2009 — Adventures in EEO-Land

June 27, 2009 — FCC to NCE's: Ixnay on the "Cold Refreshing Beer"

June 21, 2009 — Caution, E-Filers: The FCC Knows Who You Are!

June 19, 2009 — HD Radio Upgrade: FCC Concentrates and Asks Again

June 11, 2009 — Plus Ça Change, Plus C'est la Même Chose

June 5, 2009 — Court Affirms LPFM-Friendly Rules

June 4, 2009 — Post-Transition DTV Call Sign Protocol Announced

June 3, 2009 — Any Time At All

May 29, 2009 — Late Breaking News: June-October, 2009, Form 323 Reporting Requirement Suspended

May 28, 2009 — More Comments Invited On Proposed HD Radio Power Increase

May 21, 2009 — PPM Inquiry: A Can of Worms?

May 11, 2009 — 50,000,000 Birds Can't Be Wrong . . . Can They?

May 11, 2009 — Found In Translation

May 7, 2009 — New Ownership Report, Audit Designs Left To Bureau

April 29, 2009 — FCC v. Fox - The Supreme Court Rules

April 21, 2009 — Spectrum Auction Bidders In Qui Tam Scam Jam

April 17, 2009 — Brrrrrrr - FCC Announces Freezes On FM Mods

April 17, 2009 — Auction 79 - The Dates Are Set

April 9, 2009 — New Ownership Reporting Rules Adopted As Commissioners Seek "Diversity"

April 7, 2009 — STAT!! Timely Filing of CP Extension/Assignment Applications Becomes Crucial

April 2, 2009 — Nightlight, Pink Slips

March 25, 2009 — Audio Division Addresses Environmental Assessment Requirements

March 19, 2009 — LPFM Stuck With $20K Fine for "Advertisements"

March 3, 2009 — Power to the Parents?

February 21, 2009 — Another Friday Night, Another DTV Order

February 17, 2009 — Washington's Birthday Special: Another DTV Public Notice!!!

February 11, 2009 — DTV Transition Update - 680+ Analogs Set To Turn Off Early

February 9, 2009 — DTV Extension: It Ain't Over 'Til The Paperwork's . . .

February 5, 2009 — Moment Method Modeling: Update IV

February 4, 2009 — DTV Extension? June 12 Is Looking Like The New Date!

February 2, 2009 — Don't Look Now, But You're STILL Being Watched (Update II)

January 27, 2009 — DTV Extension? Senate Says June 12!

January 23, 2009 — A New (well, sort of new) Sheriff In Town

January 20, 2009 — Departing Martin Takes 31 Parting Shots At Cable

January 11, 2009 — DTV Transition Extension - The Line(s) From Vegas

January 9, 2009 — Moment Method Modeling: Update III

January 8, 2009 — DTV Transition Extension: What's the Over/Under?

January 5, 2009 — NTIA Wait Lists Coupon Requests

December 30, 2008 — In the Starting Blocks: Replacement Translator Spectrum Rush Set to Kick Off On January 5

December 27, 2008 — "Analog Nightlight" Service Standards Proposed

December 22, 2008 — Moment Method Modeling: Update II

December 19, 2008 — Antennas: When is an Omni Not an Omni?

December 11, 2008 — Comment Deadlines Set In FCC Tower Inquiry

December 10, 2008 — Postcard from the Sausage Factory

November 19, 2008 — DIGITAL TV TRANSITION Ford Fusion Doesn't Crash in Final Race!!!!

November 10, 2008 — On Fire, DIGITAL TV TRANSITION Ford Fusion Takes to the Airways - Literally

November 3, 2008 — Moment Method Modeling: Update

November 3, 2008 — Court Rejects Attack On DTV Transition-related "Viewability" Rules For Cable Operators

October 24, 2008 — Comments Invited on Proposed HD Radio Power Increase

October 23, 2008 — Still Searching for Mr. Goodwrench?

October 20, 2008 — Number 38 Crashes, Leaving FCC at 0-1 on the NASCAR Circuit

October 17, 2008 — L'Affaire NASCAR: The Yellow Caution Flag Comes Out

October 17, 2008 — The FCC Heads For the Pit

October 7, 2008 — Update: The FCC Is Not Watching You Anymore (or so they have told us)

September 28, 2008 — FCC Considers Regulating Construction of Towers (and Possibly Other Structures) Near AM Antennas

September 28, 2008 — Moment Method Modeling Manumits AMers From Measurement Manacles

September 23, 2008 — Application Fees: Up, Up and Away!

September 16, 2008 — Don't Look Now, But You're Being Watched . . .

September 9, 2008 — Ordure in the Court?

September 3, 2008 — Deadlines Set For 700 MHz Comments

August 26, 2008 — Deadline for Reg Fee Payment Set

August 22, 2008 — FCC Whacks 700 (MHz) Club

August 20, 2008 — The Reg Fee Payment Window Is Open

August 19, 2008 — The Commissioners Are Coming!! The Commissioners Are Coming!!

August 14, 2008 — 2008 Reg Fees Adopted

August 12, 2008 — A Midsummer Surprise From The FCC: A Revised Version Of The Public and Broadcasting!!!

June 27, 2008 — Embedded advertising in the cross-hairs

June 23, 2008 — A Legacy for Broadcasters

June 6, 2008 — FCC Seeks Comment on MPAA's "SOC" Request

April 8, 2008 — FCC to Translator Applicants: "Never Mind"

March 3, 2008 — Supremes Keep Us Hangin' On

February 12, 2008 — FCC to fee payers: "Show me" the money

January 2, 2008 — DTV Update: FCC Releases Third Periodic Review

December 28, 2007 — D.C. Circuit Dismisses Appeals of Junk Fax Rule Revisions

December 4, 2007 — Court to FCC: Classification of Certain Prepaid Calling Cards As "Telecommunications Services" Must Be Retroactive

November 28, 2007 — BACK TO THE FUTURE!!

November 13, 2007 — Martin Single-handedly Seeks To Solve Ownership Impasse

November 8, 2007 — Expedited Settlement Opportunity for NCE FM Applicants Available Until January 7, 2008

October 30, 2007 — Broadcast localism hearing - trick or treat?

October 11, 2007 — FCC to NCE Applicants: Ten's the Limit

August 29, 2007 — Elvis has left the building

August 9, 2007 — FCC Proposes Caps for October NCE Filing Window

August 9, 2007 — Found in Translation: Daytimers Going Nighttime

August 9, 2007 — Fedsox Drop Bombs, 13-6; Bombs Catch Crabs in Nightcap

August 3, 2007 — FHH Bombs disarmed at last minute

August 2, 2007 — $20,000 Fine for False Certification

July 27, 2007 — F-Bombs Blast Wilkinson

July 17, 2007 — Rockets spike Warren Communications

July 4, 2007 — Bombs Misfire

June 28, 2007 — Taking Precedent Siriusly?

June 28, 2007 — Bombs Fall at the Jeff

June 5, 2007 — Commentary: The FCC As Holden Caulfield

June 4, 2007 — Second Circuit Trashes FCC Indecency Policy

June 2, 2007 — FCC Introduces New EAS Rules

May 23, 2007 — FCC Considering Moment Method Modeling in lieu of Field Strength Measurements for Directional AM Applicants

May 16, 2007 — Cable Guy to Feds: Let's Kiss the FCC Goodbye

May 16, 2007 — Tower Inspection Requirement Waived for Eagle, HARK Systems