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

FAA Throws in the Towel On FM Spectrum, Apparently

After nearly a decade, the FAA advises that it is no longer pursuing a proposal that would have inserted it deeply into the regulation of FM stations.

For years, the Federal Aviation Administration has toyed with the idea of regulating use of some portions of the spectrum – including particularly the FM band (approximately 88 MHz–108 MHz) – even though conventional wisdom says that such matters are statutorily (not to mention logically) controlled by the Federal Communications Commission. The FAA backed down from these aspirations to some degree in 2010, but in doing so it sniffed, in effect, that we all hadn’t heard the last from it on this point.

Now, five years later, the FAA appears to have thrown in the towel. In a three-sentence letter to the FCC’s Office of Engineering and Technology, the FAA has advised that it is “no longer pursuing the proposed frequency notification requirements for FM radio stations” which it has long had its regulatory eye on.

Ideally, this means that the FAA has finally abandoned any hope of affirmatively regulating FM radio transmission facilities.

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Marriott Checks Out of Declaratory Ruling/Rulemaking Proceeding

Prudent network management or Wi-Fi jamming? The question has been taken off the table … for now.

Last year we reported on a couple of interactions between the FCC and the well-known hotelier, the Marriott Corporation. The news started inauspiciously for Marriott when the Commission wrapped up an investigation (started in 2013) by spanking Marriott with a $600,000 civil penalty. The FCC determined that Marriott had used “containment capability” to prevent guests at the Gaylord Opryland (run by Marriott) from by-passing the hotel’s Wi-Fi system in favor of their own DIY hotspots.

Presumably prodded by that investigation, Marriott (joined by some hotel friends) filed a request for declaratory ruling (or, in the alternative, for rulemaking), essentially asking for a determination that what Marriott had done really was OK. (Specifically, Marriott was asking the Commission to hold that a network operator may “mitigate” threats to the operator’s network, even when doing so results in interference to guests’ WiFi hotspots.)

The FCC dutifully announced the filing of the request for declaratory ruling and invited comments about it. But a month later, it also issued an “Enforcement Advisory” alerting one and all to the fact that preventing one’s Wi-Fi enabled devices from connecting to the Internet constitutes prohibited “jamming”. And a month later, out came another “Enforcement Advisory”. This one was even more pointed. Referring to “a disturbing trend in which hotels and other commercial establishments block wireless consumers from using their own personal Wi-Fi hotspots on the commercial establishment’s premises”, the advisory declared flatly that “Wi-Fi blocking violates Section 333 of the Communications Act, as amended.”

Not surprisingly, Marriott (and the other requesters) have now withdrawn their request for declaratory ruling (and the FCC has lost no time in officially bidding it adieu).

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Reminder: Sponsorship ID's Required Even When the Government is the Sponsor

If Uncle Sam is paying for the time, Uncle Sam is the sponsor. 

Long-time reader, broadcaster, Friend of the Blog, client (and, yes, attorney) Tom Taggart has suggested that a reminder about sponsorship identification might be useful in light of a recent situation he encountered. An ad agency bought time on behalf of the Centers for Medicare and Medicaid Services, a federal governmental agency, which was promoting enrollment in Obamacare in advance of the mid-February filing deadline. No problem there. The instructions accompanying the 30-second script indicated that it should be read “like a PSA with a sense of urgency”. Again, no problem there.

But the script didn’t happen to include any indication of who was paying for the spot – and there was the problem.

The mere facts that the spot was supposed to be read “like a PSA” and that it involved a subject that could qualify for PSA treatment were immaterial, since it was acknowledged by one and all that money was to change hands in exchange for broadcasting the spot. That being the case, an appropriate sponsorship identification was definitely called for, notwithstanding the omission of any such ID from the spot’s script. Having recognized that omission, the station was entirely within its rights to take steps to insure that an appropriate sponsorship ID was included in the spot.

We don’t know whether this incident arose from an over-enthusiastic, under-informed ad rep (or ad agency), or possibly a sponsor who preferred to avoid a sponsorship ID because it might somehow dilute the intended message, or possibly some inadvertent miscommunication somewhere along the line. Whatever the source of the problem, the solution was clear. If money is being paid in return for the broadcast of particular content, that must be disclosed, and it’s the broadcaster’s obligation to make sure that it is disclosed. It doesn’t make any difference if the sponsor is a governmental agency, or if the subject matter of the spot might otherwise qualify as PSA-worthy.

Tom noted our recent reports on the FCC’s recent enforcement efforts relative to the sponsorship ID requirement – here and here, for example – and thought a reminder about the rule might be appropriate. We agree – consider yourselves reminded.

Proposed MVPD Redefinition Out for Comment

FCC looks to open ranks of MVPDs to Internet-delivered services – a move that could save what’s left of Aereo

It looks like the universe of multichannel video programming distributors (MVPDs) is going to be expanding considerably. Previously populated by the likes of cable, MMDS and broadcast satellite operators, the MVPD universe is set to be redefined to include services “untethered” from any infrastructure-based definition … if, that is, a proposal laid out in a Notice of Proposed Rulemaking (NPRM) last month (and just published in the Federal Register) takes hold. The result should expand consumer options for video program service, and might even revivify whatever may be left of Aereo once Aereo exits the bankruptcy process. And even if Aereo doesn’t survive, we can look for new Aereo-like services.

The proposed redefinition of what it means to be an MVPD is part of the Commission’s overall effort to encourage innovation and serve the “pro-consumer values embodied in MVPD regulation”. It’s also one more reflection of the FCC’s embrace of the technology transition – from old-fashioned, relatively inefficient analog service to digital, Internet protocol (IP) delivery – that is sweeping virtually all aspects of U.S. communications.

The Communications Act defines MVPD as a person (or entity) who “makes available for purchase, by subscribers or customers, multiple channels of video programming.” The Act cites some examples – “cable operator, a multichannel multipoint distribution service, a direct broadcast satellite service, or a television receive-only satellite program distributor” – but makes clear that those are not the only possible MVPDs. So the FCC appears to have some latitude when it comes to filling in the blanks Congress left.

And that’s what it’s now trying to do.

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Top Ten Nonbroadcast Video Networks? The Winners Are ...

Video description rules bring FCC into the ratings game ... every three years

When you’re trying to track down the national rankings of video programming networks, you may not think to check with the FCC – but, thanks to the Twenty-First Century Communications and Video Accessibility Act of 2010 (CVAA), that’s the first place you should look. Every three years, at least.

As long-time readers may recall, back in 2011 the Commission, pursuant to Congress’s direction in the CVAA, adopted extensive video description rules applicable to broadcasters and multichannel video programming distributors (MVPDs). As to the latter, the rules require that MVPDs with more than 50,000 subscribers must provide 50 hours per calendar quarter of video-described prime time or children’s television on the five most popular cable channels.

Popularity in this context is determined based on (take a deep breath) an average of the national audience share during prime time of nonbroadcast networks that reach 50 percent or more of MVPD households and have at least 50 hours per quarter of prime time programming that is not live or near-live or otherwise exempt under the video description rules. (The relevant Nielsen ratings period this time around was September 30, 2013-September 28, 2014; the relevant stats were Nielsen’s “live +7 day” ratings, i.e., the ones that include incremental viewing that takes place during the seven days following a telecast.)

While the calculation of Top Five nets could presumably be performed annually (or even more often), the Commission chose to update its list only every three years. The first three-year term has screamed by since the 2011 adoption of the rules. And as promised, the Media Bureau has now announced the Top Five nonbroadcast video networks that will trigger MVPD video-description obligations until July 1, 2018. (Actually, it announced the Top Ten, presumably to provide for alternates should they be needed.)

The lucky networks:

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Put It In Writing, Part II: Call for Comments on Closing Closed Captioning Loophole

FCC seeks input on possible regulation of “video programmers”.

As we reported recently, the FCC has ratcheted up its video captioning requirements for “Video Programming Distributors” (VPDs), a universe defined as “all entities who provide video programming directly to customers’ homes, regardless of distribution technology used (i.e., broadcasters and MVPDs)”. (Note that, despite that last “regardless of distribution technology” language, captioning requirements don’t apply to programming distributed solely on the Internet if it was not previously broadcast.) The new rules specify new caption quality standards for which VPDs are technically responsible – but VPDs can avoid penalties for captioning violations that are outside their control by making certain “best efforts”.

Those “best efforts” entail trying to get a certification from each “video programmer” (the definition of which we’ll come back to in a minute) confirming either that (a) the video programmer’s programming complies with FCC captioning standards; (b) the video programmer adheres to certain FCC-defined “best practices”; or (c) the video programmer is exempt from captioning obligations (exemptions can be based on financial hardship but are becoming increasingly difficult to get).

This approach may seem a reasonable allocation of responsibilities between VPDs and video programmers. But to the extent that it does not impose on non-exempt video programmers any independent obligation either to comply with the Commission’s captioning standards or utilize Commission-defined best practices, the approach may create a loophole of sorts because it doesn’t allow the FCC to take enforcement action directly against video programmers, as opposed to VPDs.

Apparently sensing this, the Commission has issued a Second Further Notice of Proposed Rulemaking (SFNPRM) looking for ways to close that loophole.

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Now Available for Your Review and Comment: Form 2100, Schedule 381

Still a work in progress, but an excellent opportunity both to see what the FCC has in mind  and also to suggest possible improvements to the form before it takes final shape.

A couple of weeks ago we reported on a Federal Register notice announcing the start of a two-month period for the filing of comments about a new FCC form (Form 2100, Schedule 381, to be exact - a/k/a “Certification of TV Broadcast Licensee Technical Information in Advance of Incentive Auction”). We noted then that no copy of the form was included in the Federal Register notice and that our request for a copy (emailed to the Commission) had gone unanswered, so we couldn’t shed much light on what the form might look like.

We got word earlier today that the form is indeed available and, sure enough, when we emailed the Commission again asking for a copy, we got one lickety-split. Here’s a link to what was sent to us. (Actually, we received a Word version, which we have converted to PDF.)

As a quick glance indicates, it’s still something of a work in progress. That’s to be expected when the FCC invites comments on a form: by definition the form is subject to change based on the comments that get submitted. So here’s your chance to take a look at the Commission’s current draft and chip in your two cents’ worth.

As we noted previously, Schedule 381 is designed to provide the Commission assurance that the technical profile of the television industry as reflected in the FCC’s database is accurate. That’s obviously important because that profile will be used both to identify the facilities to be sold in the reverse auction and to form the starting point for the spectrum repacking effort which is the ultimate goal of the auction. Secondarily, the completed forms will provide the FCC with a comprehensive database of all the specific transmission equipment (transmitters, antennas, transmission line) currently in use. The detailed information about equipment will be used in determining relocation reimbursements.

All full-power and Class A TV licensees entitled to mandatory protection in the auction – and those with Commission-afforded discretionary protection – will have to complete and submit Schedule 381. Those folks all presumably have an idea of who they are, but they will know for sure when the FCC issues its “Eligibility Public Notice” spelling out the facilities that the Commission believes to be entitled to protection. The notice will specify a deadline by which protected licensees will have to submit Schedule 381. (We’re guessing that that won’t happen before the late summer of 2015, but you never know.) Completion of the form will entail a number of separate and distinct chores.

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FAA to Ease (a little) Its System for Reporting Tower Light Outages

But the FCC isn’t planning to give tower owners much slack as a result.

If you’re responsible for a tower subject to lighting requirements imposed by the Federal Aviation Administration, your life may be getting a bit easier early next year. According to an advisory issued by the FCC’s Wireless Telecommunications Bureau, the FAA is modifying its notification process to allow folks reporting lighting outages to specify, in their initial notices, the amount of time they expect to need to get the outage fixed.

We all know that the FAA imposes lighting requirements on certain tower structures, and the FCC adds extra muscle to those requirements when it comes to FCC regulatees responsible for such structures. Under the Commission’s rules, folks with a tower subject to FAA lighting requirements must monitor the tower lights at least once every day, either by directly eyeballing the tower or by observing “an automatic properly maintained indicator designed to register any failure of such lights”.

And when there’s an outage, things are supposed to happen.

The FCC requires that a record be made of the nature of the outage, the date and time the outage was noticed, the date and the outage is corrected (and the nature of the corrections) … and the date and time the FAA is notified.

Wait – notify the FAA?

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FCC Invites Comments About Not-Yet-Available Spectrum Auction Form

Can we all agree that responding to the invitation to comment on Form 2100, Schedule 381 would be easier if the form were available for review?

[Update: Form 2100, Schedule 381 has since been made available for review. See our follow-up post, which includes a link to the draft form.]

Like the first sparse snowflakes heralding a major blizzard long predicted but slow to arrive, an announcement in the Federal Register confirms that the spectrum auction is indeed approaching. The public notice invites comment on a new “information collection” – dubbed Form 2100, Schedule 381 – which all full-power and Class A television licensees will have to complete and submit prior to the incentive auction.

The form – formal name: “Certification of TV Broadcast Licensee Technical Information in Advance of Incentive Auction” – will require each licensee to certify that (a) it has reviewed the “technical data on file with the Commission related to its current license authorization” and (b) those data are “correct with respect to actual operations”. Basically, the Commission wants to be sure that the technical profile of the television industry as reflected in the FCC’s database is accurate, since that profile will be used both to identify the facilities to be sold in the reverse auction and to form the starting point for the spectrum repacking effort which is the ultimate goal of the auction. Licensees will also have to provide “basic data” concerning gear currently used by their stations; this information will be used to “facilitate the channel reassignment process following the completion of the incentive auction”.

The fact that the Commission is designing a form along these lines is not surprising – careful readers of the 400+ page behemoth incentive auction Report and Order will doubtless recall footnote 615 (nestled comfortably on page 86), which expressly flagged the FCC’s intent along these lines. But what is surprising is the fact that, while the Federal Register notice asks the public to comment on the proposed “information collection”, the form itself does not appear to be currently available. The Federal Register notice includes no copy of the proposed form, and a request emailed to the Commission has thus far elicited no response.

In other words, at this point it looks like Form 2100, Schedule 381 is the regulatory equivalent of vaporware.

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Unconsented-to Phone Call Recording + Unresponded-to Inquiry = $35,000 Penalty

Former TV licensee cops plea to violating telephone rule, ignoring Enforcement Bureau

Ah, the telephone call rule. Section 73.1206. The fact that we’ve written about it at all is surprising – surprising because the rule is so clear and so simple that any violation of it comes as something of a surprise. And now we have an even more surprising instance: a television licensee (make that former licensee – more on that below) managed to get cross-wise with the telephone rule. While such TV violations are not unheard of, the more common instances of phone rule transgressions involve radio station announces who place on-air prank calls to unwitting victims. So the fact that the Enforcement Bureau has brought a $35,000 hammer down on a TV station serves as a reminder that Section 73.1206 limits all broadcasters, radio and TV alike.

Unfortunately, we don’t know many details of the violation in question. That’s because the guilty licensee entered into a Consent Decree, i.e., essentially a plea deal. The Decree itself says only that, on August 21, 2012, the Commission received a complaint alleging that, the day before, Station KTVX had “twice broadcast a recorded telephone conversation without prior notification to the other party to the conversation”, a telephone rule violation to which the licensee eventually confessed without further elaboration.

Despite this lack of specifics, the Consent Decree does provide a few take-home lessons.

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Older Entries

November 23, 2014 — Finally Bringing Broadcast Contest Rules into the 21st Century?

September 14, 2014 — New Fast Lane in Open Internet Proceeding

September 4, 2014 — Issue-Oriented Spots: Who's The REAL Sponsor?

August 29, 2014 — 2014 Reg Fees Set, Payment Deadline Announced

August 15, 2014 — Update: Reply Comment Deadline Extended in Net Neutrality Proceeding

August 7, 2014 — Coming Soon: Online Public File Obligations for Cable, Satellite . . . AND Radio?

August 6, 2014 — What a Drag It Is . . .

July 20, 2014 — Aereo Loses First Round in Copyright Office, While Dish Wins its Next Round in the Ninth Circuit

July 16, 2014 — INCOMING! Commission's Net Neutrality Comment Conundrum

July 10, 2014 — It's ALIVE!!!! Aereo Lurches Back to Life, Sort of

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