FCC announces procedures for waiver requests by noncommercial broadcasters
In our experience, broadcasters respond to catastrophes with incredible humanity, offering help wherever and whenever possible. As the horrific stories and images from earthquake- and tsunami-devastated Japan continue seemingly unabated, broadcast stations may want to undertake fund-raising efforts to support relief efforts. The FCC clearly does not want to do anything to discourage such laudable humanitarian impulses. However, rules are rules – and the Commission’s rules (Sections 73.503(d) for radio and 73.621(e) for TV) generally prohibit noncommercial educational (NCE) broadcasters from engaging in on-air fund-raising activities on behalf of anybody but the station itself.
Not to worry. The Commission has historically waived that prohibition following “disasters of particular uniqueness or magnitude” – Hurricane Katrina, the 2004 Southeast Asia earthquake/tsunami and the 2010 Haiti earthquake come to mind as ready examples. And just to be sure that we all know that the FCC views the Japan earthquake/tsunami to be in the same league, the Commission has issued a public notice laying out the procedures by which NCE licensees may request waivers so that they can engage in fund-raising for relief efforts.
Stations seeking such waivers should prepare an informal request providing the following basic details of their fund-raising activity:
- the nature of the fund-raising activity;
- the proposed duration of the activity;
- the organization(s) to which fund will be donated; and
- whether the fund-raising activity will be part of the station’s regularly-scheduled pledge drive or fund-raising efforts
The informal request should then be emailed to the FCC. NCE television licensees should address their requests to Barbara Kreisman (email@example.com). NCE radio licensees should address their requests to Peter Doyle (firstname.lastname@example.org) and Michael Wagner (email@example.com). Those points of contact are also available for any particular questions you might have about such things.