Anne Goodwin Crump

Photo of Anne Goodwin Crump Mrs. Crump has represented both commercial and non-commercial clients in a variety of transactional and regulatory matters. These have included guiding clients through the purchase and sale of broadcast stations, assisting with the license renewal process, and advising on the DTV and repack transition processes. She also has assisted clients with day-to-day regulatory matters, including political broadcasting, children’s television matters, EEO reports and audits, and helps clients develop strategies for meeting their goals while complying with FCC rules. Mrs. Crump has filed comments on behalf of clients in a variety of FCC rulemaking proceedings, which have included both broad policy issues, such as ownership regulations and broadcast localism, and station-specific matters, such as non-routine changes in community of license. She also has engaged in written advocacy for clients, whether arising from contested transactions or FM translator interference issues, or other matters.  

Subscribe to all posts by Anne Goodwin Crump

Comment Deadline Set for Proposed Disclosure Requirements for AI Content in Political Ads

As has been widely publicized, the FCC has proposed that broadcasters be required to air an announcement for all political ads, including both candidate and issue ads that contain content generated by artificial intelligence (AI).  The deadlines for comments on this proposal have now been set.  Initial comments will be due by September 4, 2024, … Continue Reading

FTC Votes to Ban Noncompete Agreements

In late-breaking news, the Federal Trade Commission (“FTC”) has adopted a final rule banning new noncompete agreements for all workers and effectively nullifying existing agreements and requiring companies to notify most current and past employees that the company will no longer enforce such agreements. In a change from the prior FTC proposal, however, the agreements … Continue Reading

Broadcast Station Contest Rules Aren’t Just for Contestants, They Apply to the Stations, Too!

The FCC recently released a Notice of Apparent Liability (“NAL”) for a forfeiture of $8,000 that should be a cautionary tale for other broadcast licensees that conduct contests for listeners or viewers.  This fine arose out of the station’s failure to conduct a contest in accordance with its announced terms, and specifically to make payment … Continue Reading

FCC Extends Deadline for Television Stations to Implement Aural Description of Emergency Information

The Federal Communications Commission (“FCC”) has largely granted the NAB’s request and will again extend for 18 months to November 26, 2024, the effective date of the FCC’s rule governing accessibility of emergency communications. This rule requires broadcasters to provide, during non-newscast programming, an aural representation of any visual, non-textual emergency information, such as radar … Continue Reading

EEO Mid-Term Review Anticipated Starting May 2023

We remind radio licensees that Spring marks the mid-point of the current license term for some.  This mid-point is significant because it marks the beginning of the period during which the FCC will conduct mid-term reviews to determine compliance with EEO requirements for radio station employment units that employ 11 or more full-time employees. Even … Continue Reading

Reminder – EAS Test Reporting System Filing Deadline February 28

This is a reminder that the FCC previously advised that parties that are Emergency Alert System (“EAS”) Participants, which would include not only virtually all broadcast stations, but also, wired and wireless cable television systems, Satellite Digital Audio Radio Service, and wireline video systems, must submit Form One filings for calendar year 2022 in the … Continue Reading

More Emergency Alert System Proposed Changes and Reporting Requirements

To accompany its recently adopted modifications to the requirements for the Emergency Alert System (“EAS”), the Federal Communications Commission (“FCC”) has issued a Notice of Proposed Rulemaking (“NPRM”) to address the FCC’s ongoing concerns about operational readiness and the security of the EAS system from being acted or otherwise misused by bad actors. Comments on … Continue Reading

Emergency Alert System Required Changes

The Federal Communications Commission (“FCC”) recently adopted modifications to the requirements for the Emergency Alert System (“EAS”), and the new rules will go into effect on December 12, 2022.  Fortunately, however, EAS participants, which include most radio and television stations, have one year, until December 12, 2023, in which to make the necessary changes to … Continue Reading

Broadcast Deadlines

Upcoming FCC Broadcast and Telecom Deadlines for December – February December 1, 2021 Biennial Ownership Reports – All licensees and entities holding an attributable interest in a licensee of one or more AM, FM, TV, Class A television, and/or Low Power TV (LPTV) stations must file a biennial ownership report reflecting information as of October … Continue Reading

FCC Authorizes All-Digital AM Service

Taking the next step in its ongoing efforts to revitalize the AM broadcast service, the Federal Communications Commission (“FCC”) has authorized AM radio stations to convert to all-digital broadcasting. Making such a switch is expected both to improve the quality of the signal received by listeners and to expand the area in which the audience … Continue Reading

Free Press vs. Broadcast Journalism: Truth in the Time of the Coronavirus

The Federal Communications Commission’s (“FCC” or the “Commission”) recent rejection (FCC statement here) of a petition submitted by Free Press to demand FCC action with regard to broadcasters’ coverage of governmental statements about the COVID-19 epidemic has received a great deal of coverage. What may have escaped attention, however, is that, aside from some sharp … Continue Reading

Revised Children’s TV Rules Effective in Part Soon – Current Paperwork Requirements Still in Place, Further Comments Requested

As we previously reported, many of the revised children’s TV rules adopted by the Federal Communications Commission (“FCC” or the “Commission”) in July are to go into effect 30 days after publication in the Federal Register, and we now know what that effective date will be:  September 16, 2019.  That effective date will apply to … Continue Reading

Children’s TV Reforms – Paperwork Reduction One Step Closer

The Federal Communication Commission (“FCC” or the “Commission”) released the much-discussed changes in its rules relating to children’s television programming on July 12, 2019 in a Report and Order and Further Notice of Proposed Rule Making, which include a reduction in the frequency of filing Children’s Television reports and the information required in those reports, … Continue Reading

Ancillary/Supplementary Services Report and Public Notice Rule Face Regulatory Weed-Whacker

At its October meeting, the FCC proposed to clear away further regulatory underbrush by eliminating, or drastically modifying, two rules. The first is the requirement that all TV stations engaged in digital broadcasting file annual reports concerning Ancillary/Supplementary services that might have been offered. Second is the requirement that licensees filing certain applications publish and/or … Continue Reading

Online Public File to Bring New Scrutiny to Issues/Programs Lists

Believe it or not, the date by which all radio stations must have their complete public files online is now less than six months away. Television stations have been dealing with this reality for several years now, as have large stations in large markets for the past couple of years. Now, every radio station, both … Continue Reading

FCC’s EEO Policies Subject of Re-examination and Update

The FCC’s policies with regard to diversity generally have taken center stage over the past few days.  First up, on Friday, April 21, the Commission released a Declaratory Ruling which updated its policy as to whether the use by broadcasters and multichannel video programming distributors (MVPD’s) of only Internet-based recruitment sources provides sufficiently wide dissemination … Continue Reading

The More Things Change, the More They Stay the Same – UHF Discount Restored

The Commission has acted to restore the UHF discount used to calculate audience reach in connection with determining compliance with television ownership limits.  The national ownership cap currently limits the number of stations one owner may control to those which reach no more than 39 percent of national television households (with reach defined as the … Continue Reading

Large Market Radio Stations Must Have Complete Online Public File by Christmas Eve

Many radio owners have a Commission-imposed deadline looming before Christmas. Most radio stations located in large markets, which have been defined by the Commission in this instance to be the Nielsen Top-50 radio markets, will need to make sure that they have their online public files completely uploaded by December 24, 2016. Each full-power commercial … Continue Reading

Day of the Deadlines: Your Guide to Upcoming FCC Broadcast Filing Deadlines

There are a number of upcoming FCC filing deadlines over the next three months that are relevant to broadcasters.  You should review these carefully, as some are only applicable to certain licensees while others (the EEO-related and noncommercial ownership reports) are state-specific. Please do not hesitate to contact us if you have any questions.… Continue Reading

Repack Update: FCC Invites Comments on Widelity II

Input sought on revised catalog of likely repack expenses As we all know, TV stations forced by the Incentive Auction/spectrum repack process to modify their facilities will be entitled to reimbursement of their reasonable repacking-related costs. And as we reported a couple of years ago, to give everybody – FCC and affected broadcasters (and MVPDs) … Continue Reading

Time to Test Drive the New and Improved Online Public File System!

“Local” no more – as of June 24, new “OPIF” will be up and running … but a demo can – AND SHOULD – be checked out NOW Last January we reported on the FCC’s decision to expand its online public inspection file (now officially referred to as “OPIF”) requirement to include radio broadcasters, cable … Continue Reading
LexBlog