Peter Tannenwald

Peter Tannenwald Peter Tannenwald joined Fletcher, Heald & Hildreth, PLC, as a Member, after a 40-year career which included one of Washington's 10 largest law firms, where he was a partner, and more recently as a named principal of Irwin, Campbell & Tannenwald, P.C. In addition to a broad range of radio and television broadcast station groups and individual station owners and common carrier and wireless clients in both regulatory and transactional matters, he has represented inventors and developers of new technologies and has helped implement several such technologies, including wireless auditory assistance devices for persons with hearing loss, the use of AM broadcast stations for power utility load management, visual captions on television broadcasts, the Interactive Video and Data Service, compatibility of cellphones and hearing aids, and most recently combining television broadcast and broadband services in the same spectrum.

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Update: Comment Deadlines Available for Proposal to Drop Cable TV Public File Reports of Interest in Video Programming Services

On March 16, 2020, we wrote that the Federal Communications Commission (“FCC”) has proposed to eliminate the rule that requires cable television systems to post in their online public inspection file (“OPIF”) information about the nature and extent of their attributable interests in video program services and which of those services they own are carried on … Continue Reading

DTS: More or Less, What’s Your Guess?

The Federal Communications Commission (“FCC”) has issued a Notice of Proposed Rulemaking looking toward relaxing restrictions on Distributed Antenna Systems (“DTS”) for full-power television stations and making DTS newly available to Class A and Lower Power Television (“LPTV”) stations.… Continue Reading

You May Get Some More Robocalls, Thanks to COVID-19

I hate them, you hate them, we all hate robocalls with a passion (commonly used four-letter descriptions omitted here). But the Federal Communication Commission (“FCC”) had good reason last week to issue a Declaratory Ruling that under the Telephone Consumer Protection Act (“TCPA”), the coronavirus pandemic constitutes an “emergency” which invokes a statutory exception permitting … Continue Reading

Coronavirus News to Share? FCC Won’t Ensnare

The Federal Communications Commission (“FCC”) has issued a Public Notice assuring radio and TV stations that they may share news content and news-gathering resources on an emergency or ad hoc basis during the coronavirus crisis without reducing their arrangements to writing or putting them in their online public inspection file (“OPIF”) as “shared service” agreements … Continue Reading

FCC Invites Comment on Extending Deadline for Total Price Disclosure for MVPD Services

The Federal Communications Commission (“FCC”) has invited comments as to whether it should grant a six-month extension of time for Multichannel Video Program Distributors (“MVPDs”) to comply with the “Right to Transparency” provisions of the Television Viewer Protection Act of 2019 (“TVPA”). This proceeding will be a quick one, with Comments due April 6, and … Continue Reading

TV Must-Carry/Retransmission Consent Elections Must Be Made This Year: Election Notification System Will Now Be All Electronic

In Report and Orders released in July of 2019 and February of 2020, the Federal Communications Commission (“FCC”) has converted the system for television broadcast stations to notify multichannel video program distributors (“MVPDs”), of their election of must-carry or retransmission status from paper sent by certified mail to electronic notices posted on the FCC’s website, … Continue Reading

Radiofrequency Exposure Limits Revised: FCC Proposes Expanding Rules to Cover Higher Frequencies

The Federal Communications Commission (“FCC”) has resolved many of the issues that it has been considering since 2013 with respect to limits on exposure of human beings to radiofrequency (“RF”) energy. An important aspect of the decision is that existing exposure limits will not be tightened. However, the environmental rules dealing with RF exposure have … Continue Reading

FCC Wants You to Dial 988 Before It’s Too Late: Abbreviated 3-Digit Access to Suicide Help Line Proposed

The Federal Communication Commission (“FCC”) has proposed to establish “988” as a nationwide abbreviated telephone dialing code to reach the National Suicide Prevention and Mental Health Crisis hotline. An 800 number (1-800-273-TALK) already universally connects to suicide counselors, but people facing a suicide crisis might not remember such a long number. The same hotline will … Continue Reading

FCC Proposes to End Radio Station Program Duplication Restrictions

The Federal Communications Commission (“FCC”) has proposed to repeal Section 73.3556 of its Rules, which prohibits two commercial AM or two commercial FM radio stations from devoting more than 25% of the hours in an average broadcast week to duplicating programming if they are commonly controlled (through either common ownership or time brokerage) and the … Continue Reading

Who Should Say What to Whom When Cable TV Retransmission Consent Negotiations Fail?

Retransmission consent negotiations have been coming down to the wire more and more in recent years, as broadcasters have sought to recoup more of the value they feel their signals have, and cable operators have resisted increases in their expenses. Federal Communications Commission (“FCC”) rules currently require cable operators to notify both subscribers and the … Continue Reading

Picking NCE and LPFM Winners Simplified: NCE and LPFM Station Transfer Rules Relaxed

The Federal Communications Commission (“FCC”) has changed in its rules for selecting winners from groups of mutually exclusive (“MX”) noncommercial educational full-power radio (“NCE”) and Low Power FM (“LPFM”) applicants and has made it easier for MX applicants to negotiate voluntary time-sharing agreements. In the FCC’s Report and Order, it has also shortened the minimum … Continue Reading

Is it Time for All-Digital AM Radio?

The Federal Communications Commission (“FCC”) has invited comments on whether it should allow AM radio broadcast stations to abandon their analog signals in favor of an all-digital signal format. Preliminary tests have shown that all-digital signals provide improved audio quality and immunity from interference. While the FCC does not propose to require any AM station … Continue Reading

To Be or Not to Be – That is the Channel 6 Analog LPTV Question

The Federal Communications Commission (“FCC”) has invited a new round of comments on the fate of analog Low Power Television (“LPTV”) stations that transmit on Channel 6 and target their audio channel to FM radio receivers. Nearly all of the television broadcast industry has already converted to digital operation. There are no more analog full … Continue Reading

In an Emergency: Which Door Should First Responders Kick In?

About 80% of the 240 million phone calls received by 911 public safety answering points (PSAPs) come from wireless callers. The goal of regulators is that technology automatically identify the location of callers even if callers don’t know where they are or are unable to speak the information because of injury or constraint by an … Continue Reading

What to Do If Your EAS IPAWS Tests Aren’t Working

Your Emergency Alert System (EAS) equipment may have stopped passing through tests received via the equipment’s Internet connection to the Integrated Public Alert & Warning System (IPAWS) because one of the trust root certificates used to validate digital signatures associated with alerts expired a little over a week ago. If your EAS equipment is rejecting … Continue Reading

FCC Invites Comments on Request for Greater Flexibility for TV DTS Transmitters

The Federal Communications Commission (“FCC”) has invited comments on a petition filed jointly by America’s Public Television Stations (“APTS”) and the National Association of Broadcasters (“NAB”), requesting a relaxation of restrictions on where digital television stations may locate Distributed Transmission System (“DTS”) antennas. Digital television technology allows a station to broadcast from multiple transmitters on … Continue Reading

COME AND GET IT! 130 FM Channels for Sale by the FCC (But You’ll Have to Pony Up a High Bid to Get One)

The Federal Communications Commission (“FCC”) has announced that on April 28, 2020, it will offer for sale at auction 130 FM channels that are currently vacant.  These are channels formerly occupied by stations that lost or cancelled their licenses, channels sold to bidders who failed to pay their bids, channels that were offered but drew … Continue Reading

Finding Out Where You Are When You Call 911

The Federal Communications Commission (“FCC”) has adopted new rules requiring manufacturers, importers, vendors, installers and managers of multi-line telephone systems (“MLTS”) to configure those systems to provide automated location information (called “dispatchable location”) and a location-specific callback number when a caller makes an emergency call to 911, at least to the extent feasible using technology … Continue Reading

REC ‘N’ Roll in the FM Band: LPFM Changes Proposed, NCE-FM Changes Requested

Yes, REC Networks (“RECNET”) is on a roll with the Federal Communications Commission (“FCC”) when it comes to the FM radio broadcast band.  Describing itself as a “leading advocate for a citizen’s access to spectrum with a heavy focus on the LPFM and full-service non-commercial radio,” RECNET has succeeded in getting the FCC to propose … Continue Reading

Barreling Down the Road to 5G, FCC Votes to Relax EBS Spectrum Rules

On June 20, 2019, I blogged about the Federal Communications Commission’s (“FCC”) plan to vote on July 10 to relax the rules governing the Educational Broadband Service (“EBS”), including eliminating the requirement to devote part of the air time to educational purposes and opening up license eligibility to commercial entities. Sure enough, the FCC voted, … Continue Reading

Restrictions to Be Lifted from Educational Broadband Service, as FCC Hunts for more Mid-Band Wireless Spectrum

The Federal Communications Commission (“FCC”) has released a tentative Report and Order, scheduled for a vote on July 10, which, if adopted, will lift many restrictions from the Educational Broadband Service (EBS), including allowing educational institutions to sell their licenses to commercial entities and eliminating the requirement that 5% of system capacity be reserved for … Continue Reading
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