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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Extended Comment Deadlines for Regulation of RF Emissions in Higher Frequency Bands

On January 9, 2020, we blogged about a Federal Communications Commission (“FCC”) decision resolving many of the issues that it had been considering with respect to limits on exposure of human beings to radiofrequency (“RF”) energy. The FCC also invited comments as to whether it should extend its regulation of RF emissions from the present range … Continue Reading

Comment Deadlines Established for Relaxation of DTS Restrictions

On April 2, 2020, we wrote about proposals by the Federal Communications Commission (“FCC”) to relax restrictions on Distributed Antenna Systems (“DTS”) for full-power television stations and to make DTS newly available to Class A and Lower Power Television stations. The proposals have now been published in the Federal Register, establishing deadlines for Initial Comments on June … Continue Reading

FCC Lobs More Fireballs at Robocallers and Spoofers

The Federal Communications Commission (“FCC”) has taken several steps in recent years to deter robocalls of all kinds, with some success, but not enough to give us poor ordinary folks the telephone peace and quiet for which we yearn. Last year, Congress passed the Pallone-Thune Telephone Robocall Abuse Criminal Enforcement and Deterrence Act (“TRACED Act”), … Continue Reading

New LPFM Rules Adopted as Anticipated

On April 16, 2020, we wrote about new rules governing applications for and the operation of Low Power FM (“LPFM”) radio stations that were scheduled for adoption by the Federal Communications Commission (“FCC”) at its monthly meeting on April 23.  The new rules were indeed adopted, although by written vote of the Commissioners the day … Continue Reading

“Sweeps” Are Under the Rug: FCC Seeks Comment on New Metrics to Establish Significant Viewership

The Federal Communications Commission (“FCC”) has invited comments on it’s Notice of Proposed Rulemaking (“NPRM”) on whether it should update its rules that determine whether a television broadcast station is “significantly viewed” in communities outside of its Designated Market area (“DMA”) for purposes of carriage on Multichannel Video Program Distribution (“MVPD”) systems, both cable and … Continue Reading

Low Power FM Rule Changes Slated for April 23 FCC Vote

The Federal Communications Commission (“FCC”) has released a draft of a Report and Order  scheduled for a vote on April 23, looking toward making several changes in the rules governing Low Power FM (“LPFM”) radio stations.  We wrote an article last year when the rules were proposed.  Not all the requests for rule changes will … Continue Reading

Corrected Comment Deadlines for Regulation of RF Emissions in Higher Frequency Bands

On January 9, 2020, we blogged about a Federal Communications Commission (“FCC”) decision resolving many of the issues that it had been considering with respect to limits on exposure of human beings to radiofrequency (“RF”) energy. The FCC also invited comments as to whether it should extend its regulation of RF emissions from the present range of … Continue Reading

Effective Date of Truth-in-Billing Statute Deferred

Last year, a new law, the Television Viewer Protection Act of 2019 (“TVPA”), was enacted, requiring Multichannel Video Programming Distributors (“MVPDs”) and providers of fixed broadband services to disclose all charges that a consumer will have to pay before he or she signs up for service.  The statute requires compliance by June 20, 2020, but … Continue Reading

Is Hyper-Local FM Radio Coming?

A company called GeoBroadcast Solutions, LLC, has filed a petition for rulemaking with the Federal Communications Commission (“FCC”), to allow FM radio stations to operate on-channel boosters that do not entirely duplicate the content of the main station.  The idea is to allow each booster to insert local content intended for just the portion of … Continue Reading

TV Stations Granted Limited Waiver to Pre-Empt Children’s Programming to Air Local Events in Support of Social Distancing

The Federal Communications Commission’s (“FCC”) Media Bureau announced today that from now until April 30, 2020, full power and Class A TV stations may pre-empt children’s television programming to broadcast live or same-day, recorded community events to enable the public to view those events without attending in person, in furtherance of the “social distancing” advocated … Continue Reading

FCC Waives Sponsorship Identification for Sponsored COVID-19 PSA’s

The Federal Communications Commission (“FCC”) has announced a waiver of broadcast sponsorship identification requirements concerning air time donated by commercial advertisers for public service announcements (“PSAs”) provided by the Centers for Disease Control and Prevention (“CDC”) and other government agencies addressing the COVID-19 emergency.… Continue Reading

You May Get Some More Robocalls, Thanks to COVID-19 – But Maybe Not So Much

On March 25, 2020, we blogged that the Federal Communications Commission (“FCC”) had issued a Declaratory Ruling under the Consumer Protection Act (“TCPA”), that the coronavirus pandemic constitutes an “emergency” which invokes a statutory exception permitting certain kinds of robocalls to be made and texts sent without the consent of the recipient.  Since that date, … Continue Reading

Dates Announced for Comments on Regulation of RF Emissions in Higher Frequency Bands

On January 9, 2020, we blogged about a Federal Communications Commission (“FCC”) decision resolving many of the issues that it had been considering with respect to limits on exposure of human beings to radiofrequency (“RF”) energy. The FCC also invited comments as to whether it should extend its regulation of RF emissions from the present … Continue Reading

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
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