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Repack Update: FCC Invites Comments on Widelity II

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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) alike – an idea of the expenses they’re likely to face, the Commission hired Widelity, Inc. to come up with a standardized catalog of likely costs. The Commission published Widelity’s preliminary list in 2014 and invited comment on it.

That was more than two years ago, and we’re still months (or more) away from the repack. So the FCC is already thinking about updating the initial Widelity catalog. To that end, it asked Widelity to take a look at the original list. Widelity has come up with a number of suggested changes, and now the Commission is looking for more input from the public.

To come up with its proposed revisions, Widelity sought input from a number of industry stakeholders (including this firm), looking not only for updates on prices that might have gone up but also for categories of expenses that might have changed or might need to be added. The result: an updated catalog which: eliminates some expenses that technological advances have made unlikely; increases baseline costs for many items; and adds new reimbursement categories to cover items that either were overlooked or have developed since the first catalog. (For example, liquid cooled solid state UHF transmitters are now available in more power ranges, additional types of antennas are listed, and a provision for professional fees in connection with transition timing or co-ordination has been added.)

Here’s the revised list (with the proposed revisions clearly and conveniently identified). If you expect to be having to modify your facilities to accommodate the repack, you would be well-advised to take a close look and let the FCC know of anything you might disagree with.

For its own part, the Commission is also proposing routine, annual modifications to the baseline catalog costs based upon the Bureau of Labor Statistics Producer Price Indexes (PPI). (If you’re heavily into such things, you’ll probably want to know that the Commission is planning to use the PPI annual average – a/k/a the WPUFD4 series – rather than the seasonally-adjusted final demand index.)

Once the Commission has considered any incoming comments and made any edits deemed necessary, it will adopt a revised catalog; the baseline price list will be released as a stand-alone document and also embedded in the online Reimbursement Form, FCC Form 2100, Schedule 399. As the Commission has emphasized, a licensee seeking reimbursement will not necessarily be limited to the items or amounts in the catalog … BUT the catalog will be the Commission’s starting point in considering reimbursement requests, and any licensee seeking reimbursement either for an item not on the list or in an amount greater than the baseline range will have to explain convincingly and with evidence. That being the case, if you have anything to say about the accuracy, or lack thereof, of the cost estimates, now is the time to speak up. Once the revised catalog is adopted, it’s likely to be an uphill fight to argue otherwise.

Comments on the revised catalog are due by November 14, 2016; reply comments by November 29. Comments and replies may be filed through the FCC’s ECFS online filing system; refer to Proceeding Nos. 16-306 and 12-268.


Expecting Money From The FCC Post-Incentive Auction?

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webinar-1If you’re the owner of a full-power or Class A broadcast television station or are a multichannel video program distributor, and anticipate receiving a winning bid or seeking reimbursement funds from the Commission post-incentive auction, how will you get your money? The FCC has created an online tutorial to explain how this will work.

To see the tutorial, go to the Auction 1001 website  and click on the “Education” tab.

All entities doing business with the FCC must update their information in the Commission Registration System (CORES), so the agency has the appropriate point of contact for payment and banking questions. The tutorial describes how to make changes in the updated version of CORES.

Those who expect to receive FCC payment(s) after the incentive auction must also submit additional data, including bank account information, after taking these initial steps to update their records. The changes to the system are designed to strengthen the security of records, improve the system’s usability and improve the Commission’s compliance with various statutes that govern debt collection and the collection of personal information, according to the FCC’s Incentive Auction Task Force.

These required changes and updates include: (1) designating specific FCC Usernames to access FCC Registration Numbers (FRNs) and related records (multiple usernames for each FRN with different levels of access are permitted); (2) requiring valid email addresses for online access to the system; and (3) establishing password-recovery security questions specific to each Username.

Those who watch the online tutorial will learn how to update their FRN point of contact information as well as how to register for a new FCC Username Account; register for a new FRN; associate a Username to an existing FRN; reset a Username-Password; approve or reject an FRN Association Request; update FRN information; and administer a View FRN Financial Info Permission in CORES and the new FCC User Registration System. The agency says it’s critical that it have complete and accurate CORES information for everyone who expects to receive an auction-related payment. Those who do should follow the procedures in the tutorial; the Commission plans to hold an additional webinar on post-auction payment processes in the future.

Incentive Auction Update: Quiet Period Partially Lifted, Channel Reassignments Coming, M&A Gold Rush Begins

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After teasing that such relief was coming, the FCC has confirmed a partial waiver of the limitations on communications for reverse auction participants. In other words, broadcasters who participated in the auction, regardless of whether they were successful bidders or will remain on the air, are now free to communicate with all parties about their status.

This relief comes at a critical time when the post-auction repack transition is about to get underway. Stations are now free to discuss future plans for repacking, as well as enter negotiations for sales, acquisitions and channel shares, without threat of violating the FCC’s anti-collusion rules. The one caveat to keep in mind: forward auction participants are still forbidden from divulging their bids or bidding strategies, so broadcasters should not call up the local wireless carrier and ask (directly or indirectly) if they are bidding in the market.

The FCC also announced that it is mailing to broadcasters this week confidential letters to apprise stations that are subject to repacking, or elected to move to a VHF or lower-VHF channel, of their new channel assignments, technical parameters and the transition phase to which they will be assigned. This is being done in confidence as the official determination of channel reassignments will not be final until the Incentive Auction is complete, which will be signaled only by the release of the Auction Close and Channel Reassignment Public Notice. That notice is not expected for at least 6 weeks.

The Public Notice also provided some additional guidance for stations wondering how station sales and acquisitions will be processed while the auction is still technically pending. The Commission advises that stations may enter into agreements and file applications seeking consent to assignment, but cautioned that transactions would not be permitted to close until after the official end of the auction.

Finally, the Public Notice also reminded broadcast licensees of changes to the Commission Registration System (CORES) which is used to assign FCC Registration Numbers (FRNs). FRNs are required to do business with the FCC.  These changes will require all licensees to create a new CORES log-in and password, which they can then associate with their existing FRNs.

 

FCC Releases Instructions on Receiving Incentive and Reimbursement Payments after the Incentive Auction Closes

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fcc building-1On March 29, 2017, the FCC released a Public Notice providing instructions to full power and Class A television broadcasters and Multi-Channel Video Programming Distributors (MVPDs) on receiving incentive and/or reimbursement payments following the closure of the Incentive Auction.  The Public Notice stated that, in order to receive payments, winning bidders in the reverse auction (i.e., broadcasters that successfully bid to relinquish some or all of their spectrum rights) must submit an FCC Form 1875 (Reverse Auction Payments), and broadcasters and MVPDs eligible to receive reimbursement payments from the Television Broadcaster Relocation Fund for costs incurred during the reverse auction and repacking process must submit an FCC Form 1876 (Reimbursement Payments).  While the application processes are similar for Reverse Auction and Reimbursement Payments, payment recipients may receive their disbursements at different times depending on the type of payment for which they are eligible.  In addition, while the Public Notice did not announce a deadline for reimbursement payees to file Form 1876, entities receiving Reverse Auction Payments must file their Form 1875 by no later than 20 days after the FCC releases its public notice closing the auction (currently expected in early to mid-April).

CORES Update.  Prior to submitting payment applications and receiving payment, all Reverse Auction and Reimbursement Payment applicants must update their Commission Registration System (CORES) accounts by:  (1) creating an FCC Username Account; and (2) designating at least one FRN Administrator.  Detailed instructions on how applicants may complete these steps can be found on the FCC’s CORES site.  We have also kicked the tires on the new CORES, so please feel free to contact us if you need assistance.

Payment Applications.  The application processes for Reverse Auction and Reimbursement Payments both follow a two-step process to reduce “the risk of error or fraud.”

First, all payment applicants must submit to the FCC a signed and notarized FCC Form 1875 or 1876, as applicable, along with a either a bank account verification letter or redacted bank statement confirming ownership of the bank account to which payments are to be made.  Applicants may only designate one bank account to which payments are to be made, but may designate third party payment recipients on their applications.  Reverse Auction Payment applicants must submit a separate application for each station with a winning bid in the reverse auction.  Reimbursement Payment applicants must submit a separate application for each reassigned station or for each MVPD eligible for reimbursement as a result of expenses during the reverse auction and repacking process.

Second, after determining the accuracy of the payment applications, the FCC staff will grant each applicant access to the CORES Incentive Auction Financial Module.  For Reverse Auction Payment recipients, this access will be granted to only the single individual listed in the Form 1875; Reimbursement Payment recipients may identify two individuals to receive access in their Form 1876 .  Other users may later be granted access to view certain limited financial information, but only the individuals listed in the Forms 1875 and 1876 will be able to enter such information in the system.  In the Financial Module, applicants must enter bank account information for the designated payment recipient.  The FCC will then compare the financial information entered in the Financial Module with that submitted on the applicable FCC Form 1875 or 1876, and will contact the applicant regarding any discrepancies prior to payment.

Payment Disbursements.  While application processes for Reverse Auction and Reimbursement Payments are similar, the payment disbursement processes differ between the two.

Due to the fact that Reverse Auction Payments cannot be made until forward auction licenses are granted (and payments made), the Commission demurred from offering a precise timetable for issuing Reverse Auction Payments.  In addition, the Commission noted that if it is able to release only some Reverse Auction Payments at any given time (based on its receipt of forward auction payments and grant of forward auction licenses), it would do so on a schedule that was designed to accommodate the repacking schedule for continuing broadcasters.  In other words, if forward auction licenses are granted on a rolling basis, Reverse Auction Payments may also be made on a rolling basis, with those stations who may hold up the transition schedule getting paid first.  When the FCC is ready to disburse any given Reverse Auction Payment, it will release a “Ready to Pay Public Notice,” directing the U.S. Treasury to disburse payments to eligible recipients.  Reverse Auction Payments are deemed to be made within five days of release of the Public Notice.

The process for disbursing Reimbursement Payments is, necessarily, somewhat more complicated.  Within 90 days of the release of the public notice closing the auction, any entity expecting to receive reimbursements must submit an estimate of such reimbursements to the Commission.  The Media Bureau will then make an allocation of up to 80% of those costs for commercial broadcasters and MVPDs and 90% for non-commercial broadcasters.  Entities will then be entitled to “draw down” against these allocations as they incur expenses.  As the three-year reimbursement period proceeds, these allocations will be adjusted by the FCC.

Because Reimbursement Payments will be made on a rolling basis, and subject to the allocation noted above, the Commission does not make any estimate as to how soon after a request a payment will be made.  All Reimbursement Payments, however, are to be made within three years of completion of the forward auction pursuant to the Spectrum Act.  In contrast to Reverse Auction Payments, the Commission does not have the authority to direct the Treasury to make Reimbursement Payments to eligible recipients and cannot control when Treasury does so after receive the Commission’s instructions.  Instead, the CORES Incentive Auction Financial Module will be updated when the Treasury has made payment.

Ownership Changes for Stations Receiving Reimbursements.  The Commission’s Notice also addressed how the Commission will handle the (potentially numerous) situations where a station receiving Reimbursement Payments is transferred or assigned during the reimbursement period.  Upon receipt of a notice of consummation of such a transfer of assignment, the Commission will de-activate the bank account information of the assignor and hold any pending reimbursement requests.  The assignee will be required to submit a Form 1876, and otherwise follow the same process to provide account information and gain access to the Financial Module.  The Commission in the Public Notice promised that, prior to granting or accepting any consummation notices, it would provide additional guidance to the parties involved regarding reimbursement procedures.

Please contact us should you have any questions regarding the Reverse Auction and Reimbursement Payments processes after the closure of the Incentive Auction.

FCC Brings Spectrum Auction to a Close, Sets Repack Transition in Motion

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fcc building-1 With the release of the Incentive Auction Closing and Channel Reassignment Public Notice (affectionately known as the “CCR”), the FCC officially draws the spectrum Incentive Auction to a close. The CCR is a must-read for TV broadcasters and wireless carriers alike. It announces broadcast and wireless winning bidders, sets deadlines and timetables for filings, and provides buildout benchmarks relevant to both broadcasters and wireless companies to convert the new 600 MHz band to wireless use.  Of particular interest to FHH broadcast clients is the setting in motion of the Post-Incentive Auction Transition (“Repack”), starting with a 90-day scramble to file construction permit applications and relocation expense reimbursements for repacked stations which ends on July 12, 2017.  LPTV stations also will be impacted by the channel reassignment and will need to prepare for displacements starting this fall.  Fletcher, Heald & Hildreth PLC is ready to guide you through this process – give us a call.

Incentive Auction Second Priority Filing Window Opens: What to Know

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On Sept. 20, the FCC announced the second filing window for all full power and Class A television stations receiving new channel assignment as part of the post-incentive auction repack. The filing window will open Oct. 3 and close at 11:59 p.m. EDT on Nov. 2. During this “second priority” filing window, all eligible stations may file applications requesting authority to operate on a new channel or with expanded facilities.

Stations eligible to file during the second priority filing window include all Class A and full power stations that were assigned new channels by the Commission during the repack, including those who were involuntarily assigned new channels, and those who elected to move from a UHF to VHF channel (or from high VHF to low VHF) as part of the auction. If an eligible station’s initial post-auction construction permit application remains pending, it can submit its second priority filing window application as an amendment. If the station’s initial construction permit application has already been granted, the station will need to apply for a modification of that permit.

Second priority window applications may request expanded facilities, provided that the requested facilities would qualify as a minor change under the Commission’s rules. Applicants may also request authority to operate on a different channel, although any application requesting a channel change will be treated as a major change, and will be subject to local public notice procedures and to the filing of petitions to deny.

Applicants in the second priority window also must ensure that their applications protect any facilities applied for in the initial 90-day window for post-auction applications or the first priority filing window (closed September 15), regardless of whether those applications have been granted or remain pending. For Class A stations, the FCC reminds applicants that those stations, “must also demonstrate that the proposal would not cause interference to a low power television or television translator facility previously authorized or proposed.” If for any reason a second priority filing window application is incomplete, the FCC will allow the applicant an opportunity to submit amendment via LMS in order to address the issues.

As with other filing windows, the Commission also offers a reminder that filing early will not provide a station with greater protection. All applications filed during the window will be treated as filed on the last day of the window for determining any conflicts. If any applications filed during the second priority window are mutually exclusive, the Commission will offer the applicants 90 days in which to resolve that conflict amongst themselves.

Finally, the Commission reminds potential applicants that any additional costs incurred in applying for or constructing expanded or alternate channel facilities requested for in the second priority window (or after) will not be eligible for reimbursement.

Got questions? Feel free to reach out so that we can best help you navigate the hurdles.

FCC Grants Request by Fletcher, Heald & Hildreth to Revise Post-Auction Broadcast Transition Phase Assignments and Deadlines for Puerto Rico and U.S. Virgin Islands in Wake of Hurricane Maria

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January 16, 2018 – Fletcher, Heald & Hildreth is proud to announce that, through its efforts, the FCC’s Incentive Auction Task Force and the Media Bureau division on Jan. 11, 2018 granted a request to allow 20 broadcast TV stations in Puerto Rico and the U.S. Virgin Islands to construct post-incentive auction facilities early.

The request was spearheaded by Washington, D.C.-based telecommunications and broadcasting law firm, Fletcher, Heald & Hildreth (“FHH”) on behalf of a coalition of full-power and Class A television licensees of repacked stations in Puerto Rico and the U.S. Virgin Islands to allow the stations to transition early. This request was filed in response to the devastation caused by Hurricanes Maria and Irma in fall 2017. Chairman Ajit Pai in a statement said that this measure is an, “important step to expedite the restoration of vital communication services.” Stations can start their testing of post-auction channels at 12:01 a.m. on July 1 and must discontinue operations on these channels no later than 11:59 p.m. on Aug. 1.

The filing, made by FHH attorney Davina Sashkin, Esq., emphasized that the current conditions on the island of Puerto Rico and the U.S. Virgin Islands made the request a smart and necessary move by the Commission. As noted in the filing, “If pre-hurricane economic and infrastructure conditions, particularly in Puerto Rico were poor, now conditions are dire.” This, the filing stressed, means that there “are simply not enough resources for broadcasters to contemplate building duplicate broadcast facilities over the course of the next 20-30 months.”

The devastation to island infrastructure generally and the broadcast community specifically, means that many television stations still, nearly four month after the hurricanes, are trying to rebuild. The stations were facing a Phase 3 transition, which would have required rebuilding the stations now, only to have to build new facilities in 2019. The capital demands for a double-build were simply too much for the broadcasters of the island to bear twice in such a short period of time. Therefore, the coalition requested the Commission to permit building of facilities only once on the reassignment channels to avoid costly expenses. This timing allows Puerto Rico and the U.S. Virgin Islands TV broadcasters to utilize currently available funds from federal disaster relief and low-cost government loans in combination with repack reimbursement funds to begin the process of returning stations to full operation.

“The broadcasters on the islands are working together in a collaborative way to rebuild, and they wanted to be able to maximize this opportunity to coordinate building the new television infrastructure required in the post-Auction environment,” said Sashkin. “The FCC agreed that these licensees, who have been through so much, should have the opportunity to minimize costs, maximize coordinated effort, and speed rebuilding of a vibrant, integral industry that provides news, information, and entertainment to more than three million American citizens each day.”

On a recent trip to Puerto Rico, Chairman Ajit Pai  said that there are no dedicated funds available to the FCC to assist broadcasters, requiring the Commission to be “creative” in solving this problem. It is Sashkin’s and the coalition’s belief that granting this early transition is the type of creative solution that the FCC needs to rebuild the region’s broadcasting systems.

For information about the firm, visit www.fhhlaw.com or contact Helena Okolicsanyi at okolicsanyi@fhhlaw.com for press inquiries. A PDF version of this press release can be found here.

Repack Funds and First Responders – What Broadcasters Need to Know About the ‘Omnibus’ Spending Bill of 2018

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Photo by Jomar courtesy of the Creative Commons Licence

On Friday, March 23 President Trump signed a $1.3 trillion appropriations bill that will mean some significant changes to the broadcasting community. The 2,232-page omnibus bill not only includes an additional $1 billion for spectrum repack on top of the already $1.75 billion already allocated, but also changes how broadcasters are treated in terms of access to funding, resources and critical areas in cases of disasters.

To cut right down to the chase: this is good news for broadcasters all around.

Repack Funds. First, the bill authorizes $1 billion in additional funding to supplement and expand the TV Broadcaster Relocation Fund for reimbursement of costs incurred by post-Incentive Auction repacking of full-power and Class A TV stations. $600 million is specifically allocated toward supplementing the $1.75 billion repack funds for these stations – alleviating what was expected to be at least a $250 million shortfall in funds.

The bill also specifies that $150 million of the total shall be used to pay reimbursement costs incurred by low-power TV station and translator stations displaced by the repack. Another $50 million is specified for FM stations which will incur costs due to collocated TV stations transitioning to their post-auction channels. This budget will ensure that the estimated 600+ affected FM stations will not have to be forced to operate at reduced power or be forced off the air due to the TV repack. Finally, the bill sets aside $50 million help educate consumers during the transition process.

Broadcasters as First Responders. Second, the bill broadens the definition of “first responders” during a disaster to include radio and television broadcasters. Recognizing the critical role that radio, television, cable, phone and satellite services play during times of crisis, the new definition will allow these entities to be provided priority access to funding and resources through FEMA (such as fuel for generators) that were previously restricted to traditional first responders.

In addition, inclusion as a designated first responders will permit broadcasters access to crisis areas, both for reporting on a disaster and for maintaining station operations. As demonstrated in 2017 with Hurricanes Maria, Harvey and Irma, broadcasters are crucial to ensuring public safety and the dissemination of critical information before, during, and after disasters. Designation as first responders will make it easier to ensure stations can stay on the air or resume operations quickly, and provide the best possible news and information to their audiences.

If you have any questions about how these changes will directly impact you, please contact us.


Reminder: Special LPTV/Translator Displacement Filing Window Opens April 10

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In case you forgot, this a reminder to Low Power Television and TV Translator broadcasters of the FCC’s Special Displacement Window for LPTV Stations. The FCC issued a 60-day advanced notice of the filing window which opens up on Tuesday, April 10 and lasts through Tuesday, May 15 at 11:59 p.m. EST. This special window is limited to applications to change channels, which may be filed only by operating LPTV stations and TV translators being displaced from their current channel as a result of the TV spectrum repack. Other LPTV stations and translators seeking to change channels must wait for a later application filing opportunity.

An LPTV is considered “operating” for purposes of eligibility for this window if it was constructed and licensed, or had a license to cover application on file, as of April 13, 2017 – the date on which the incentive auction closed.

“Displaced” stations are defined by the Media Bureau as stations that:

  • are authorized on channels that are being taken by a full power or Class A television station in the repacked television band (channels 2- 36) as a result of the incentive auction and repacking process;
  • are authorized on frequencies that will serve as part of the 600 MHz Band guard bands (which includes the duplex gap); or
  • are authorized on channels 38-51.

All applications filed during the Special Window will be treated as having been filed on the same date, so there is no advantage to filing on the first day of the window. There are other strategic considerations affecting when to file, which may vary with the circumstances of each station. We at CommLawBlog strongly suggest not waiting till the last day to file, because FCC online applications system have in the past crashed when overwhelmed with too many filings on one day.

The one exception to all applications being treated the same is that applications for fill-in translators by full power stations filed on any day will have priority over LPTV and other translator applications.

If you need advice on navigating this filing window, we will have attorneys ready to help with strategy and application preparation. Reach out to us at www.fhhlaw.com or call us at (703) 812-0400.

*Editor’s note: This post was updated on 04/02.

FCC Proposes LPTV and FM Repack Reimbursement Schedule

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The Federal Communications Commission (“FCC”) has invited comments on a “catalog” of categories and amounts it thinks are reasonable for reimbursement of expenses incurred by low power TV (“LPTV”) stations as a result of involuntary channel changes imposed by the post-incentive auction repacking of the TV spectrum. Congress initially appropriated funds to reimburse costs incurred by only full power TV stations changing channels; the full power TV industry is currently going through the reimbursement process.  Congress later added more money so that displaced LPTV and affected FM radio stations could also seek cost reimbursement, with FM stations eligible to claim reimbursement if they are forced temporarily or permanently to modify or to relocate their transmission facilities to accommodate repacked TV stations.  We’ve previously discussed this portion of the repack reimbursement process here and here

The catalog indicates costs estimated by the FCC for certain kinds of equipment and services it expects stations to incur during the repack.  It was prepared by the same outside contractor that prepared a similar catalog of costs for full power TV and Class A stations.  The catalog does not address eligibility for reimbursement, which is the subject of a separate proceeding.  In general, to be eligible, an LPTV station: (1) must have been displaced by the repack, (2) must have filed an application for a new channel, (3) must have had its application granted by the FCC, and (4) must actually build facilities on its new channel.  The FCC does not propose to pay for more than one channel change for LPTV stations, even though some stations will be forced off their existing channel before a permanent displacement channel is available and thus will have to move first to an interim channel and later to a final channel. Eligibility for an FM station hinges on the station having been forced: (1)  to move to a new tower, (2) to relocate its antenna(s) on an existing tower, and/or (3) to operate with auxiliary or other temporary facilities during the time that a TV station is constructing new facilities on a shared tower.

While the proposed catalog is not the final word on amounts the FCC will reimburse, it is significant for several reasons.  First, it indicates the types of expenses the FCC may be willing to reimburse.  The list is comprehensive and includes both equipment and services, although we notice the FCC thinks that FM stations will incur HVAC costs, but LPTV stations will not.  Second, the costs in the final catalog will serve only as benchmarks.  Stations that actually incur higher costs will be able to claim them, though no stations will be able to recover costs beyond actual cash expenses they can prove they paid out; but stations seeking reimbursement above catalog limits will have their feet held more closely to the fire in terms of having to prove why they need to spend so much more than stations whose claims are within the catalog limits.  Finally, the FCC will be able to pay out only the amount of money made available by Congress; so if total claims exceed available funds, the FCC will likely get even tougher during the review process and may ultimately reduce claims it does approve to less than 100 cents on the dollar.

The reimbursement claims experience for full power and Class A stations has not always been easy, as federal fraud laws apply to FCC processes, resulting in the FCC’s acting very meticulously (sometimes to the point of frustrating claimants) in requiring complete and detailed documentation of incurred costs and of actual amounts paid to vendors.  If you believe that you are eligible for reimbursement, you should review the catalog carefully and then keep all receipts and other documentation in detail for every dollar you hope to claim.  You should also obtain written price quotations from vendors in advance of making purchases.  Keeping good records from the outset will make life a lot easier when it comes time to file a claim.

Meanwhile, you should also review the FCC’s catalog of expenses and consider filing comments with the FCC if you feel the FCC has underestimated the cost of necessary equipment and/ or services or omitted them entirely.

Comments will be due November 21, 2018, with replies due on December 6, 2018.  We will be happy to help prepare comments and will also be ready to assist clients with future reimbursement claims.





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