The SBE has released the latest addition to the Broadcast Station Self-Inspection Guides. The new document covers low-power FM (LPFM) stations. The SBE released the AM, FM and TV Guides in 2024. The SBE partnered with the National Association of Broadcasters (NAB) to produce the Guides. These guides are designed to aid stations and Alternative Broadcast Inspection Program (ABIP) inspectors in evaluating a broadcast station’s compliance with FCC rules and regulations.

The Guides are being developed to replace the FCC Self-Inspection Checklists that were first released in the 1990s, but had not been updated for nearly 15 years. While the previous Checklists only provided references to rules, the new SBE Guides include recommended practices for stations to establish policies and procedures for their own stations to ensure overall regulatory compliance.

The SBE Government Relations Committee, chaired by Charles “Ched” Keiler, CPBE, 8-VSB, ATSC3, CBNE, formed a working group of SBE members in April 2022 to begin reviewing and updating the Guides. Additional Guides for other broadcast services are under review and will be released later.

The Guides are available for download from the SBE website under the Legislative/Regulatory and Resources tabs. They are free to SBE members.

The SBE has released new Broadcast Station Self-Inspection Guides for FM and TV broadcast stations. The SBE partnered with the National Association of Broadcasters (NAB) to produce the documents, which are the first part of a planned series to cover all broadcast services. These Guides are designed to aid stations and Alternative Broadcast Inspection Program (ABIP) inspectors in evaluating a broadcast station’s compliance with FCC rules and regulations.

The Guides were developed to replace the FCC Self-Inspection Checklists that were first released in the 1990s, but have not been updated for nearly 15 years. While the previous Checklists only provided references to rules, the new SBE Guides include recommended practices for stations to establish policies and procedures for their own stations to ensure overall regulatory compliance. The Guides are available for download from the SBE website under the Legislative/Regulatory and Resources tab. They are free to SBE members.

The FCC is in the midst of a proceeding examining whether and how to repurpose the 12.7-13.25 GHz Band for new “expanded use”-namely, broadband wireless. Many broadcast stations make use of the band for crucial broadcast auxiliary services (BAS), including for links from studios to transmitters (STLs and TSLs), electronic newsgathering (ENG), and intercity relays (ICRs). Because the “expanded use” contemplated in the band may displace or require the repack of incumbent BAS operations, the Commission is requiring the majority of BAS licensees in the 12.7 GHz band to complete a certification as to the accuracy and operational status of their operations in the band.

The FCC has issued a Public Notice announcing that those certifications are due on or before November 29, 2023. It will be extremely important for broadcasters to timely and accurately complete and file those certifications; the FCC has indicated that it will use the certifications as the mechanism by which to grant or deny broadcasters’ future ability to receive various benefits in the band, including reimbursement for relocation, interference protection, and/or repacking to a new location within the band.

The below synthesizes some of the most important generally applicable aspects of the Notice; however, the following summary should not be viewed as a substitute for a careful examination of the Notice itself.

• Certifications for BAS licenses must be filed in ULS. Broadcasters will need to file certifications for their affected 12.7 GHz Band authorizations in the Commission’s Universal Licensing System (ULS) as a “non-docketed pleading” associated with all BAS call signs to which the certification applies. The Notice provides more information on pages 2 and 3, including the required content for each certification. Because ULS functionality can at times be limited due to unexpected technical issues, it is strongly recommended that broadcasters not wait until the last minute to prepare and submit these filings.
• Certifications must certify (1) the present accuracy of all information reflected on the license, and (2) that the facilities are operating as authorized. A sample certification format is included at the end of the Notice as “Attachment 1.”
• Limited exemptions. If you applied for a new or modified license on or after January 1, 2021-including a modification request in response to the Notice-the specific call sign involved in the application is exempt from the certification requirement. To be clear, this exemption does NOT apply to applications solely for renewal.
• Some modifications permitted; also due by November 29. If you discover incorrect information on your current authorizations in the Band, the Public Notice outlines the procedures you must take to modify your authorization to reflect accurate information. Minor modifications will be permitted so long as a licensee can establish in an exhibit to the application either that (1) the modification would not add to any relocation costs, if applicable in the future, or (2) a waiver of the current filing freeze would be justified. Any other (non-minor) modifications must include a request for waiver of the freeze, and will be evaluated on a case-by-case basis.

If you have BAS operations in the 12.7 GHz band, you should carefully examine the Notice and consult your regulatory counsel to ensure a full understanding of how the certification requirements and procedures affect your own authorizations.

The FCC has established GN Docket 22-352, titled Expanding Use of the 12.7-13.25 GHz Band for Mobile Broadband or Other Expanded Use. In this proceeding, the FCC has proposed repack and/or relocation of broadcast (and other) existing authorizations in the 12.7-13.25 GHz band. A forthcoming certification deadline for existing, incumbent 12.7-13.25 GHz broadcast licenses operating under Part 74 is outlined as part of this proceeding, but the FCC has not yet set the actual deadline by which such certifications must be filed. Accordingly, the SBE does not yet know when the FCC will require licensees to file such certifications or how well that date—as well as the requirements for making such certifications—will be communicated to licensees.

It is imperative that you verify all license data in the FCC’s Universal Licensing System (ULS) related to your 13GHz broadcast auxiliary services licenses as soon as possible. In addition, if you are currently using 13GHz for ENG, not fixed links, please notify SBE Frequency Coordination Manager RJ Russell at rjrussell@sbe.org of the licensee callsign and designated market area.

More information is available at https://docs.fcc.gov/public/attachments/FCC-23-36A1.pdf, paragraphs 83-84 and 143-147 of which further explain the need to confirm the accuracy of ULS data for your 13GHz licenses and prepare to certify as accurate all information on such licenses that fall under Part 74.