FUNDING ELIGIBILITY CLARIFICATION
YESTERDAY WE REPORTED ON THE TWO-STEP PROCESS FOR QUALIFYING FOR DISPLACEMENT FUNDING, AND SOME OF YOU WENT THROUGH THE ROOF THAT WE WERE WRONG - SO WE ASKED THE FCC, AND SEE BELOW WHAT THEY SAY...
- The displacement funding rule making is still open, so while the final decisions have not yet been made, we have the NPRM as a guide. The FCC anticipates that by March 23, 2019, next month, that it will issue a Report & Order, and they suggest we carefully read the NPRM for guidance.
- In the NPRM, the FCC proposes that to be eligible for reimbursement, a station must be an LPTV/translator station that was eligible to file, and did file an application during the Special Displacement Window. The NPRM details that eligibility must be limited to stations with valid displacement construction permits obtained through the procedural mechanisms associated with the Special Displacement Window that will permit them to construct the displacement facilities for which they receive reimbursement.
- From the NPRM..."An LPTV/translator station that filed in the Special Displacement Window whose application is dismissed may subsequently file a displacement application when the Media Bureau lifts the freeze on the filing of such applications. We tentatively conclude that such stations will be eligible for reimbursement under the REA if their later-filed displacement application is subsequently granted. Although they would receive their construction permit through a displacement application that was not filed during the Special Displacement Window, these stations would meet the threshold eligibility criteria under the REA because such stations were eligible to file and [did] file an application in the Special Displacement Window."
To sum it up, you first must have applied in the Displacement Filing Window, and if you were awarded a new CP or CP mod, you then need to pass the on-air test. If your application was dismissed (500+ were), and you apply in the open window, and subsequently are awarded a new CP, you may still qualify for displacement funding, assuming of course, you still pass the on-air test.
So, in ALL cases, you must FIRST be issued a new CP, or CP mod, from the FCC, either from the Displacement window, or the upcoming open window.
- 2,159 Initial Applications For Displacement Channels
- 639 Applications Have Been Dismissed (may apply in open window)
- 1,421 CP's have been granted
- 98 are Pending
What we do not at this time know is:
1) How many of the 639 dismissed applications will file for new channels in the open window, and how many will be issued which qualify as displacement CPs?
2) Of the 1,421 CPs which have been issued, how many will meet the on-air test?
3) Of the 98 pending, how many will be granted CPs, and how many will have to apply in the open window?
What we do know at this time is that if you did not file for a displacement channel, you do not qualify for displacement funding, and even if you did file and got a new channel, you may still not be eligible.