Are any underwriting rules waived because of the emergency? Can we “promote” restaurants or other businesses that are still open?

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There are no specific policies that are waived as a result of the emergency.  Therefore, if an store, restaurant, etc. has provided your station any remuneration (cash, free services, discounts, anything of value), then the acknowledgements must follow the normal guidelines.  In our opinion, we feel that it is appropriate and non-promotional to state that a business is open during the emergency as long as there are no value-added statements encouraging patronage.  The previous non-commercial nature policy documents never addressed business hours.

A safe example could be:

“Programming on KXYZ-LP is made possible in part by Joe’s Steak House located at 123 Main Street in Podunk.  Currently open during the emergency for carry out.  Their phone number is 555-1212.  On the web at joessteakhouse.com.”

This is a very sensitive issue and REC is providing analytical advice which does not constitute legal advice.  For legal advice, contact a qualified attorney.

Topics: 
COVID-19 Coronavirus radio operations
Answer Date: 
Thursday, March 19, 2020