However, based on some of the requests for FM translators from LPFM stations, we do need to reiterate the actual rules and the mindset of the FCC back in 2013 when they created these rules. We have seen cases where LPFM stations are wishing to place a station about 10 to 15 miles away, especially in more rural areas where communities are further spaced from each other or they are expecting a nice fat signal that will cover a lot of additional communities. Some may see where “fill-in” FM translators are covering and think that they could get similar results.

When the ability for LPFM stations to own translators were being discussed in the proceeding that resulted in the Sixth Report and Order in 2013, you had two sides of this issue. NAB and NPR opposed cross-ownership because of the potential impact to the “local character” of the LPFM service.1 REC countered stating that cross-ownership would enable LPFM stations to better reach their local communities; National Lawyer’s Guild and Media Alliance stated that translators could help overcome some terrain issues and several stated that FM translators could allow stations to serve their entire intended service area, such as a single county.2

To understand this concern about local character, we need to go back to the original 2000 Report and Order where the intention of LPFM was to provide service to “very localized communities and underrepresented groups within communities”.3 Over the past 26 years, the objectives of the LPFM service have not changed. It is to provide a “hyperlocal” service, which Merriam-Webster defines as “limited to a small geographic area.” The original concept of LPFM was to put small stations mainly in urban neighborhoods of larger cities to serve populations that were not being represented by full-service radio. Unfortunately, several events including the Radio Broadcast Preservation Act of 2000 and the Auction 83 “Great Translator Invasion” filing window of 2003 prevented new LPFM stations in many urban areas and as such, LPFM would be used in a manner that was not consistent with the original intentions but that was simply because these were the only places where spectrum was available.

One of REC’s main arguments in the various LP-250 proceedings over the past decade expressed a need to redefine what is considered “hyperlocal”, especially in more rural areas where “a country mile seems longer than a city mile”.

The bottom line is that the FCC wanted to keep LPFM service areas small and that was reflected with the rules put in place to allow for the cross-ownership of FM translators. Specifically, the rules require:

• An application for an LPFM commonly-owned FM translator must propose a 60 dBu service contour that overlaps the 60 dBu service contour of the LLPFM station being rebroadcast. This is to assure that LPFM stations keep their local character by providing an contiguous extension of the existing LPFM service area instead of being able to “leap-frog” (the FCC’s own words) into other communities.

• An application for an LPFM commonly-owned FM translator may not be placed more than 10 miles from the LPFM station in the top-50 markets or more than 20 miles in all other areas. These are distances consistent with Commission’s past definitions of what is considered “local” in an LPFM context. With the other restrictions in place, it may not be possible to place a translator more than 10 miles from the LPFM but there are some certain terrain situations, especially on the part of the LPFM where this could be possible.

• An LPFM commonly-owned translator must rebroadcast the main analog (HD-1) programming of the LPFM station and must receive the signal over the air. This is to prevent LPFM translators from being used as second programming services, such as an analog rebroadcast of an HD2 stream. The requirement for over the air reception is consistent with the rules for many non fill-in FM translators not eligible for the “satellator rule”.

Yes, these rules are restrictive, but they are consistent with the original objectives of the LPFM service which keeps stations focused on a particular “hyperlocal” area. There are some of us who would like to see changes to these rules. In 2022, REC filed a Petition for Rulemaking in what we called Translator Reform. One part of Translator Reform proposed to eliminate the 60 dBu contour overlap requirement and to extend the maximum distance for a translator while maintaining the over the air reception requirement. We had hoped that the FCC would have considered some rule changes to FM translators before jumping the gun with this filing window.

In a past comment period for the ground rules for the upcoming translator window, concerns were expressed by REC, LPFM-AG, Common Frequency and Prometheus regarding the current limitations on LPFM. If the FCC was to consider these issues, it may result in a delay of the filing window. We are not sure who is giving pressure to the Bureau to get this window going (though we do have our suspicions), but there should have been a rulemaking proceeding to reexamine the existing FM translator rules including some rules that have not been examined for over 25 years and to modernize the rules to reflect current market trends.

With that, REC is still accepting shows of interest for new FM translator stations from LPFM and full-service noncommercial broadcast stations. LPFM stations considering translators should keep in mind of these policies and understand if I state that the location where they want a translator is just simply too far away.

If your station wishes to show interest, please email lpfm@recnet.com. Please be prepared with sites identified. We will respond with an information package including the information that we need in order to check for FM translator availability. Please, no phone calls. We need this in writing.

Starting today, March 19, 2026, the FCC has lifted a filing freeze [dates subsequently changed] that has been in effect since 2010 that allows for the filing for new Low Power TV (LPTV) stations as well as major modifications to existing stations. This is not being handled like a filing window. Instead, it is being handled first come-first served. Any applications filed on the same day that conflict each other will be declared mutually exclusive and any applications filed the next day must protect those filed on the previous days (as well as any other filing activity).

The lifting of the filing freeze will be of concern to Low Power FM (LPFM) broadcast stations operating in the reserved band (88.1~91.9) as well as existing FM translators in the reserved band and subsequent translators that will be added as a result of the filing window that will take place later this year. This does not impact full-service NCE FM stations in the reserved band.

If the LPFM or FM translator station is operating in the non-reserved band (92.1~107.9 MHz), then there is no impact unless a future LPFM modification is made to move to the reserved band.

Specifically, the impact will take place if the LPTV application is filed to specify operation on RF Channel 6 (82~88 MHz). LPFM stations are required to protect Channel 6 TV stations pursuant to §73.825 of the FCC Rules and FM translators in the reserved band must protect Channel 6 TV stations pursuant to §74.1205 of the FCC Rules. We have not received any specific guidance from the Audio Division, but it is very likely that any existing LPFM station wishing to move closer to the LPTV Channel 6 station or any FM translator expanding their contour will need to demonstrate protection to the LPTV facility. LPFM stations can either apply the §74.1205 method, which simply protects LPTV stations to their 47 dBu F(50,50) service contour and then a specific interfering contour for the LPFM station based on channel is used; or they can apply the more complex §73.525 protection method that is used by full-service NCE FM stations.

Existing LPFM and FM translator operations will not be displaced as a result a new LPTV station (or for that matter, a full service station) on Channel 6 being added or modified. Interference from the new Channel 6 station to the existing LPFM or FM translator is extremely unlikely. LPTV stations are not required to provide any protection to FM facilities in the reserved band.1

As of 3:40PM EDT on March 19, 2026, there have been 27 applications for new Channel 6 LPTV stations. We have not checked these applications for mutual exclusivity.

We will do our best to make this a fluid list and to update new Channel 6 applications as they come in, so please check this list frequently.

These applications are for the following areas:

Arkansas: Little Rock
California: Concord, Hemet, Salinas, San Clemente
Connecticut: Hartford (2)
Florida: Hobe Sound
Iowa: Statler (2)
Indiana: Indianapolis
Idaho: Boise
Kentucky: Louisville, Richmond
Louisiana: Brownfields, Kenner, New Orleans
Maryland: Baltimore
Michigan: Alma
Minneapolis: Alma, Faribault, Minneapolis
New York: Amsterdam
North Carolina: Lumberton
Ohio: Cleveland, Dayton
Pennsylvania: Lopez
South Carolina: Georgetown
Tennessee: Knoxville, LaVergne
Texas: Beaumont, Moody
Virginia: Richmond
Washington: Olympia, Spokane

LPFM and FM translator licensees with facilities in the reserved band should monitor the daily “Applications” public notice that is available through the “Daily Business” link on FCC.today, at the FCC EDOCS website or in the Daily Digest. Look for any facilities that specify Channel 6. Since these are new applications and REC’s eLMS system does not support real time updating on TV engineering applications, we are unable to display (using the green background) any new applications regarding Channel 6. Note: fcc.today does have a feature where an application for an existing facility operating on Channel 6 has a new action, the information will show with a green background. Here’s an example of a page from the Applications public notice and where to find the channel number involved:

Please note that these new facilities may not yet be reflected on the REC FM Translator Window Prequalification Tool until we run a program to bring them in. These will have to be manually performed so it may take a week or few before they reflect in the translator prequalification tool.

REC Networks does not provide any filing services at this time for television facilities.

In Monday, REC had filed comments in MB Docket 26-20 regarding the ground rules for the upcoming Reserved Band FM Translator Filing Window expected later this year.

In their comments, REC supported the proposed cap of 10 applications per licensee and the limitation that applications are limited to only the licensees or permittees that the proposed translator is intended to serve. In addition, REC supported the ability for LPFM stations to file up to 2 applications (4 for Tribal), pursuant to §73.860 of the rules.

REC notes that the 10 cap being proposed was even more restrictive than the one it proposed in the Translator Reform petition for rulemaking.

In comments, REC did bring up two very important matters that pertain to application caps and window eligibility.

REC reminds the Commission that LPFM stations are subject to an ownership cap on commonly-owned FM translators and FM boosters, which when commonly considered, LPFM stations are limited to two facilities (4 for Tribal) where such an ownership cap does not apply to full-service broadcasters. REC has asked the Commission to permit an LPFM applicant that already has one or two translator or booster holdings to be able to participate in this window under a condition that upon program test of the new translator(s), the LPFM station will divest themselves of the FM translator(s) and/or FM booster(s) they wish to remove in order to remain within their §73.860 limit.

REC has also identified a potential for gamesmanship in this filing window. REC sees opportunities where a bad actor licensee/permittee may, under some form of agreement (either “under the table” or above board), will use their spare allocations in the 10 cap to actually apply for FM translators, which in turn after grant, will be redirected to another noncommercial broadcaster for which may have entered into such an “arrangement”. The potential risk for this is higher than normal due to the increased portability of FM translators vs. full-service stations as well as the ability for full-service broadcasters to be able to place a translator anywhere in the country under the so-called “satellator rule”.

In order to prevent what REC calls “surrogate stations”, REC is asking for a holding period on all grants of original construction permits granted in this filing window. Specifically, the condition would restrict, within the first four years of licensed operations:

• Any change in primary station, except in cases where the new primary station is commonly owned by the original applicant for the translator.

• Any assignment or transfer of the FM translator permit or license to a different entity, except in cases where the primary station that is being rebroadcast is also being assigned to the proposed assignee/transferee of the FM translator facility.

The restrictions that REC are proposing are somewhat similar to those restrictions that were put in place for the 2016 AM Revitalization opportunity where existing translators could be moved up to 250 miles in order to provide translator service for an AM broadcast station.

Comments in MB Docket 26-20 are due on March 13, 2026. Reply comments are due on March 23, 2026.

The FCC has released a circulation draft of a Report and Order in MB Docket 24-626 which proposes to remove or change certain rules that would codify certain Media Bureau practices, remove references to outdated language and best reflect current application processing requirements. REC Networks was deeply involved in this proceeding. [Comments|Reply Comments] Please note, that this is a circulation draft of a Report and Order. This item will be voted on at the FCC Open Meeting on March 26, 2026. If the item is adopted, then the rule changes will normally take place 30 days after its publication in the Federal Register.

Simultaneously filed LPFM minor modification applications

In the wording of the current rules for LPFM, it states that if two conflicting minor modification applications are filed on the same day, the FCC will accept the applications in the order tendered. However, in all other broadcast services, the rule is that if two conflicting applications are filed the same day, then both applications will be considered simultaneously filed and therefore mutually exclusive meaning that the applicants would need to develop an engineering solution.

This rule was put to the test a few years ago in the case of Electron Benders, KOKT-LP where KOKT-LP filed an application for a non-adjacent channel change in the early morning and then later in the day, there was another LPFM station that filed a conflicting application for the same channel. In response to an Informal Objection that was assisted by REC, KOKT-LP had put this rule to the test stating that because KOKT-LP’s application was filed first. The Media Bureau determined at the time that they would apply the rules that applied to other broadcast stations and treated the applications as mutually exclusive. This resulted in both applications remaining pending for over a year.

In 24-626, the Commission proposed that the rules for LPFM be officially changed to match that of the other broadcast services. REC opposed this change citing the fact that unlike paper filing and the previous CDBS filing system, minor modifications filed in LMS are instantly viewable and the current environment can foster a behavior of one entity being able to “torpedo” a previously filed application on the same day. REC had proposed that instead of making LPFM move to the “same day simultaneously filed” rule, that the Commission should move all broadcast services to a “first come first served, even if on the same day” rule to reflect the technological changes that came with the evolution of the LMS filing system.

The Commission has recognized that REC did make some persuasive arguments in favor of using “first in time” for determining the order of applications received as opposed to using an obsolete method that goes back to the paper filing days. For now, the Media Bureau has been instructed to handle conflicting LPFM modifications under the “same day simultaneously filed” rules, but the Commission does want to explore the “first in time” method proposed by REC to apply to all of the broadcast services in a future proceeding as such a change would reflect the changes in technology.

Protection of prior-filed applications in respect to LPFM filing windows

§73.807 of the Rules current states that LPFM stations must protect, in part, “applications for new and existing FM stations filed prior to the release of the public notice announcing an LPFM window period”.

In the events leading up to the 2023 LPFM Filing Window, REC took the Media Bureau to task on this phrase based on how the 2023 window was handled. Specifically, on June 22, 2023, the Media Bureau released a Public Notice announcing the dates of the 2023 LPFM Filing Window and then issue a subsequent Public Notice on July 31, 2023, which detailed the procedures for the filing window. This method was inconsistent with the single Public Notice that was released prior to the previous 2013 LPFM Filing Window. REC argued that LPFM stations filing in the 2023 Filing Window should only be required to protect other (secondary) facilities applied for prior to June 22, 2023 when the dates were announced as opposed to the July 31, 2023 date which was honored.

To address this issue, the FCC will amend §73.807 of the Rules to clearly state that this protection starts at the “release of the public notice announcing the filing procedures for the LPFM window period”.

The FCC also removed a reference to “cut-off” applications which reflected a process for application handling that was used prior to the year 2000.

Changes to the “signature rule”

For original construction permit applications (or for that matter, all applications), the FCC Rules require that for corporations, that the applications must be electronically signed by an officer of the corporation. If an application is not properly signed at the start, the application is fatal and would be dismissed for a violation of the signature rule.

During both the 2021 NCE and 2023 LPFM Filing Windows, there were a significant number of original construction permit applications that were filed by persons other than the parties to the application (i.e. not a board member, director or officer). Some of these applications were signed by volunteers, station managers and some by persons involved in the business of preparing applications. Some of these “mis-signed” applications were confronted with Informal Objections, resulting in dismissals because of a “beginner’s mistake”.

The FCC proposed to expand the signature rule to include “duly authorized employees” of an organization. This term drew concerns by other community radio advocates who state that because of the nature of some nonprofit organizations, these volunteers are not necessarily “employees” (i.e. being on the payroll). REC raised concerns that expanding the signature rule could lead to gamesmanship in the window process, especially when an application is signed by a third-party consultant involved in application preparation.

The FCC will expand the signature rule to include “duly authorized employees” but at the same time clarifies, that such an “employee” does not have to be of the traditional sense, meaning that a volunteer representing the organization would be able to sign. In addition, in addressing one of REC’s concerns, the Commission has clarified that third-party persons who are involved in the preparation of applications (who are not a part of the organization) are not considered duly authorized employees.

The FCC has declined the requests by REC and other community radio advocates to permit applications that were dismissed for the signature rule to be given a single opportunity (nunc pro tunc) to update the signatory. With the expansion of the eligibility to sign being extended to duly authorized employees inside of the organization, the chances of an application being dismissed for the signature rule (other than by a third party consultant) are greatly reduced.

“Accepted for filing” indicator in LMS

In the discussion about non-controversial changes related to the documents that can trigger an application being accepted for filing (thus opening a period of Petitions to Deny and Informal Objections, see below), REC raised the issue that with the conversion of electronic filing from CDBS to LMS, the industry lost a systematic method of determining when an application was truly accepted for filing and that the methods needed to determine if an application is properly accepted for filing are overly burdensome.

As a workaround, REC developed a program in our Enhanced License Management System (eLMS) that would attempt to “read” the Applications public notice and re-status those applications within eLMS as “Accepted for Filing”. As an “Accepted for Filing” status can take place in other documents other than the Applications public notice, eLMS cannot fully track these applications.

To address REC’s concerns, the FCC has ordered the Media Bureau to modify the LMS database to include an “accepted for filing” date in the application data. As long as that data is properly provided in the daily raw data dump that LMS provides to the general public, we would be able to read that information and thus discontinue the need for the “outboard” program that we currently use to determine application acceptance.

Changes to how Informal Objections are filed

In light of the many Informal Objections filed during the 2021 and 2023 filing windows, the FCC proposed some major changes to Informal Objections. Specifically, the FCC proposed to:

1. Require that Informal Objections and responsive pleadings be served upon the relevant applicant or objector;

2. Limit the type of responsive pleadings that may be filed; and

3. Impose filing deadlines for responsive pleadings that aligned with the limitation set for responsive pleadings (oppositions and replies) to Petitions to Deny.

In opposition, REC argued:

1. Informal Objections are a critical tool to combat gamesmanship;

2. LPFM and NCE community “watchdogs” (including REC) use these objections in order to maintain application and service integrity; and

3. Informal Objections allow members of the general public who may not normally participate in proceedings (such as the average radio listener or TV viewer) to participate without an attorney.

REC states that such requirements would create a barrier to a station’s obligation to allow for participation from local listeners and that applicants could explote procedural requirements to get Informal Objections dismissed. REC suggested that it would not be in the public interest to prevent members of the public, especially those who are not well-versed on Commission policies from participating in the public comment process.

In response, the FCC was persuaded by REC’s arguments on this topic and as a result, will not make any changes to this rule stating that the current rule “strikes an appropriate balance to promote critical participation from members of the public in our filing and licensing proceeding”.

Non-controversial items

The Report and Order has also made several changes which REC determined were not controversial or otherwise do not apply to the FM broadcast services:

• Update references in the rules to the former CDBS filing system to reflect the current LMS electronic filing system.

• Update references in the rules that refer to old form numbers used in the paper filing and CDBS days to reflect the schedule numbers used in LMS.

• Rewording some rules that referred to the Table of FM Allotments and the Table of TV Allotments that referred to those tables by different names.

• Removing the reference to the 10-application limit for new NCE FM full-service stations that was put in place for the 2021 filing window. This language is now obsolete. This change is consistent with a past deletion the FCC did after the conclusion of the 2007 NCE FM full-service filing window.

• Codified the long-standing interpretation of an “authorized station” in §73.807 of the Rules to include both licensed stations and/or granted construction permits for FM, LPFM and FM Translator stations.

• Amend the rules to clarify that an application will be accepted for filing, not just when it shows on the daily Applications public notice as being accepted for filing, but also in other documents, such as the determination of tentative selectees in the point system, threshold fair distribution or through any other order.

• Eliminate the restriction that Special Temporary Authority applications due to technical or equipment problems are only granted for 90 days. Instead, they will be granted for 180 days, consistent with other STA applications.

• Amend rules to eliminate the term “tendered for filing”, which is a term that goes back to the paper filing days and replace it with simply, “filed”.

• Combine two Petition to Deny rules, one related to renewals and one related to other applications into a single rule.

• For AM broadcast stations, removing a requirement that AM stations requesting a power increase must propose at least a 20% increase in nominal power and to update references to Class B, C and D AM stations to confirm to the parameters in §73.21 of the rules and international agreements.

• Remove post-Incentive Auction view and MVPD (multichannel video programming distributor) notification requirements and to remove references in the rules regarding TV operations above Channel 37.

Final reminder

This Report and Order is just a circulation draft at this time. It will be voted on at the March 26, 2026 FCC Open Meeting and if adopted, the rule changes will normally go in effect at least 30 days after publication in the Federal Register. Any adopted items that may involve changes in information collection (such as form changes) may take longer to implement due to Office of Management and Budget/Paperwork Reduction Act processes that must be completed first.

Overall, REC is very satisfied with the outcome of this proceeding. While we did not get everything we wanted, the Commission has left open some new opportunities for longer term improvements that were suggested by us. Overall, we consider this proceeding a “win”.

At today’s FCC Open Meeting, the Federal Communications Commission has has adopted a Public Notice (MB Docket 26-20, text of adopted notice not available at the time of this writing) to establish a comment period for the “ground rules” for the upcoming filing window for new noncommercial educational (NCE) FM translators operating in the reserved band (88.1~91.9), which is expected in “late 2026”.

Based on the presentation at the Open Meeting, the Media Bureau proposed that there will be limitations on the number of applications filed and the scope of applicants that can participate in this window. Specifically:

• Full-service licensee/permittee entities (as determined by attributable interest) will be limited to 10 applications nationwide.

• LPFM licensee/permittee entities will be limited to two applications, except for Tribal entities that will be limited to four applications. The limitations that apply to LPFM stations are further restricted by the limitations in §73.860(b) and (c) of the FCC Rules.

• Applicants must be the licensee/permittee of the station that the proposed translator will rebroadcast.

According to staff, these proposed limitations are being put in place in order to prevent speculation (such as what happened in 2003 during the “Great Translator Invasion” Auction 83 filing window) and to assure for efficient application handling. REC further notes that these application limits were also proposed by staff in order for this filing window to remain in the spirit of Section 5 of the Local Community Radio Act of 2010, which states that LPFM, FM translator and FM booster licenses will be distributed based on community need. The limit of 10 applications for full-service applicants is consistent with the limits put in place for past full-service NCE FM filing windows in 2007 and 2021.

This is the first ever reserved band filing window since the rules for a translator filing window were first adopted in 2000 following the Bechtel vs. FCC case in the early 1990s that argued that the old “comparative review” process was arbitrary and capricious and was not consistent with the first amendment as it was charged that the FCC could “pick and choose” who can be a broadcast licensee when competing applications are filed. Following Bechtel, noncommercial applications were first handled through “cut-off lists” before these rules were adopted. Commercial applications were settled through auctions.

Like with all adopted items, a comment and reply comment period will be established once the item is published in the Federal Register.

REC launches prequalification tool to assist potential translator applicants

REC Networks has announced today that a new “toybox” tool has been released to assist with identifying potential channels that may be available for the upcoming filing window.

The NCE FM Reserved Band Translator Prequalification Tool will allow the user to enter a target location and the Tool will search for all nearby facilities and determine which of these facilities put service contours over the target site and then will “eliminate” those channels from consideration or in cases where available, keep the channels but warn of the need for a waiver of §74.1204(a) of the rules (second- and third-adjacent channels). The Tool will also check channels for intermediate frequency short spacing, which would restrict a channel to no more than 99 watts (contingent on the protection of other facilities) and will indicate whether a location may be within the 47 dBu service contour of a Channel 6 TV facility, which further restricts availability.

REC points out that the Tool is not a “channel search” similar to those that the Network had released in the past to support filing windows. Instead, the Tool is a “first step” in the quest to find a suitable channel.

The Tool will show details for all 20 reserved band channels and provide either an explanation on why a channel cannot be used or whether it needs to be examined by a consulting or engineering professional to determine if the channel can be used and what the power and coverage limitations will be. Any positive results received from the Tool must be further researched in order to determine the distance from the target location to the proposed translator’s interfering contour in order to assure compliance with §74.1204(a) of the Rules.

REC recommends that users of the Tool first visit the link below in order to learn the basics of FM translator protection rules, how the Tool works and the Tool’s limitations:

https://recnet.com/nce-translator-check

Once you read the documentation, there will be a link to take you to the Tool.

REC has not yet released details of a limited service offering for potential translator filing window applicants but is accepting shows of interest at their email (lpfm at recnet dot com). REC will eventually establish the amount of workload it will take, the priority on how potential applicants will be selected and proposed rates. These details will be released on a subsequent notice.

On January 27, 2026, the FCC released a Public Notice from the Wireline Competition Bureau (the part of the FCC that handles telephones and related services) regarding potential forfeitures (fines) for failure to provide correct information in the Robocall Mitigation Database (RMD) and for failure to update contact information in the Commission Registration System (CORES). For the latter, the notice threatened a forfeiture of $1,000 per day.

The content of this notice prompted a couple of attorneys who work on broadcast issues to interpret the notice to suggest that the FCC was going to fine anyone who does not have their information current in CORES to be subjected to the forfeitures, regardless of which service(s) the FCC Registration Number (FRN) is associated with. As a result, several State Broadcasters Associations (SBAs) sent alerts to their member stations about the potential of forfeitures if CORES is not updated for each FRN. Some of the warnings that were circulated even suggested that this can also impact the FRNs that are used on ownership reports. REC received one media inquiry about these concerns. We have also viewed the alerts provided by several SBAs.

On Friday, February 6, 2026, the FCC released a subsequent Public Notice which clarifies that the original Report and Order for the RMD “did not address or change any forfeiture amounts that may be associated with failures to update the CORES information by non-RMD filers.”

In other words, the FCC is not going to start an arbitrary “witch hunt” to look for any user from any service that has not updated their CORES information. The information recently communicated by the FCC in the January public notice related only to the Robocall Mitigation Database and related CORES FRN data from telecom providers and not the general FCC community.

Regardless of that, broadcast stations (all classes) are required to keep their contact information up to date. Section 1.80(b)(11) of the FCC Rules allows the Commission to impose a forfeiture of up to $4,000 for failure to respond to Commission communications and up to $1,000 for “failure to maintain required records”. The FCC may attempt to reach a broadcaster through e-mail or by postal mail. Normally, if the agency sends a Letter of Inquiry (LOI) to a station which requires a response within a certain time period, they will normally send it both via email and postal mail, usually by certified mail so they can get a return receipt. As a broadcaster, you are required to timely answer any LOI and respond to each question truthfully and to the best of your knowledge, pursuant also to any additional instructions in the LOI. Normally, the Commission will permit the responses via email following the instructions in the LOI.

Broadcasters of all services are reminded that they must keep their information current in all relevant FCC databases and must make the update within 10 days of the change.

LMS Administrative Updates

The Media Bureau normally uses the information in LMS in order to contact a station. This information includes the mailing address, telephone number and email address of the licensee, their legal representative (which is normally a person in leadership or other administrative contact for stations that do not have retained counsel) and a technical representative. An Administrative Update needs to be filed in LMS if any of this information changes. Administrative Updates are notifications and they do not have to wait to be granted.

For stations that have paid REC in the past, regardless of minimum spend, we will file Administrative Updates at no charge. For all others, our fee is $50. You can also file this yourself. It is one of the easiest LMS applications to file.

FRN updates in CORES

While the Media Bureau normally does not depend on CORES for contact information, it is also a good idea to make sure that the information for the organization’s FRN is also correct in that system.

For full-service stations that file Ownership Reports, the FRNs that are used for each individual are likely “psuedo-FRNs” that were assigned by LMS during preparation of the Ownership Report form. These psuedo-FRNs cannot be maintained in CORES and there’s no way to correct them.

For those who have FRNs for other non-broadcast services, such as the Amateur Radio Service, GMRS, commercial radio licenses, etc.; you should assure that your FRN information in CORES is updated, in addition to other relevant databases.

Administrative update in ULS

For broadcast licensees that also have studio to transmitter links (STL), remote pickup units (RPU), licensed wireless microphones that are authorized under Part 74 of the FCC Rules, as well as for services licensed in other parts (including individual licenses for Amateur Radio, GMRS, etc.), you should also issue an administrative update in the FCC’s Universal License System (ULS) to assure that your most current contact information is up to date.

Reminder about changes in board members

For LPFM stations, any change in board members that triggers more than a 50% change in board members (each member counts equally) since the last time the board members have been reported to the FCC (either through the original construction permit application, an assignment of license application or previously-filed transfer of control application), the FCC requires the filing of a non-pro forma Transfer of Control application. This was formerly known as Form 316. This form must be filed within 10 days of making the change.

For full-service FM stations, this is a little different. The non-pro forma process is not used. Contact REC or your attorney for assistance.

If the license is being “transferred” to a different organization or the same organization where the state of incorporation has changed, then an Assignment of License application is required. The assignment application must be granted before the transfer/assignment can be consummated. For more assistance, please contact REC or your attorney.

Transferring control without an appropriate transfer of control application (for LPFM if more than 50% of the board as detailed above) or a granted assignment application can be considered an “unauthorized transfer of control”, which can lead to forfeitures.

Updating the state government

In addition to updating the FCC, you need to assure that other information is kept up to date by making appropriate filings with your state’s Secretary of State, Corporation Commission or equivalent agency. What exactly needs to be updated and when will depend on the laws of the state your organization is incorporated in. REC does not provide state filing services.

Board member changes

Your state may require you to file an amendment to your articles of incorporation or similar instrument when there is any changes to your board membership (regardless of the 50% threshold for the FCC transfer of control process). If there is a mismatch between the state records and what the FCC has on file, it could lead to a forfeiture, based on the circumstances.

Annual Report filings

Many states require corporations (for-profit and non-profit) to make annual filings with the Secretary of State (or equivalent). Failure to make these reports will place your corporation into a suspended, involuntary dissolution or inactive status. Technically, under such state laws, your organization technically cannot conduct business as long as the corporation status is lapsed. Many states will retroactively reinstate lapsed corporations due to a previous failure to file an annual report as long as the required report(s) is/are filed and any fees are paid. Please check with your state of incorporation for details. REC does not have this information.

Since 2026 may be a filing window year for new NCE reserved band FM translator construction permits, it is very important to assure that your organization’s corporation status is current and in good standing at the time when an application is filed in the window. If the corporation is not active at the time of filing the translator application in the window, the application may be dismissed. Correcting the issue with the state after the fact will not result in reinstatement. So, if your organization plans to file in this window, make sure the corporation status is in good standing. Again, for more information, please check with your state of incorporation for details. REC does not have this information. State incorporation documents may be required for any NCE FM translator applicants claiming the Established Local Applicant points in the event of mutual exclusivity.

Use “evergreen” contact information that always stays the same even if people change

A good idea is to establish specific email addresses and telephone numbers for broadcast stations that are general to the station and will not change when the person who answers those emails or phone calls change. This will make it easier in the event the agency needs to reach your station and there has been personnel changes. Adding additional Gmail email addresses are easy to do. Many VOIP providers (such as voip.ms, which REC uses) can provide you with a “Direct Inward Dial” phone number that can forward to any other telephone number at a very reasonable monthly rate (in the case of voip.ms, you pay less than $1 per month for the phone number but you pay a low per minute rate for incoming calls).

Bottom line

As a broadcaster, you have a responsibility not only to your listeners and your community, but you also have a responsibility to assure that your information with the FCC and the state remains current. You are also responsible to assuring that your corporation remains active with the state as this is normally required to be a FCC noncommercial educational licensee.

On January 28, 2026, the FCC has released a circulation draft regarding ground rules for an upcoming filing window for new FM translators in the reserved band for non-commercial educational use for consideration for vote by the full Commission at their February 16, 2026 Open Meeting. The circulation draft is for a Public Notice that will collect ground rules regarding an upcoming filing window for new FM translator stations operating in the “reserved band” (the 20 channels between 88.1~91.9 MHz) for use exclusively by noncommercial educational broadcast stations, including both full-service and LPFM stations.

The rules for new reserved band FM translators were originally enacted in 2000 and in those 26 years, there has never been a filing window for new FM translators in the reserved band.

FM translators are solely for the rebroadcast of an existing FM or AM noncommercial educational broadcast station (including LPFM) and cannot be used to originate its own programming.

FM translators come in two flavors:

• A fill-in translator was originally intended to allow stations, especially in rural areas to fill in a gap in coverage within their service contour that is otherwise impeded by terrain. Modern day applications of fill-in translators also include the use of these stations to rebroadcast the HD Radio stream (such as an HD2) of the primary station being rebroadcast as well as to rebroadcast the signal of an AM broadcast station. The 60 dBu service contour of a fill-in translator must be completely inside of the service contour of the FM station (or for AM, within either the 2 mV/m daytime contour or 25 miles from the AM station, whichever is farther in each direction). There are no restrictions on height and a 250 watt power limit as long as the contour of the translator remains inside the contour of the primary station and as long as other stations are protected.

• A non fill-in translator can be used by noncommercial broadcasters (including LPFM stations). These translators can be used to extend a station’s service area into a different community. There are restrictions on power based on a “maximum height above average terrain” formula. There are different height/power limitations for proposals east or west of the Mississippi River and for California south of 40 degrees latitude. Most non-fill in translators (including all translators for LPFM stations) must be able to receive the primary station it is rebroadcasting from over the air (you can’t use the internet). Non fill-in translators licensed to full-service noncommercial stations that have primary stations in the reserved band can use any method to deliver programming (LPFM stations can’t do this).

There are also additional restrictions on the placement of FM translators that are licensed to LPFM stations as well as ownership limits.

FM translators use one-way contour protection (translator interfering into the other station’s service contour) and can utilize directional antennas to achieve protection. FM translators are vulnerable to interference complaints using a procedure outlined in both §74.1203 and §74.1204(f) of the rules. FM translators in the reserved band are required to protect all TV Channel 6 facilities, including full-service, Class A TV, Low Power TV and TV translator stations. Waivers can be provided by the licensee(s) of the affected Channel 6 station(s). FM translators exceeding 99 watts must also protect the facilities on intermediate frequencies (+ 10.6 and 10.8 MHz/+53 or 54 channels). There are also additional protections & restrictions for proposals near Canada and Mexico.

Ground rules being considered

In the Circulation Draft, the Commission is considering adding specific ground rules for the following translator window to accommodate this window. These proposed ground rules are intended to prevent the speculation that took place following the 2003 “Great Translator Invasion” (Auction 83) filing window. Specifically, the FCC is proposing:

• For full-service FM NCE stations, the proposed limit is 10 applications based on attributable interests. This is exactly like the same limit that was put in place for the 2021 full-service NCE FM filing window. (In most cases, this means up to 10 applications per licensee and not 10 applications per station. It gets tricky if an organization has a board member that serves on the boards of more than one organization applying in the filing window.)

• For LPFM stations, the proposed limit is 2 applications for most stations and 4 for stations that serve Tribal lands. This is consistent with §73.860 of the rules. LPFM stations that already have one translator licensed to them can only obtain one translator as to not exceed their limit.

• For all station types (NCE FM, noncommercial AM and LPFM), the translator may only be applied for by the licensee of the station for which the FM translator is intended to rebroadcast. Unlike the AM Revitalization windows (Auctions 99 & 100) in 2017 & 2018, the translator will not be permanently “married” to the primary station and therefore can be changed in the future to a different station that would otherwise meet the requirements.

REC LCRA evaluation

Section 5 of the Local Community Radio Act of 2010 (LCRA) states that the FCC must make licenses available to both LPFM and FM translator stations based on community need. It is important to remember that the LCRA did not just address the needs of future community LPFM broadcasters but it was also intended to address the abuses that took place in the 2003 Auction 83 translator filing window.

When the FCC held the AM Revitalization translator filing windows (Auctions 99 and 100) in 2017 and 2018, REC had supported the Commission’s ground rules because the window was restricted to one translator per AM station, the AM station licensee was required to apply for the translator (not a third party) and that the FM translator must be permanently “married” to that AM station. The primary station the translator is broadcasting could not be changed. We saw the need to add FM service to struggling AM stations, especially in rural areas to be a community need from an LCRA perspective.

For this window, we note the two major points here. First, the window is proposing an overall cap of 10 applications per licensee/attributable interest for full-service stations. This is a cap that is even smaller than what REC had proposed in our Translator Reform petition for rulemaking. This means that even the big NCE broadcasters, like K-LOVE and Calvary Chapel of Twin Falls can only apply for 10 translators nationwide (no different than 2021). The proposed restriction that requires the applicant to be the licensee of the station being rebroadcast will prevent third-party actors who are not the licensees of the stations being rebroadcast from applying. This was a huge problem in the 2003 Auction 83 window.

From an LCRA perspective, while we do not feel that Section 5 is not being followed exactly the way we would like it to, these controls are strict enough to address most of our LCRA related concerns regarding community need. REC will not oppose these ground rules as originally proposed.

However, we do feel that the FCC is jumping the gun on this window

Despite our “tolerant” LCRA finding, we do feel that the FCC is prematurely launching this filing window. Due to changes in our industry since the rules were originally enacted in 2000, we do feel that there needs to be some rule changes, mainly in respect to the comparative selection process for mutually exclusive (MX) applications. When applications are MX, this means that two or more applications have conflicts in their engineering where the two or more applications can’t all be granted (such as two applicants applying for the same or adjacent channels in the same area). In the translator world, “adjacent” means co-, first-, second- and third-adjacent channels.

The current will allow for remediation, including channel changes and certain minor engineering changes to cure MX situations. However, if there is still an MX situation, the following rules will apply:

Applicants proposing fill-in translators will have priority over applicants proposing non fill-in translators. Therefore, if there are non-fill in translators competing with fill-in translators at the time the comparison is done, the non-fill in translators will not even be considered, even if a non-fill in translator is “orphaned” (they could otherwise be grantable after the fill-in translator is granted in an otherwise “daisy chained” MX Group).

If a single winner cannot be determined after removing the non fill-in applications, or there are no fill-in applications in the MX Group, the point system that is used for full-service NCE applications will be used:

• Established local applicant. 3 points for local applicants. An established local applicant is considered as an organization that, for no fewer than 24 months, has their headquarters, campus or 75% of their board members (each board member with equal weight) within 25 miles of the reference coordinates of the community that will be served by the translator.

• Local diversity of ownership. 2 points for an applicant with no attributable interests in any other radio broadcast station, authorized radio construction permit who’s principal community contour (70 dBu for FM, 5 mV/m for AM) does not overlap the 60 dBu contour of the proposed FM translator station.

• Statewide network. 2 points if they are a public or private school system with at least 50 accredited elementary or secondary full-time schools within a single state, an accredited public or private institution of higher learning with at least 5 full-time campuses in a single state, or an organization without direct authority over schools that will regularly provide programming. In all cases, the organization has to provide programming to the schools in furtherance of their curriculum. An application claiming statewide network cannot also claim the diversity points. (In 2021, there were no applicants that met the criteria of statewide network and we do not anticipate any in this window. This goes back to the days when educational stations provided programming that were intended to be listened to or watched in classrooms, a relic of the early days of educational radio and television.)

• Technical points. 1 point to the applicant covering the largest geographic area and population where the land area (square km) and population is at least 10% more than the next lower application. 2 points if the area and population exceeds 25% over the next lower application.

If there is still a tie after the points are applied, then there are three tie breakers:

• Existing authorizations. The station with the lowest number of existing radio authorizations, including FM, AM and non-fill in translators. If the tie is between fill-in applications, then the applicant with the lowest number of fill-in applications will be considered.

• Existing applications. If there is still a tie, then the station with the least number of existing pending AM, FM and non fill-in FM translators (including those filed in this window). If the tie is between fill-in applications, then the applicant with the least number of fill-in applications will be considered.

• First come-first served. If there is still a tie, the applications will be processed on a first come-first served basis. (Presumably, in the LMS environment, we can assume this will mean the applicant with the lower file number.) There is no such thing as time sharing for FM translators.

With that said, REC does have a serious problem with this system due to significant changes in the industry. When these rules were originally written, they were written at a time when fill-in translators were used only to help fill in gaps in coverage of the main analog station. The concept of using fill-in translators for HD2/3/4 rebroadcast or for the rebroadcast of AM stations was not even thought of at the time (remember this was the late 90s when this was being debated). Because of the major change in the nature of how fill-in translators are used, they are no longer being used solely to fill in gaps in rural areas, but will be used to expand the coverage of large broadcast stations in very well-served areas. In Translator Reform, REC proposed that applicants claiming the fill-in priority must be in situations for which fill-in translators were originally intended for and proposed a requirement that in no part of the 60 dBu contour of the proposed fill-in translator that there are more than two educational services (based 60 dBu contour), including the applicant’s primary station serving any area. Thus meaning that only underserved areas of the country would be able to claim the priority. In order to change this, it would require a Notice of Proposed Rulemaking to change the definition of fill-in, solely for MX comparison purposes. REC is inclined to demand that the Commission waive §74.1233(e)(1) of the rules and apply no special considerations at all for proposed fill-in stations as well as not enforcing the carve-outs for fill-in stations in the tie breakers.

REC also wants clarification on the Established Local Applicant definition, specific to NCE FM translators, where it comes to the reference coordinates of the community being served. Unlike full-service radio, FM translators do not have a specific (§307(b)) community of license or community coverage requirement. FM translator applicants can use any community name, including those that would not meet the §307(b) requirements as a community for allotment purposes. For FM translators, it is REC’s position that the 25 mile radius should be based on the transmitter site for the translator (like with LPFM) and not reference coordinates for a community, especially communities that are not Census Designated Places where no reference coordinates exist.

REC really wanted the FCC to first consider our Translator Reform petition before opening any kind of FM translator filing window (commercial or noncommercial).

Finding potential channels

REC will be working on a technology solution to find potential channels. Because FM translators can use directional antennas, having a channel search tool like what we have done in the past with LPFM will not be possible.

The easiest way to first see if there is any potential is to look at all 20 channels (88.1 through 91.9). If the channel has another facility (full-service, FM translator or LPFM station) on the same or first-adjacent channel that places a 60 dBu contour over the proposed location, that will disqualify that channel. If there is another facility on a second- or third-adjacent channel that places a 60 dBu contour over that location, then there, and those are the only facilities that do, there may be a possibility with a waiver demonstrating no interference to nearby occupied structures. For “adjacent” facilities in the “commercial band” (e.g. 92.1, 92.3 or 92.5) you must use the 54 dBu contour for Class B and the 57 dBu contour for Class B1. (In the 88.1~91.9 reserved band, Class B and B1 stations are only protected to the 60 dBu contours). Even if you find a channel using this quick method, a full engineering study needs to be done to determine interference protection to other facilities and in the long run, the channel may still not be available.

REC full services for this filing window

This information is subject to change.

Due to personal and family health issues and other limitations, our bandwidth for personally handling applications for this window will be extremely limited and thus, the number of “slots” will be substantially limited.

We will not use an intake tool like we did with the 2021 and 2023 windows. Instead, we will consider only serious requests from full-service and LPFM licensees with priority given to those who have had a long-standing business relationship with REC in the past.

We also plan to provide “wholesale” services to other consultants, advocates and certain “DIY” filers who need technical preparation of exhibits as these take less time for us.

Those with serious interests in filing in this window who meet the criteria above can contact REC Networks to express a show of interest. We reserve the right to select which potential applicants we will work with due to these bandwidth restrictions this year.

It is very likely that we will be providing status through our Filing Window Application Tracking System.

What happens next?

At this time, we are getting ready for a comment phase. Once the item is adopted by the Commission and it is published in the Federal Register, there will be a 15-day comment period and reply comments will be due 10 days after that.

As a matter of history, for the 2021 full-service NCE FM filing window, it took approximately six months from the time when the Public Notice was adopted by the Commission (which will happen in mid-February) to the day when the application caps were announced and the filing window dates were set. The filing window was then about 2 months later.

If this proceeding follows that same timeline, it is likely that this filing window will take place around October, 2026, but it can happen any time before or after that depending on how long the processing of the comments and the subsequent issuing of Public Notices take place.

Please stay tuned to REC on Facebook for updates. We will eventually publish FAQ questions and answers to address questions that we have already received as well as questions we anticipate receiving.

For more information on new NCE FM Translators, please see this page at REC Networks.

A Petition for Rulemaking has been filed by Press Communications, LLC, licensee of WHTG(AM), Eatontown, NJ and co-signed by several other broadcasters to propose that the FCC open another opportunity for the licensees of AM stations to be able to acquire existing FM translators and allow them to be moved up to 500 miles for the purpose of allowing the translator to be used as fill-in service for an AM station. This is similar to the 2016 “250-mile move” opportunity that was provided in former FCC Chairman Ajit Pai’s “AM Revitalization” initiative, MB Docket 13-249 (paras. 12~17).

Unlike the previous 250-mile move window of 2016, Press, et. al. is requesting that the maximum move distance be 500 miles instead of 250. They cite that the additional distance is needed because stations on both coasts, the Gulf of Mexico and in the border areas were at a disadvantage because they did not have a full 250-mile circumference in all directions to translators from. They also want the move opportunity to make this 250/500-mile move opportunity permanent. They also want to impose a limitation of a maximum of “3 translators per AM station license”. The latter is so no AM station is forced out of the market by additional FM translators by either a huge entity acquiring dozens or a greater number of translators for a particular station or a greater number of FM translators for a particular AM station or a competing station upsurping all available FM translator spectrum in a market. In the previous 250-mile move window, AM stations were limited to only moving one FM translator. They also want to give Class C and D AM stations a head start, which is consistent with the 2016 opportunity.

Today, FM translators can only be moved a distance where the 60 dBu contour of the current facility overlaps in part with the 60 dBu contour of the proposed facility. A separate process, called a Mattoon Waiver can be used to move an FM translator a farther distance if the translator is to be used for AM fill-in service, does not impact future LPFM availability in “spectrum limited” markets, there is mutual exclusivity in either direction between the current and proposed translator facility, and the applicant does not have a history of multiple filings in order to slowly move a translator to the desired location through a series of minor modifications.

In the past, other LPFM advocates had opposed the 250-mile move opportunity because it would not pass the statutory muster of Section 5 of the Local Community Radio Act of 2010. At that time, REC did not take this position because Section 5 of the LCRA applies only to new FM translator, LPFM and FM booster stations and not to the move of existing stations. The LCRA would only come into play if new (drop-in) translators were being proposed, similar to the Auctions 99 and 100 filing windows in 2017 and 2018. At that time, REC’s position was that because AM stations were limited to one FM translator and each translator obtained through the Auction window would be permanently “married” to the AM station with no opportunity to change the translator’s primary station, the addition of the translators would fall under “community need” as required in §5(2) of the LCRA. We note that the Press petition does not propose the opening of a new auction filing window for new FM translator stations, only the modification of existing FM translator stations.

Because REC’s constituency is more than just LPFM stations (which we are commonly stereotyped as), but also includes smaller commercial and noncommercial AM and FM broadcasters, especially those in rural areas, we must look it in a way that protects the interests of LPFM stations as well as those of smaller AM broadcast stations.

Over the years, REC has either witnessed or received complaints regarding FM translators proposing strangely designed composite directional antennas that are engineered as a way to completely surround an LPFM station, such as the recently filed modification by W276DV and its impacts to WUGR-LP near Hollywood, FL, which has resulted in an Informal Objection (incorrectly presented as a Petition to Deny) opposing the modification of the translator.

REC has always been concerned about these types of arrangements, especially where such antennas would be very costly and where some translators authorized in this manner would eventually build with a different antenna which may cause actual interference. While LPFM stations do have recourse under §§ 74.1203 and 74.1204(f) of the rules, those rules are based on the contour and not on actual operations. LPFM stations may not have recourse to address an improper antenna because it would require FCC field enforcement to inspect the translator antenna and as many of us know, broadcasting is well on the bottom of the FCC’s field enforcement triage as it does not involve high value commercial services nor safety of life communications.

While it may be necessary for REC to first conduct a constituent survey before going on the record with the FCC on this proposal (which we may do if this petition receives an “RM” number and it opens for comments), we will make our initial positions on this issue in a manner that would be a compromise across our entire constituency. These positions are subject to change based on the outcome of a constituent survey.

250 vs. 500 mile move: If the Commission was to entertain a 500 mile move distance, REC would insist that a move between 251 and 500 miles would only be allowed for AM stations in the continental United States and Alaska that are physically located less than 250 miles from one or more of the following: Pacific Ocean, Atlantic Ocean, Gulf of America (as recognized under Executive Order 14172, also recognized as some as Gulf of Mexico)1, the common border with Canada and the common border of Mexico.

Three station maximum: We do not agree with the three station maximum. Instead, we would call for that the number of stations be limited to two and whether the Commission was to go with two or three stations, any translators that were granted (even if not built) in the original 250-mile move or obtained new in Auctions 99 or 100 would count towards those two stations. This means that many AM stations would be able to move one translator and those who did not participate in 2016~2018 would be able to move two.

Licensee of moved station: REC would insist that the licensee of the translator be the same as the licensee of the AM station which will be designated as the primary station. If the current licensee of the FM translator is different, then an application to request consent to assign the FM translator authorization must be filed simultaneously. In cases where an assignment application is filed, program testing and/or licensing would not be authorized until the assignment is both granted and consummated. This prevents speculation. Once moved in this manner, the translator cannot be assigned again for the lifetime of the translator and must be simultaneously assigned or cancelled if the AM ownership changes.

Primary station designation: The primary station of the FM translator must remain the AM station and cannot be changed in the future at any time. In the 2016 opportunity, the FM translator only needed to operate with that AM station as the primary for four years of licensed operation. This would be a permanent marriage similar to those translators authorized in Auctions 99 and 100. This will prevent a translator being moved to a more prominent metro area and then after four years, being sold off to be used for a different station. REC could consider situations where the primary station is redesignated to a different AM station that is commonly owned by the licensee in the same area.

Translators within close proximity to an LPFM station: Any translator that proposes to operate within 67 km of one or more LPFM stations on co-channel and/or within 35 km of one or more LPFM stations on first-adjacent channels and with a directional antenna must be subject to §74.1235(i) which requires that a directional antenna must have a proof of performance (including computer modeling for antenna models that were previously physically proofed) with the exception of “off the shelf” directional antennas used in a single antenna (non-composite) configuration and in all cases (including “off the shelf”), must certify that the antenna is mounted per the manufacturer’s instructions and to certify that the antenna is mounted in the proper orientation and location. The latter would have to be conducted by a licensed surveyor (this is a rule that we would like to see with all future FM translator modifications and construction permits, regardless of primary station).

New FM translator stations: Even though this proposal does not call for the creation of new FM translator stations (only the moves of existing ones), we absolutely oppose a second set of auction windows for new “FM into AM” translator station construction permits. Actually, we oppose any new translator filing window (either in the non-reserved or reserved band) until the FCC puts the safeguards in place as proposed by REC in RM-11952 in order to comply with the LCRA and to address the changed role of fill-in FM translators.

We see these counter-proposed compromises to be a happy medium that does address the issues being faced by current smaller AM broadcast stations and to protect the current base of the 2,000+ LPFM stations currently operating or otherwise authorized.

Again, these are not our final positions, just our starting points. We do welcome feedback on these positions and any compelling arguments that could sway our position knowing that any such arguments must be consistent with both the interests of LPFM stations and those of AM broadcasters seeking FM translators.

Edited to correct the RM number of REC’s Translator Reform petition for rulemaking.

Edited to change text and add footnote 1 regarding the gulf coast of the southeastern United States.

Whenever the Commission considers an action that will be on the agenda, they will release a “circulation draft”. This is normally released three weeks prior to the open meeting date. This was a process started by former Chairman Ajit Pai. Because of these documents, it gives industry stakeholders a two-week opportunity to make ex parte presentations or send ex parte letters to decisionmakers in the appropriate bureau or office. In the past, REC has been able to successfully use this process to modify the bureau’s/office’s/Commission’s decision on a matter. One case was during the online public notice policy change to §73.3580. In the past, it has also been used against us, such as in MB Docket 03-185, when the Commission was ready to reach a Report and Order eliminating all NCE protections to TV Channel 6 (§§73.525, 73.825, 74.1205) but then it was stopped because of ex parte presentation by Disney (owners of WPVI, Channel 6 in Philadelphia, the only network affiliate remaining on RF Channel 6). FCC regulations and the Sunshine Act prohibit ex parte presentations be made upon the release of the “sunshine notice” which normally is released on the Thursday before the meeting (one week prior).

For the circulation draft for the Direct Final Rule from the Office of Engineering and Technology (OET), REC had submitted an ex parte letter directed to OET and the offices of all three Commissioners. In that letter, REC expressed concern regarding the complete deletion of §15.233, which addresses the use of cordless telephones operating in various bands between 43.71 and 50.00 MHz. Our letter stated that it would not be appropriate to delete frequency privileges of consumer equipment that may be still in circulation, especially in rural and collector settings. We noted that without the rule in place, which allows a field strength of 100 times greater than that for normal Part 15 devices in this spectrum, it could render each phone to be illegal, in violation of §301 of the Communications Act. REC had stated that we do not oppose deleting portions of §15.233 that relate specifically to the certification and sale of new cordless phones in this spectrum, but we do feel that these phones need to remain legal for the few who may continue to use them.

Like with what the Media Bureau did to address our concerns about online public notices, we do note that OET did very quietly address the cordless phone issue. Even though the entire rule is still ordered to be deleted, we note that the adopted version of the Direct Final Rule does include the following new language in footnote 5 in respect to §15.233:

This language did not exist in the circulation draft. While we do feel that keeping some language in the CFR to recognize the 10,000 mV/m at 3 meters emission limitation for these phones would fully protect these units, we do have language that continues to protect these units. The bottom line is that because of REC’s actions in this matter, these phones will remain legal to continue using. New phones of these types cannot be manufactured (and they have not been manufactured for decades, which is likely why they wanted to delete the rule).

REC recommends that collectors and others who continue to use cordless phones that exclusively operate in the 43~50 MHz band (including the “46/49” type phones) to print a copy of the Direct Final Rule and keep it with their records permanently so it can be referred to in the unlikely event of future enforcement action.

FCC removes 800 MHz blocking requirement on scanners

In the same Direct Final Rule order, the FCC has also deleted and reserved §§ 2.1033(b)(13) and 15.121, which addresses the need for scanners to block out specific portions of spectrum in the 800 MHz range where cellular telephones operate. These rules were put in place originally following the enactment of the Telephone Disclosure and Dispute Reduction Act (106 Stat. 4195), an amendment to §302a(d) of the Communications Act. This was also at a time when cell phone communications were still analog in some cases and could be easily heard using an unblocked scanner or communications receiver. Analog cellular communications in the 800 MHz band using Advanced Mobile Phone System (AMPS) would be completely phased out by 2008. Because of the conversion of this spectrum from AMPS to digital technologies, such as CDMA and GSM, a conventional scanner or communications receiver would no longer be able to pick up telephone communications in the 800 MHz band.

The way that we read this rule deletion is that scanners are no longer required to block those portions of the 800 MHz band that were previously used for AMPS cellular service and thus may be used for other public mobile/broadband purposes. We do note that §302a(d) is still on the books and thus it is still a violation of federal law for any scanning receiver that is capable of-

1. Receiving transmissions in the frequencies allocated to the domestic cellular radio telecommunications serivce.

2. readily being altered by the user to receive transmissions in such frequencies; or

3. being equipped with decoders that convert digital cellular transmissions to analog voice audio.

Since all cellular communications have converted to encrypted digital formats, it can be interpreted that the deletion of §§2.1033(b)(13) & 15.121 would remain in compliance with §302a(d). Federal law still prohibits any devices that can convert digital cellular communications to analog audio.

Whether this means that Uniden and other scanner manufacturers will be rushing to change their models to remove this blocking is yet to be seen, however, it would likely be fruitless due to the lack of analog and unencrypted digital communications (e.g. P25) that may exist in the blocked spectrum.

Use this information about the 800 MHz band at your own risk!!

(Bonnet on.) With the new stations coming on the air and observations of things I have been seeing other LPFM and small full-service NCE stations doing, I think it’s time to re-raise the uncomfortable subject of underwriting acknowledgement compliance.

Times have been tough for NCE/LPFMs, I get it!

Non-commercial Educational (NCE) broadcast stations, this means BOTH full-service and Low Power FM stations, are currently going through some very rough times over these past few years. Many stations (but not all) were able to make it through the “2020 crud”, despite the fact that many public facing businesses either had gone out of business or otherwise experienced substantially reduced revenues due to the loss of foot traffic. Today, we are continuing to experience reduced public involvement in the funding of NCE stations due to competing technologies, such as streaming and social media advertising, which have very few restrictions on advertising content compared to the “identify but not promote” model of NCE underwriting acknowledgements.

The history of this educational radio service intended for school districts

I again remind everyone the type of service that they applied for when they obtained their NCE (full service or LPFM) station. This service was originally designed for schools such as colleges, universities and high schools, originally as a method for schools to transmit academic lectures to other school campuses and to provide programming to the public outside of school hours. It would eventually evolve into a training ground for future broadcasters as part of a curriculum. When the original Communications Act of 1934 was passed, there were statutory provisions put in place for the new FCC to set aside reserved spectrum for educational purposes:

“The Commission shall study the proposal that Congress by statute allocate fixed percentages of radio broadcasting facilities to particular types or kinds of non-profit radio programs or to persons with particular types of or kinds of non-profit activities, and shall report to Congress, not later than February 1, 1935, it’s recommendations together with the reasons for the same.” [47 USC §307(c) (1934)]

The first hearing for these new types of radio stations and reserved spectrum took place on October 1, 1934.1 The Commission would eventually set aside spectrum for the new “high frequency” radio service (which we know today as FM). Even when FM spectrum was in the 41~50 MHz range in those early days, there was still spectrum set aside for educational broadcasting. In the TV Table of Allotments, specific channels are set aside for educational use. This is still done to today. Since AM radio was already widespread by 1934, it was not really possible to practically reserve spectrum in the band. AM has never used a “table of allotments” like FM and TV does.

How Christian broadcasting opened the door for non-academic secular organizations, including Pacifica

In the early days, educational broadcasting was limited to not only schools but school systems. This is consistent with the original intention of educational broadcasting to be able to deliver lectures to remote campuses.2 It took action in the early days by the Moody Bible Institute of Chicago, which operated a single campus (not a school system) to argue that religious schools can provide an educational program and that their “students” also included the general public. The Commission’s decision in Moody would open the door for other educational institutions, including those in the private sector and eventually to organizations that are not in an academic setting, such as Pacifica Foundation to be the licensees of NCE stations. The organizations still had to be educational in nature and if they were not an academic facility, they had to make a showing that the radio/TV station would be used to advance an educational program. This is why today, NCE and LPFM applicants for new stations and assignment applications must include an educational statement with their application in order to justify their eligibility to use NCE broadcast facilities.

NCE/LPFM stations are currently under threat

We are now in a time when NCE stations are now under the microscope more than ever. Due to politics, stations are afraid of losing their licenses or otherwise being sanctioned just for existing. It has come to the point where some on one side of the aisle are now claiming that because the Corporation For Public Broadcasting has been defunded, that NPR affiliate stations should lose their licenses because they can’t provide programming that is “in the public interest”. This argument does not hold much water since not all NPR affiliate stations have applied for and thus have never received CPB funding. One example is right here on Delmarva in the case of WHCP, an NPR station in Cambridge, MD that graduated from LPFM in the 2021 NCE window. A graduation that was supported by REC.

While there are LPFM stations that are Pacifica Network affiliates, there are very few, if any LPFM stations that are associated with NPR though they may take programming from other public radio providers. Most secular LPFM stations today are operating with music formats. While some are true local stations with local talent and taking on local issues, a considerable number are merely jukeboxes running music formats that could have viability on commercial radio and sometimes operate in a manner where a commercial radio way of thinking is held. This kind of attitude is dangerous territory for the promotion of LPFM and small full-service NCE stations.

The reality of LPFM’s lack of an underlying funding source

Likewise, most of these stations do not have what the larger stations have, original underlying funding from school districts, university systems or well-funded nonprofit organizations. These small stations, were funded through good ol’ grassroots fundraising in the community or out of pocket expenses by the founder(s) and many are operating on shoestring budgets. Because of this, these stations are always strapped for cash and may come up with that they think are “creative” ways to fund raise. Unfortunately, there are many out there, especially in the LPFM side who either are not aware of the FCC’s Policy on the Nature of Noncommercial Broadcasting or they do know, but they ignore it or just don’t understand it because they never reached out to experts, such as REC or the peer Facebook groups in order to ask. Unfortunately, reaching out to peer groups may only expose them to more bad advice that other stations are doing that may not align with the FCC’s Nature policy.

Violations of the underwriting rules are real, and so are the fines

Violations of the FCC’s Nature policies could lead to forfeitures (fines), which in some egregious cases, could lead to the six figures. One of those egregious cases involved the Cesar Chavez Foundation (CCF), which operated a number of NCE full-service stations in California and Arizona under the brand La Campesina. The underlying foundation works to promote immigrant farmworkers. In 2018, CCF settled with the FCC by Consent Decree where CCF admitted that they “broadcast announcements that violated the Commission’s underwriting laws by broadcasting announcements that promoted the products, services or businesses of its financial contributors.”

In the introduction of that Consent Decree, the FCC, through the Media Bureau, clearly drew a line in the sand where it comes to what advantages NCE broadcasters have in exchange for providing a commercial-free service:

While LPFM stations do not have reserved spectrum (but they can use the reserved NCE spectrum if a channel is available there), they are subject to the other privileges, such as no regulatory fees and fewer requirements.

The Consent Decree also very well explains the nature of what can be included in an underwriting acknowledgement and the latitude of good judgment it gives licensees:

In the case of CCF, which involved commercials on two full-service NCE stations, the licensee and the FCC settled with a civil penalty of $115,000.

100-watt LPFMs are not immune from FCC fines

Don’t think that LPFMs will get away with only a hand-slap because of their size. In 2023, the FCC upheld a $15,000 forfeiture against Plymouth Gathering, licensee of KELS-LP, Greeley, CO. In this case, the FCC determined that the station carried over 1,600 announcements they considered commercials. In the original Notice of Apparent Liability for Forfeiture issued to Plymouth, they give examples of announcements that were considered troublesome. In the case of Payson Center for the Musical Arts, Inc., licensee of KRIM-LP, Payson, AZ, the Commission agreed to a civil penalty of $20,000, which would increase to a total of $61,500 if the licensee either fails to make the $20K payment or receives another Notice of Apparent Liability for Forfeiture.

The bottom line here is simple. Identify, but DO NOT PROMOTE. You are allowed to acknowledge a business name (which matches what is on their state corporation documents, not just a brand name), their address (without any promotional precursors such as “conveniently located at…”), their telephone number (without a call to action such as “call..”), their website URL (as long as the website URL is the business name and does not contain anything promotional in it and a brief non-value added description of one or two of their product lines (i.e. “they sell toilets from Toto and Kohler”). Slogans, while a allowed are a very very slippery slope unless you absolutely know what you are doing. Just because there is promotional language in their slogan, it does not mean that you can use it. The slogan and logogram language is more to benefit television than it is for radio. I would avoid it all costs. Also, another common misbelief is that it is OK to give some kind of promotional information as long as it is factual (i.e. “voted New Times Best of Phoenix in 2025.”) This is also NOT TRUE.

While this may have expanded since FCC Chairman Brendan Carr had recently inquired several NPR affiliates regarding the content of their underwriting messages, it has been traditional that the FCC acts on these based on complaints from commercial stations. Statistically, LPFM stations that are the most vulnerable to complaints are those that are in smaller markets where there is one prominent local or regional owner and the LPFM station is operating a format that is commercially viable (such as album rock, oldies, retro, country of all eras, etc.) or that the LPFM station engages in predatory fundraising that tries to “steal” revenues from commercial stations (predatory fundraising could be simply making claims that the LPFM station is an alternative to commercial radio advertising). We had one case a smaller southern market where the LPFM station undercut the local commercial station that for many years, had carried the local high school football games. It was reported that the LPFM would engage in commercial advertising during the football coverage.

Michi’s 11 Underwriting Commandments

So, what can an LPFM do to prevent pissing off the commercial stations, resulting in an FCC investigation and potentially a forfeiture or civil penalty:

1. Stick with the true community radio model. Do not run a jukebox of a certain music format that commercial stations could normally run, even if no commercial station in the area is running that format right now.

2. Identify and do not promote in underwriting as well as keeping message lengths to a minimum and do so in a way where programming is interrupted for the underwriting messages. Don’t do an acknowledgement in the segue and lead-in to a song. Stop programming, add a second of silence, do the underwriting, do another second of silence and return to the program.

3. Do not attempt to sell underwriting airtime by message length. (e.g. $xx for 12 30-second spots, etc.) or even try to publicize it on a rate card, etc.

4. Never say that on-air underwriting acknowledgements are for promoting a business.

5. Never sell airtime. (i.e. $xx for 30 seconds, $xx for 5 minutes, $xx per hour, etc.). Any kind of consideration received for “messages of public importance” is considered a commercial under the Communications Act, even if the typical underwriting no-nos like “calls to action” are not used.

6. Do not assume that “call to action” is the only restriction on underwriting announcements. Read the REC Compliance Guide. Also, do not assume that any kind of “call to action” is prohibited. You can do “calls to action”, but not in a manner where consideration (reimbursement) is involved. A permitted call to action can be “come to City Park this Saturday for the annual City of Podunk Spring Festival.”.

7. Just because you hear a style of announcement on an NPR affiliate, don’t assume that it is OK because “they are the experts”. Many NPR affiliates cross the line (and this is where I agree with Chairman Carr). The main difference is that NPR affiliates normally do not engage in predatory fundraising nor do they run program formats that are also very viable in commercial radio.

8. Never allow your air talent to do live reads of underwriting announcements. All announcements should be written, vetted for compliance and pre-recorded for playback during pauses in programming.

9. Never name a station element after an underwriter. (e.g. “At the Riverton Honda weather center, it’s clear and 78 degrees. You are listening to WVWA-LP Riverton, coming to you from the Joe’s Crab Shack Studios.”)

10. Never, ever do live remotes from sponsors. I know there are several LPFMs that do these, but they are extremely unbecoming of noncommercial stations and can open stations up to a treasure trove of trouble. If your station decides to go on the road to raise awareness and/or funds, bring the cameras to post social media, but keep the microphones back in the studio.

11. Avoid hiring or bringing in volunteers who’s previous experience is radio commercial advertising sales. They will bring all of their bad habits with them.

Simple.. just don’t be like a commercial station.. be different

Stations need to just provide programming that is so compelling and addresses the local needs of the community so well that local businesses will want to be associated with the station, even if they can’t talk about the mattress sale on the air therefore stations do not feel compelled to violate the Nature policies in order to make a buck to survive.

Remember, your neighbors on the dial are listening.. and perhaps Brendy is listening too. These violations not just hurt the station but they also hurt the service itself. As the one who has traveled to Las Vegas in April to be the punching bag for the service, I would love to come back from NAB some year without too many literal knocks to the noggin.

Also remember, every 8 years when your organization needs to renew their license, they must disclose any enforcement activities related to the station, including where it comes to underwriting. The Commission will then have to determine if the station is acting in the public interest. Depending on who is FCC Chairman when your license comes up for renewal could vary what that “public interest” standard really is. If there’s any time in our history to keep your nose clean where it comes to the FCC’s enforcement docket, now is that time.

Remember, advice from REC is always free (though donations are always appreciated).

Under Commissioner Brendan Carr, there has been a substantial effort by the FCC called In re: Delete Delete Delete to identify and eliminate or amend regulations in Title 47 of the Code of Federal Regulations (CFR) also known as the “FCC Rules”. A part of the overall initiative is to “delete” rule sections or subsections that may be either non-applicable or duplicative outside of the CFR. This was in response to the overall efforts of the now-former Department of Government Efficiency (DOGE) to reduce the CFR. In these cases, the Commission is identifying regulations also associated with obsolete technologies, such as regulations related to NTSC analog television receivers and telegraph service. These deletions can be done through a Direct Final Rule (DFR) process where there is no formal rulemaking process where comments and reply comments are invited. Instead, there will be a period where, within 20 days of the Order’s publication in the Federal Register, interested parties can file concerns regarding the proposed deletion of a rule. We have found that in most cases, the items being proposed for removal in the CFR were definitely justified and REC had not raised any issues.. until now.

The rule in question is §15.233. Part 15 of the FCC Rules relates to “radio frequency devices”, both “intentional radiators” which actually are intended to transmit a radio signal and “unintentional radiators” that because of the nature of the equipment, they emit a signal in the electromagnetic spectrum such as computers and power supplies. §15.233 is a rule that is specific to devices operating within the bands 43.71~44.49, 46.60~46.98, 48.75~49.51 and 49.66~50.00 MHz. This rule section states that:

(a) §15.233 is limited to cordless telephones.
(b) Telephones must operate on paired channels (a table of frequencies is included in the rule section), include a mechanism to prevent the phone from transmitting on a channel pair already in use and the instruction manual must indicate that placing a cordless phone near a TV or VCR may cause interference.
(c) The field strength of the fundamental emission shall not exceed 10,000 microvolts per meter (mV/m) at 3 meters.
(d) The fundamental emission is limited to a bandwidth of 20 kHz.
(e) Any emission that exceeds 20 mV/m must be reported in the application for certification.
(f) If the device provides for the connection of external accessories, the device must be tested with the accessories attached.
(g) The frequency tolerance of the carrier signal shall be maintained within +/- 0.01% of the operating frequency.
(h) If the device does not comply with a different cordless telephone rule, §15.214(d) regarding digital security codes to obtain access to dial tone, the packaging must include a warning message stating that the phone may pick up other radio frequency devices or RF noise resulting in the phone line being used with the knowledge of the intended user.

The cordless telephones at issue here are the second generation of cordless telephones where both the base and handset frequencies are within the 43.71~50.00 MHz bands shown above. Some of these models were marketed as “46/49” cordless phones. The first generation phones had a handset frequency in the 49 MHz band a base frequency in the 1.7 MHz band, above the AM broadcast band. Later generation phones use digital encryption for privacy and utilize frequencies in the 900 MHz, 1200 MHz and other bands in the UHF spectrum.

In the circulation draft to be considered as an agenda item for the FCC’s December Open Meeting, is a DFR for the Agency’s Office of Engineering and Technology (OET). This DFR proposes to completely delete or otherwise amend several regulations in Parts 15 and 18 which are in the purview of OET. One of the rule sections planned for complete deletion would be §15.233.1 By deleting this rule, it would eliminate the ability for these devices to be used as it would eliminate the allowance that these devices can operate with a power level of 10,000 mV/m at 3 meters. Without this specific allowance, low power devices operating in this spectrum would be limited to 100 mV/m at 3 meters. In the circulation draft footnote, OET claims that these phones “no longer operate in these bands”. They provide no evidence that every single 46/49 cordless telephone has been committed to the landfill.

When REC posted the other day on Facebook about this change, we received comments that these phones are obsolete, lack privacy and question our inquiry into why we are going out of our way to protect these devices.

Many know REC for our work with broadcast regulations but may not understand REC’s full 41-year history or our overall objectives. In our objectives statement, as part of “Citizen’s Access to Spectrum”, we state that REC does “involve itself” in “non-broadcast service issues such as the Amateur Radio Service, Personal Radio Services (CB, GMRS, MURS, FRS), broadband access and other subjects in the FCC’s jurisdiction.” REC got its start by using the public switched telephone network to deliver content and we have always been “phone phreaks”. Therefore, spectrum that is allocated for telephones would definitely fall within our operational objectives.

As far as the obsolescence of these devices, REC disagrees with OET’s general findings that these phones “no longer operate”. The OET provides no proof of that. We stated it is very possible that there are still some rural or elderly users of these devices because they simply have not changed them out (if it ain’t broke, don’t fix it). In addition, there are also telephone collectors that may still possess and use these devices. We also stated that unlike other issues that have been considered in this and past Delete Delete Delete proceedings, this proposed rule deletion removes operating privileges for a device that continues to be completely compatible with existing technology. Existing technology is any device that provides talk battery, ring generation and permits a two-way full duplex telephone conversation to take place. These devices directly plug into devices such as terminal adapters associated with Voice over IP (VOiP) services, key system and PBX devices (such as those used by collectors and some legacy businesses) as well as those that are directly connected to wireline PSTN either through copper, pair gain or fiber connections through a modular jack on the wall or an interface device. In other words, a 46/49 style cordless phone with a good handset battery can still be used to place and receive telephone calls.

While there may not be many of these devices still in circulation, the deletion of §15.233 would eliminate the 10,000 mV/m at 3 meter field strength allowance in favor of the default 100 mV/m and would make the use of these devices “unauthorized operation” in violation of §301 of the Communications Act. To put it simply, it will make the use of these devices similar to radio piracy.

REC’s position that any rule proposed for deletion of any rule under DFR that arbitrarily deletes operating privileges outside of a full rulemaking process does not fall into the “public interest” exemption in the Administrative Procedure Act (see 5 USC §5.53 (b)(4)(B)) and that the DFR cannot be used for those purposes. If the Agency allows §15.233 to be deleted by DFR, this could set a precedent that would give the FCC free reign to eliminate frequency operating privileges or make other substantive rule changes without having to go through the normal comment and reply comment process.

In other words, the FCC wants to ban a certain consumer device, which can still be used, is not being done to free up spectrum for another service and is being done under such a general assumption that these devices are “no longer used” without any documentation to back up that claim. This is not what the Delete Delete Delete DFR process was intended for. There is no reason other than “this rule is taking up space in the CFR” to delete this rule.

The concept of issuing circulation drafts three weeks prior to the FCC Open Meeting was an initiative started by former Chairman Ajit Pai and was intended to provide more transparency at the agency. Under the current Sunshine Act policies as described in §1.1203 of the FCC Rules, no person may contact FCC decision making personnel in less than one week before the scheduled Open Meeting (when the Sunshine public notice is released) regarding an item on the published agenda.

REC wrote a letter to the attention of the head of OET, the Chairman and the other two Commissioners to voice our concerns regarding deleting §15.233 through DFR alleging that it is not appropriate for this rule to be included as it would constitute a substantive change in regulations (a loss of an increased field strength/power for a consumer device that may still be used). This letter was sent on November 29, 2025, more than seven days in advance of the December 18, 2025 Open Meeting. We are requesting that this specific item be removed and recirculated to the Commissioners in respect to the DFR that will be voted on December 18.

While on its face, it may seem like REC is doing this to protect telephone collectors and rural users of this equipment, which is true, but it also exposes the carelessness that the Agency is conducting as a part of their mass eradication of regulations. In other words, banning an existing device that has been in circulation for several decades, utilizing technology that is still available does not meet the same level as the deletion of rules regarding kits for cable television interface devices that were used in the NTSC analog television days.

By allowing §15.233 to be deleted by DFR, the Agency is expanding Delete Delete Delete into new territory causing a dangerous precedence for future Delete proceedings. All FCC regulated services and devices should be worried about such a precedent.

The Media Bureau has issued a Public Notice in respect to the License Management System (LMS) used for broadcast applications. LMS will return to service on Tuesday, November 18, 2025.

For construction permits that expired during the Government shutdown or after the shutdown up to and including November 18, a license to cover application must be filed by November 28, 2025. Some permits can be tolled pursuant to §73.3598(b) & (c) of the FCC Rules.

For silent stations where the statutory 12 months of non-operation fell within the shutdown period or up until November 18, must resume operations by 11:59PM EST on November 18 in order to avoid statutory expiration of the license under §312(g) of the Communications Act.

Consistent with the REC Sixth Notification, any Special Temporary Authority (STA) that was/is set to expire between October 1 and November December 4, 2025 have been extended to December 5. Make sure your station restores licensed operation or files for an extension by December 5 (this includes silent STAs where the §312(g) period has not been reached).

In a separate public notice for commercial full service stations, the FCC has set several filing windows for uploading political file data to upload records of requests to purchase broadcast time that were received between October 1 and November 12, 2025. The filing window dates vary by state as set forth:

• November 19~25, 2025 - for stations in NY, NJ and CT.

• December 1~8, 2025 - for stations in DC, MD, VA and WV.

• December 9~16, 2025 - for stations in CA.

• December 17~24, 2025 - for stations in all other states and territories.

This is hopefully the last REC Notification regarding post-shutdown resumption of operations at the FCC. It should not have taken seven notices, but this year, it did.

In a Public Notice issued by the FCC on Monday, November 17, 2025, the agency has announced updates deadlines for several systems and proceedings.

The Notice does not provide a new filing deadline for the License Management System (LMS) used for radio and television broadcast applications. The agency advises that the Media Bureau will issue their own notice and that users should also monitor the LMS Help Center page.

For the Online Public Inspection File system (OPIF), the FCC has extended the due date for the 3Q 2025 quarterly report to December 1, 2025. This applies to full-service commercial and noncommercial stations and does not apply to LPFM stations.

EEO filings that were due on October 1, 2025 are now due on November 24, 2025. Again, this does not apply to LPFM stations.

For ULS personal radio services that include, but are not limited to amateur radio, general mobile radio service and commercial operator licenses; renewal applications that were or are due between October 1, 2025 through and including March 5, 2026 are now due on March 5, 2026. Therefore, if your ham or GMRS license “expired” during the shutdown, you may continue operating but make sure you get your renewal (with filing fee) in by March 5, 2026.

For ULS purposes other than personal radio services (broadcast auxiliary, land mobile, microwave links, etc.), the deadline for renewal and other time critical filings is now December 5, 2025.

Any Special Temporary Authority which was set to expire between October 1, 2025 through December 5 is now extended to December 5, 2025 (unless this is overridden for broadcast by the Media Bureau when they release their advice on LMS).

We will issue a Seventh Notification when we receive news about LMS.

REC Networks can verify that at least in the case of the Federal Communications Commission’s (FCC) License Management System (LMS), which is used for filing broadcast applications and obtaining detailed information about broadcast stations will remain out of service until November 18, 2025. This is based on information posted by the FCC on the LMS Help Center web page. The FCC had previously announced that filings were due by November 18, 2025.

Edited 11/14/2025 1:42 PM EST: We can also verify that this same date also applies to the Online Public Inspection File system based on a message placed on their Help Center page. We are still looking into ULS.

“Turning on a system after being shut down for more than 40 days (and 40 nights) and then expecting over a month of backlogged filings to be placed in the system in less than 24 hours will cause congestion on the system and is not very efficient, especially because at times, we may need to depend on information from exhibits from previous applications and authorizations to help prepare applications and because of the shutdown, those resources are not available. This further delay in the resumption of the systems makes matters much worse as such a delay is unprecedented compared to the recovery efforts following previous Government shutdowns. While I am not here to point fingers on particular political parties, I do seriously question this misstep, which only compounds a good share of inefficiencies these days throughout the entire (FCC) agency.”, said Michelle Bradley, founder of REC Networks in reaction to the latest delay.

We are not aware of whether the Universal Licensing System (ULS), which is used for wireless services, including broadcast auxiliary, amateur radio and the General Mobile Radio Service (GMRS) is also impacted by this same restoral date.

There is no news yet from either the FCC’s Media Bureau or the Office of Managing Director on any extension to the deadlines.

Likewise, REC eLMS services and FCC.today will remain unavailable until at least Tuesday, November 18, 2025.

Stay tuned for updates.

Further edited to update the quote from Michelle Bradley, founder, REC Networks.

November 13, 2025, 2:00PM EST

The Public Safety and Homeland Security Bureau has reprogrammed the Emergency Alert System Test Reporting System (ETRS) to allow for the filing of ETRS Form One for the 2025 Test Cycle.

The deadline set in ETRS is Thursday, November 20, 2025 at 11:59 PM EST.

As of 2PM EST, other FCC filing systems, including the License Management System (LMS), which is used for broadcast applications; the Universal License System (ULS), which is used for wireless services, including broadcast auxiliary and amateur radio service applications and the Online Public Inspection File (OPIF) systems remain unavailable. REC is frequently monitoring these systems and will announce when they return.

November 13, 2025, 10:15AM EST

The Federal Communications Commission has released a Public Notice announcing processes as a result of recovering from the recent shutdown.

First, the notice states that the “FCC staff will work in good faith with parties to resolve and address issues that arise with an influx of new filings and requests. We anticipate that complications may arise in some cases. FCC staff will bring a flexible, commonsense approach to resolving the range of issues that may arise upon re-opening in these circumstances.”

The FCC will extend the deadline of all filings that would have been due between October 1 to November 17, 2025 (yes, even going into the future) on November 18, 2025. This is somewhat consistent with the shutdown recovery policy from 2019.

For Special Temporary Authority (STA) authorizations that would have expired between October 1 and November 17, 2025, they are extended until November 18, 2025.

Finally, the Notice requests that “until such further guidance is issued, we ask parties to limit filings and submissions except where immediate authority is needed and to refrain from submitting filings seeking additional relief from filing deadlines for the time being.”

As of 10:25 AM EST, the FCC has not restored LMS, ULS or reactivated the 2025 Test Series in ETRS. Likewise, REC has not yet restored eLMS and FCC.today. REC is periodically monitoring for system status.

At this time, REC Networks is otherwise, in normal operations. We are giving priority to ETRS and any authorizations set to expire between October 1 and November 17, 2025. If you need assistance, please contact via email lpfm@recnet.com. Please make sure you leave a valid phone number and the call sign or facility ID of the station.

REC expects to release a fourth notification after the FCC systems have been restored and when eLMS and other REC update servers are resumed.

Wednesday, November 12, 2025, 11:45PM EST

Russel T. Vought, Director of the Office of Management and Budget (OMB) has circulated a memo to the heads of executive departments and agencies instructing that agencies should take all necessary steps to ensure that offices open in a prompt and orderly manner on November 13, 2025. Employees who were on furlough due to the absence of appropriations should be directed to return to work on November 13.

As of 11:45PM EST, both LMS and ULS filing remains unavailable.

Our next update will be Thursday morning.

Good night (for certain this time) from Riverton.

Wednesday, November 12, 2025, 11:00 PM EST

The President has signed the Continuing Resolution (CR) legislation that was passed in both houses in order to reopen the government. As this event was reported at 10:30PM EST, it is unknown yet how this will impact the Thursday workday for federal employees. Federal employees should receive guidance either through the Office of Personnel Management (OPM) or their agencies regarding returning to work.

Some legal experts in the field of the Federal Communications Commission (FCC) have suggested that filing deadlines will be the day the business day that the government reopens. REC is not prepared this soon to enjoin in that advice.

We do note that in the aftermath of past shutdowns, the FCC has issued specific advice in regards to filing deadlines including those where filings may be due over the next several days. We do feel that this will very likely happen in this case given the unprecedented length of thus shutdown period and what the potential impacts could be with a significant amount of filings going into LMS, ULS and other FCC systems. However, we do advise applicants to remain on the side of caution and be prepared to file.

We have a particular concern regarding the EAS Test Reporting System (ETRS) as the deadline for filing ETRS Form One fell on October 3, three days into the shutdown. We will be watching this system closely, especially given that it is a contracted system, operated outside of the standard FCC IT structure. We need to make sure that the FCC’s Public Safety and Homeland Security Bureau, (1) reopens Form One filing for the 2025 Test Cycle and (2) provides a reasonable extension (such as at least 5 business days) for Form One filings for the 2025 Test Cycle. We may find that any advisory that extends out the deadlines will also encompass ETRS, but we need to make sure that the system is reenabled for the updated deadline.

As of 11:00 PM EST, access to certain FCC systems suspended for the shutdown have not yet been restored. We will make another check again in the early morning on Thursday. In the meantime, REC will keep our online services in shutdown mode until we know that systems are operating and that REC systems, such as eLMS are able to communicate with the FCC.

In accordance with our “bonnet on” policy, we will not comment on any issue in this bill that is under political contention which is not directly related to the Federal Communications Commission, including the welfare of its career staff. We will only state that we are grateful that career federal employees are returning to work, they will receive retroactive pay and that any reductions in force (RIFs) announced during the shutdown have been rescinded. We are not aware of any such RIFs for the FCC.

Hopefully, we will have more information in the morning. Good night from Riverton.

The lack of appropriations caused the closure of most Federal government functions started on October 1, 2025, which in turn, ceased operations at the Federal Communications Commission. On Sunday, November 10, about forty days later, there has been bipartisan progress in the U.S. Senate in an effort to reopen the government. As of this writing, the Government is not yet open. There are a still several hurdles to cross first.

By policy (“bonnet on”), REC Networks takes no position on the nature of the continuing resolution other than our support for the resumption of FCC operations and returning career FCC employees back to work.

FCC filing deadlines that fell during the shutdown

Those needing to file with the FCC may receive, but should not assume extended filing deadlines upon reopening. In our current shutdown, LMS and ULS are not operational. On September 30, 2025, the FCC released a Public Notice to advise that the filing due date will the business day after the FCC resumes normal operations. We do note though that during the 2019 government shutdown, which lasted 23 days and resulted in systems such as LMS and ULS not being available, the FCC did extend filing deadlines based on what date during the shutdown that the filing was actually due. Again, I stress: do not depend on the 2019 policy to match the one that will be put into place when 2025 operations resume. It may be the same, it may not. We won’t know until after the government reopens.

For full-service broadcast stations, as the deadline for the Q3 issues lists (public file) would have been during the shutdown (October 10), we strongly suggest that you have your documents prepared and be ready to upload your reports to OPIF once the FCC resumes operation and makes OPIF available again.

If your station was on a silent STA and the statutory 365-day limit on being silent passed during the shutdown, but your station did resume operation on or before the original 365-day deadline, be prepared to include additional statements to show that the station did truly return before the 365-day deadline. §312(g) of the Communications Act permits the FCC to extend the deadline for “any other reason to promote equity and fairness”. I cannot guarantee that they will. They may ask for more evidence of construction prior to the §312(g) date, so be prepared with copies of any invoices, photographs, etc. that prove that the station was broadcasting a signal on or before the statutory 365-day period date. In my non-attorney opinion, this 365 day period does stand, even though the government was shut down. For legal advice, please seek the services of a qualified communications attorney.

REC operations following the conclusion of the shutdown

Unless superseded by family priority, REC will return to normal operations on the first day of federal business. Our first priorities will be on the following:

• ETRS Form One filings (REC will be advocating for an extension to allow for reasonable time for these “routine” filings to be made).

• §312(g) silent station resumption notifications (where the resumption of operations happened on or before the business day of the station going silent).

• License to cover applications for construction permits with expiration dates during the shutdown period.

As of Monday, November 10, 2025, REC will return to modified operations as FCC systems will not be available. We will accept new requests and collect fees. Once government operations resume and FCC systems are restored, then we will move ahead handling applications, giving first priority to the three bullet points above.

When FCC systems are restored, the impacted REC interfaces (such as eLMS) will be restored and we will go back to our normal database update schedule. At that time, we will restore services on fcc.today.

During the shutdown, REC has been involved in some heavyweight non-broadcast related projects which included the development of some methods that could improve the user experience in our broadcast-related online products.

How to help support REC Networks

You all may have noticed that I have taken somewhat of a back seat during this shutdown. This is mainly because of our “bonnet on” policy where I do not take partisan political sides of an issue and because the issues at hand do not directly address the purview of REC’s broadcast related operations from a policy perspective. Right now, our priority is getting the government reopened, getting government employees back to work and getting applications and other services once again flowing through our shop. During the shutdown, we did not collect any money for services because we could not anticipate when the government would be reopen for business. In addition, the lack of some FCC resources (such as past application exhibits, etc.) compromised the quality of the work that I do here. I was not going to collect money only to have to give it back because it turns out we could not do that.

For those who have made sustaining donations to REC on a monthly basis, I would like to thank you all as that little bit of a donation did help during these difficult times.

Those who wish to help support REC’s efforts can do so in four different ways:

• Have REC handle your FCC application filing needs. We handle LPFM, full-service FM (commercial and noncommercial), FM translators as well as FM booster stations in certain situations.

• Direct donations can be made by going to our main website (recnet.com) and clicking on the donate link (REC is not a §501(c)(3) organization for tax purposes). You may donate one time or become a sustaining supporter once per month.

• If you need to purchase a broadcast transmitter, you may purchase one through Progressive Concepts. Use the coupon code REC for a 5% discount on equipment manufactured by BW. REC receives a commission on those sales. (The 5% discount and REC support only applies to BW equipment and does not apply to antennas or anything else they sell.)

• If you need streaming services, mobile apps, Alexa skills or other similar services, you can purchase those through Cirrus Streaming (SecureNet) using our specific website link. REC will receive a recurring commission for as long as you continue their services.
  https://cir.st/?RSCODE=10070352

Money received helps keep our systems running and helps keep food on the table.

Thank you for your support.

Due to family priority, REC will be in reduced operations (unavailable for a portion of the day) on Tuesday, November 11 (this is also a federal holiday, REC is normally closed on holidays but given the situation, the phones will be on) and minimal operations (unavailable for most of the day) on Wednesday, November 12.

You can reach REC by calling 202 621-2355 or email lpfm@recnet.com.

10/03/2025 7:35 AM - NETWORK UPDATES ---

ULS: The FCC has kept the Universal Licensing System (ULS) inquiry functions (i.e. to look up ULS handled licenses, antenna structure registrations, etc.) up and running, however the ability to electronically file applications through ULS is not available. We are assuming that this also impacts the batch filing system that is used by amateur radio volunteer examiner coordinators. The database for ULS has not been updated since 10/1. We are keeping our update services to ULS offline until the shutdown is over.

CONTOURS API: The FCC also has not interrupted service on the Contours API. This is good news for us as we have several services (FCCdata, myLPFM, toybox and internal applications) that are dependent on the API for contour mapping and HAAT measurements. We note that if there is a disruption in the Contours API, you will see messages that appear on many of the services that use that API to warn of a disruption.

FCC.TODAY: REC has completely suspended fcc.today for the duration of the shutdown and users are being redirected to an outage message. The Licensing Management System (LMS), which is used for broadcast applications was suspended by the FCC for the shutdown. This includes the ability to look up applications directly in LMS. You can still look up applications in FCCdata, but links to FCC resources, such as actual applications, exhibits and authorizations is not available. On applications involving engineering (that appear on the left side), clicking the [Application Details] button may show a bunch of information from the application that may help you during the shutdown.

URGENT REQUESTS FOR LMS/CDBS DATA ELEMENTS: Please note that our eLMS system does read most non-engineering applications for FM, AM and TV including some of the application details and we do collect most data elements contained within the four-corners of the application. While we store this data in eLMS, we don’t have a self-service method of displaying all of that data. If you have a critical need for data that was on a particular LMS handled broadcast application (we don’t have exhibits, authorizations or correspondence), please contact REC and if possible, we can do a manual search. A donation in connection with such a search is always appreciated (donations are always appreciated!). If you need more details about an application that was originally filed in CDBS (file number beginning with a “B”), you can try our CDBS Historic Search at cdbs.recnet.com. While we do not keep exhibits, we do have an extensive collection of correspondence (letters to and from the FCC, decision documents, etc.) on the CDBS-filed applications. Like with LMS/eLMS, if you need some kind of raw data research, please contact REC to see what we have. Serious requests only. Thank you. Just as a reminder, we do have the raw LMS data dump on the shutdown page and historic CDBS raw data is available on the historic CDBS site.

ETRS: Those who have already contacted REC for ETRS filing, we have your requests. We note that ETRS is still operational however it is still set with the current deadline of 10-3-2025. We are expecting an extension of that date, pursuant to 47 CFR §1.4(e) of the Commission’s Rules. We will once again accept requests for new ETRS filings. We note that we will not be sending invoices during the shutdown. However, if you do request ETRS from REC, you must be prepared to pay any invoice nearly immediately after receiving as any deadline extension may not be that long. Please send requests to lpfm@recnet.com and PLEASE include the word ETRS somewhere in the subject line so it can be easily screened (we do get a lot of spam, lists, etc.)

THE ADVICE IS FREE: If you have any questions on anything that is within our purview, please contact lpfm@recnet.com. The advice is always free, but donations are appreciated.

WE ARE THINKING OF THE FEDS: Broadcasting and the FCC only works, not because of the partisian politics (from both sides) at the top, it’s because of the career federal employees, many of whom have worked through multiple administrations at 1600 and still provide the same top level expertise regardless of who sits on the FCC Bench. Right now, many of these employees are furloughed and even for those considered “essential”, they are not getting paychecks right now. We are thinking about our federal partners and hopefully soon, we can all be back to work. These employees have families. This is not vacation.