FCC is requiring all broadcast stations (including LPFM) to make their annual ETRS filing by October 3. REC PACE Program update.
ETRS Form One is due by October 3. REC will provide this service. Updates on REC's PACE Program for LPFM station recognition.
On Monday, the FCC announced that the Emergency Alert System Test Reporting System (ETRS) is now open for Form One filings between now and October 3, 2025.
Based on all of the information received, there does not appear to be a full EAS National Periodic Test (NPT) this year. This is unusual as in the past these tests have occurred every two years and this would have been the year when a full test would have otherwise taken place. As such, there will be no Form Two or Form Three filing requirements this year.
During years which there is not an NPT, §11.61(a)(3)(iv)(A) of the FCC Rules require that broadcast stations refresh their information in ETRS on an annual basis, even if there is no FEMA/FCC coordinated NPT that year.
For stations, this means going into ETRS, updating and then submitting Form One. If your station has used ETRS in previous years, all of the information should be retained, but you will still need to do a form submission, regardless.
LPFM stations from the Third Generation 2023 LPFM Filing Window that are not yet on the air are not required to file in ETRS.
Licensed stations that are currently silent are still required to file. Please note that since the creation of ETRS, there has already been one enforcement action taken against a station for several reasons, including failure to file ETRS.
ETRS filings are not required for FM translator or FM booster stations.
REC Service Offering
REC will provide ETRS filing services for all broadcast stations. Our rates are based on the station’s service type and whether REC Networks has handled ETRS in a previous year. Per the REC Networks 2025 Professional Services Rate Card:
Licensees who have used REC in the past for ETRS filings and have not since the previous time assigned the license (where the FRN has changed), our rates are as follows:
LPFM stations: $50 per facility.
Full-service FM stations (commercial and noncommercial): $100 per facility.
Licensees who have never used REC in the past for ETRS filings or have had the facility assigned since the last time REC handled a request (thus meaning the FRN for the facility had changed), our rates are as follows:
LPFM stations: $100 per facility.
Full-service FM stations (commercial and noncommercial): $150 per facility.
Market premiums: All commercial stations located in top-50 markets as well as full-service noncommercial stations located in the top-50 markets with a service contour population exceeding 1.2 million persons will pay a higher rate depending on service contour population. Please contact REC for details or consult the appropriate rate card. Market premium rates do not apply to LPFM stations. All LPFM stations pay the same rate.
How to request REC services: Please e-mail your request for service to lpfm@recnet.com. Please include your station(s) call sign(s) in the initial email. EZforms ordering is not available for this service at this time. Like with any other REC service, we will invoice via email. The fees will be paid by clicking the link in the email and paying with a major credit or debit card.
REC PACE Program
REC’s PACE Program is a recognition provided by REC to licensed LPFM stations that have been licensed to the same entity for at least the past four operational years that meet certain performance metrics around:
Participation: Participating in all full EAS National Periodic Tests when they are scheduled in the past four operational years, and all three forms are timely submitted. Years where only Form One needs to be filed (2022, 2024, 2025) are not considered when determining Participation.
Availability: Ensuring that in the past four calendar years, the LPFM station has not been silent for a period exceeding 365 days (either consecutive or grouped into separate issues).
Compliance - The station has not received any enforcement notices in the past four operational years.
Experience - The station has been fully-licensed to the same entity for a period exceeding four operational years (time while on the original construction permit does not count).
“Four operational years” is based on a rolling calendar and does not include days that the station was silent.
For the purposes of the PACE Program, years in which only a Form One submission is required (such as this year) is not considered in when determining the Participation metric for PACE.
We are also announcing in regards to PACE, the four year anniversary for the Form Three deadline from the 2021 NPT is coming up on September 27, 2025. Stations that have had no silent periods within the last four days will see the 2021 NPT test year age off of their records. This means for stations that had submitted all three forms in 2023 but not in 2021, the [P]articipation metric will show as satisfied as long as the station was not silent in the past four years. This may mean that there will some LPFM stations joining PACE for the first time after September 27, 2025.
Benefits of PACE status
PACE is our way of identifying reliable LPFM stations that are fully involved in their station and have taken steps to remain compliant, remain on the air and have gained enough experience to be a broadcaster. This helps when we perform regulatory advocacy and defend the LPFM service.
Stations receiving PACE recognition will be indicated by a green star symbol, after their call sign in FCCdata.org, FCC.today and LPFM.us, the national LPFM station directory.
Stations receiving PACE recognition have the elevated feature access to myLPFM at the same level as any facility with a minimum of $350 historical spend on application services from REC.
Stations receiving PACE recognition will receive an enhanced listing at LPFM.us, the National LPFM Station Directory.
For more information on PACE, visit:
https://recnet.com/pace
To check your LPFM station’s current PACE status, visit:
https://recnet.com/pacer