REC Networks has reported information on a bug to the Media Bureau regarding the handling of renewal applications in LMS.
This bug only applies to broadcast stations that also have FM translators and/or FM boosters, especially those who have commonly-owned translators that are not rebroadcasting a commonly-owned primary station (such as leasing, time brokerage on an AM, etc.)
Currently, in LMS, you have an option to file a renewal application for a commonly-owned translator or booster on the same application by adding that facility ID number on a certain screen. You will then be asked to answer the renewal questions specific for that translator. However, when the application is filed, you only get one file number that covers the primary station and all of the translators on the application.
This current functionality causes a couple of issues:
- SInce there is no separate file number for the translator, if someone was to go to the FCC's LMS Public Access search tool and enter the translator call sign, it will look like no renewal was filed. In order to see the renewal, you have to know the call letters of the station that the application was filed on.
- LMS raw data does not include any table that references these "sub" stations thus making it difficult to display these in third party tools such as REC's FCCdata.org.
- If an informal objection or petition to deny is filed against one of the translators, then the entire application is blocked from renewal, even if the primary station facility is not under any kind of controversy and is not the subject of the objection. Likewise, if the FCC grants an objection on the one facility under controversy, it is unclear how the FCC will dismiss the one facility off the application while allowing the other facilities to go granted.
The previous filing system CDBS had the ability to enter multiple facilities on an application however it would assign a file number (ARN) for each facility and tie it to a master record. CDBS's current handling of assignment of license and transfer of control applications work the same way.
At this time, REC's advice is to do a workaround. Instead of indicating the other faciliies on a single renewal application, issue the primary renewal application without any additional translators. Once that application is issued, file a separate renewal for the translator. If you have one primary station and one translator, you will end up with two different file numbers.
REC is aware of many problems with LMS, both on the front end and in the raw data that we use to interpret the facility information for our various tools.
We have added this to our LMS BUG LIST and have notified staff who is looking into it.
