With the recent approval of the information collection and form changes by the Office of Management and Budget, the FCC has made several announcements to state that certain forms will be changing. Some of these changes are to reflect rule changes in MB Dockets 19-3 and 19-193.
LPFM Directional Antennas
LPFM stations proposing to operate a directional antenna will now select on the ":Antenna Technical Data" tab that the antenna type is "Directional". When "Directional" is clicked, the form will open up 36 fields for you to enter the field values in each of the 36 different directions. These field values indicate the amount of attenuation in each direction. These tabulations will be provided to you by your antenna manufacturer. There are additional fields where, in the event that a field value (mainly the peak of the antenna, field value 1.000) is not on a 10 degree increment, then you can enter the heading and the field value.
It is also important that LMS does not support a "rotation" function. Therefore, if you have a generic tabulation chart from the antenna manufacturer that was not custom done for this customer and this antenna, you may need to "rotate" your pattern. Therefore, you will need to manually start your peak lobe at the direction that the antenna is facing and then work your way around. For example, if the antenna is pointed at 140 degrees from what the generic spec sheet for the antenna states, the enter the value from the sheet of 0 into 140, 10 into 150. (If you go 360 or over, then subtract 360 from the heading value). If the heading is not a value of 10, then there is more complexity involved and you will need to contact the antenna manufacturer, REC or your consultant of choice for assistance.
REC has raised concerns with Audio Division staff regarding the use of the tabulation entry for LPFM stations desiring to operate on a directional basis solely for Travelers Information Service or for second adjacent channel waivers as these are either codified in the rules or extended to be nondirectional in previous rulemaking proceedings.
LPFM stations continuing to operate nondirectional facilities will select Non-Directional from that screen.
LPFM/NCE Site Assurance
The new FCC LMS schedules for LPFM now show, in the Technical Certifications, a place for Reasonable Site Assurance. In this section, the Commission will expect an answer to a certification question regarding whether the applicant has reasonable assurance to build and if the site ownership is not connected to the applicant, name and phone number of the tower contact.
Normally, FCC policy only requires site assurance for NCE (including LPFM) original construction permits. REC will be expressing concerns with Audio Division Staff regarding the requirement that site assurance is being collected also on modification applications.
Assignments and Transfers - moving to LMS
The FCC has announced that on November 18, 2020, applications for assignments of license and transfers of control will be moved from CDBS to LMS. The new LMS names of the various forms will be as follows:
- Assignment of Authorization non-pro forma (replaces Form 314 for most assignment applications including the ones we do in NCE/LPFM, replaces Form 345 for FM translators)
- Transfer of Control non-pro forma (replaces Form 315 for most FM services, replaces Form 345 for FM translators)
- Assignment of Authorization pro forma (replaces Form 316 for certain types of assignment applications)
- Transfer of Control pro forma (replaces Form 316 for transfer of controls and used for board changes)
In LPFM and NCE, the two most common transactions will be:
- LPFM facility from one nonprofit organization to another: This is currently done in CDBS on Form 314 but after November 18, 2020, use the option: Assignment of Auhorization non-pro forma.
- A change of over 50% of the board members of the existing licensed organization: This is currently done in CDBS on Form 316, but after November 18, 2020, use the option: Transfer of Control pro forma.
So what's still in CDBS?
At this time, it appears the following things will still be in CDBS:
- Special temporary authority (STA) applications.
- Silent notifications.
- Requests for Silent STA.
- Resumption of Operations.
- Digital Notification (for stations turning on HD Radio)
- Change of address for CDBS - also file an administrative update in LMS.
We will check with Staff regarding Consummation Notices and how those will be handled based on how the original (assignment/transfer) application was filed.
