REC LPFM Advisory Letter #18: Second advisory announcing the resolution of the Local Community Presence bug in LMS

Second advisory (08/09/2023)

The issue originally reported by REC in which the new LPFM application in LMS was not accepting applications which cannot claim the Local Established Presence point appears to have been resolved. 

On the Point System Factors section of LMS, applicants that cannot claim the Local Established Presence point should select the option "N/A".  Applicants that can claim this point must select the criteria on which they are basing their claim (educational organization, public safety or Tribal).  

Original advisory (07/29/2023)

On Wednesday, July 26, 2023, the FCC made live in LMS, the application form for filing original construction permits in the upcoming Third Generation LPFM Filing WIndow which will be held from November 1~8, 2023.  As of July 29, 2023, the FCC Media Bureau has not issued a public notice to announce this form and provide guidance. 

During our testing as part of our development of eLMS capabilities to properly handle the LPFM CP applications, we have noticed a serious issue with the form.  

In the Point System Factors/Tie Breakers section of the form, it is currently requiring all applicants to claim the Established Community Presence, regardless of the age of the organization.  Only LPFM applicants with a minimum of two years established local presence may claim this point pursuant to §73.872(b)(1) of the FCC Rules.  The form requires an entry and does not have an option for not claiming the point.

This fatal bug has been reported to staff.

At this time, we advise all filers who plan to participate in the Third Generation LPFM Filing Window to refrain from starting their application if the applicant is not eligible to claim the Established Community Presence point.  

We will update this Advisory Letter when we have more information. 


  • 7/29/2023 02:50 PM EDT - Initial version of this Advisory Letter.
  • 8/9/2023 09:10 AM EDT - Second avisory announcing resolution of the issue.

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