LPFM Checklist: Station Administration and Inspection Availability

Accessibility for Inspection

Unless the station is subject to a pledge made in the 2013 or 2023 LPFM filing windows, LPFM stations are not required to staff a main studio.  Even for stations that are subject to the pledge, there is no requirement for a meaningful management presence like there is in the full power rules.  Even without a main studio requirement, you must make a station available for inspection during the station’s business hours or at any time the station is in operation.

Unattended Operation

LPFM stations are allowed to be operated “unattended”.  This consists of either automatic transmission monitoring or self-monitoring equipment that can automatically shut down the station within 3 hours if an out of tolerance condition arises or by operating equipment designed to operate for prolonged periods of time which virtually all LPFM transmission equipment is.  In cases where there is no automatic monitoring, the station should be monitored frequently throughout the day and may need to be shut down within 3 hours of detecting operation out of tolerance.

If an LPFM station plans to operate unattended, notification should be provided to the FCC’s Media Bureau to advise them of the address and/or telephone number where a responsible party can be reached during unattended operation.  A copy of this letter should be retained in the station records during the entire time the station is operating unattended.

(11/2017) The FCC LPFM Checklist publication states that notification is required.  Research conducted by REC and others have confirmed that this is an informal process within the Enforcement Bureau (the authors of the FCC Checklist) to assure they have contact names and numbers for the local broadcast stations in the area where the field offices cover.  There is no specific rule that codifies a requirement for notification.  REC strongly suggests notification to either the Media Bureau or to your local field office.  See 10 FCC Rcd 11479 at paragraph 33.

Control Point

Every station should have a designated control point.  This is the location where the operation of the station takes place such as where the studio is located.  At that control point, certain documents need to be made available for inspection.

Authorizations

There is no longer a requirement that stations post a copy of their license and other permits at the station's control point.  Despite a lack of requirement, we do recommend that copies of all authorizations be available in a location where they can be easily accessible by station staff when needed.

Station Logs and Records

While LPFM does not have a public file requirement, they are still required to keep specific logs and records.  These logs and records include:

Transmitter/Station Log

In this log, you need to record various events that take place including turning on and off the transmitter as well as entries related to any discovered non-compliant operation that is pending or has been resolved especially related to the status of Emergency Alert System (EAS) equipment as well as any maintenance to the other station equipment.  Logs should note the date and time of the entry and the person making that entry.  It’s always a good idea to log when nothing is wrong but was checked just in case.

Political File

LPFM stations are required to keep a complete record of all requests for broadcast time made by or on behalf of candidates for public office (at any level) together with the appropriate notation showing the decision made by the station of such requests and if the request was granted, any charges made, if any.

EAS Log

In most cases, the EAS log will be generated by your EAS equipment.  It’s always a good idea to periodically print a paper log for your station records.  The EAS log will track messages received including required weekly and monthly tests as well as actual activations.  There will be more on EAS later on.

Antenna Structure Lighting

This does not apply to a large majority of LPFM stations but for LPFM stations that own their own tower that is subject to lighting and painting requirements, you must keep a log that tracks the extinguishment or malfunction of required lighting as well as repairs, adjustments or replacement of the lighting system and any related notifications to the FAA.  We will expand on this later on in this training.

All of these items must be maintained in your station records for a minimum of two years and must be made available to FCC staff and representatives upon request for review and/or duplication.

Third Party Fundraising Reports

Third Party Fundraising is the interruption of programming in order to raise funds for a bona-fide §501(c)(3) non-profit organization other than the station's licensee organization.  Stations may devote up to one percent of their annual airtime to this type of fundraising.  All documentation related to the operation, including the dates and times the fundraising took place and documentation about the benefactor organization, including evidence that they are truly an IRS §501(c)(3) organization. 

For more information on Third Party Fundraising, see the REC Compliance Guide.

Records Retention

While logs and reports should normally be maintained for at least two years, REC strongly suggests that records be retained until at least 30 days after the grant of the station's renewal, or two years, whichever is later.

General organization eligibility

Localism

For LPFM stations that are not operated by government entities for public safety purposes or Tribal entities, localism must be maintained for the life of the LPFM license.  This means that all LPFM licensees must meet one of the following requirements:

• The headquarters of the organization must be within 20 miles of the LPFM transmitting antenna; or
• At least 75 percent of the governing board must reside most of the time within 20 miles of the LPFM transmitting antenna.
• Within the counties/areas that are designated as Nielsen Audio top 50 markets: The 20 mile limit is reduced to 10 miles.

If the organization's headquarters is not within 10 or 20 miles of the LPFM antenna, they need to be aware when a member of the governing board moves to a different residential address to assure that the localism requirement is being maintained.

Public safety and Tribal entities are only required to have their LPFM station serve their jurisdiction or Tribal Lands.

State Corporation Status

The FCC requires that nonprofit organizations that are licensees of LPFM stations to not only be an active recognized corporation at the time of application, but also throughout the station's license term.  Maintaining a corporation status may require the filing of annual reports with the state and/or paying annual fees.  Stations should check with their Secretary of State's "Business Search" websites to check on their current status.  If the status is anything but active, they need to take measures to reinstate their corporation status.  Most states will reinstate corporations retroactive to when they were originally suspended.

Notifying the FCC of Board Member Changes

The FCC requires that any sudden or gradual change of more than 50 percent of the governing board must be reported to the FCC through a pro forma Transfer of Control application.  To determine the amount of change, use the information on the latest filed original Construction Permit, Assignment of License or Transfer of Control application.  If the makeup of the governing board has changed at least 50 percent from that previous application (counting all persons equally), then the pro forma Transfer of Control application must be filed within 30 days of the triggering change.   LPFM stations are not required to file Ownership Reports.  Filing an Ownership Report in lieu of a pro forma Transfer of Control application is not appropriate.

FCC Administrative Information

The FCC needs current contact information for each station. This includes a mailing address, telephone number and email address.  The license record should also reflect the exact name of the corporate entity as shown on the official State corporation records.  You can see your current license records using the Facility Search in LMS.  If the information has changed, the station needs to file an Administrative Update in LMS to update the information.

Point System Pledge Requirements

This section only applies to LPFM stations that, during the filing window, were mutually exclusive (MX) and had to use their points in order to obtain their original construction permit, even if the station had been assigned to a new owner since the filing window.  If the station was originally granted as a singleton or was able to "break out" of their MX Group after the close of the filing window, then this section does not apply.  Most stations that are subject to these pledge requirements are shown on REC's Pledge List. 

For LPFM stations from the first First Generation LPFM Filing Window Series (2000~2001 with a facility ID number beginning with 12XXXX or 13XXXX), these pledge requirements only apply if the station made a major change during the Second Generation LPFM Filing Window (2013) and used their points to obtain a construction permit.

Local Program Origination

Applicants that claimed the Local Program Origination pledge and are subject to the point pledges as described above must originate at least 8 hours of local programming per day.  Local programming is defined as production of programming by the licensee, within 10 miles (regardless of market) of the transmitting antenna.  Local origination includes licensee produced call-in shows, music selected and played by a disc jockey present on site, broadcasts of events at local schools, and broadcasts of musical performances at a local studio or festival, whether recorded or live.  Local origination does not include the broadcast of repetitive or automated programs or time-shifted recordings of non-local programming, whatever its source.  In addition, local origination does not include a local program that has been broadcast twice, even if the licensee broadcasts the program on a different day or makes small variations in the program thereafter.

Main Studio

Applicants that claimed the Main Studio pledge and are subject to the point pledges as described above must maintain a publicly accessible main studio that has local program origination capability, is reachable by telephone, is staffed at least 20 hours per week between 7AM and 10PM and is located within 10 miles of the LPFM transmitting antenna in the top 50 markets and within 20 miles elsewhere.

Self Check

Items with an asterisk * may not necessarily apply to all stations.

• Are current station authorizations readily available where staff can access them? 
• Are required logs being retained for a period of 2 years?
• Are station logs/records readily available for inspection and/or duplication at the request of the FCC or its representatives?
• Do the logs clearly and accurately document all repairs, changes and other maintenance performed on the station equipment?
• Do the logs contain the time and date of each observation and the name of the person making the entry?
• Is the station maintaining a political file in accordance with §73.1943(a)~(c)?*
• Is the political file being retained for a minimum of 2 years?*
• Does the licensee organization still meet the localism requirements?
• Is the licensee organization's corporation status with the state currently active and in good standing? (does not apply to public sector, including Tribal entities)
• Has the station had any board member changes of over 50% since the last time the FCC was notified about the board members through a previously filed application? (may not apply to public sector entities, please consult your general counsel or attorney for advice.)
• For stations subject to the point pledges, is the station complying with those pledges in respect to Local Program Origination and Main Studio?*
• Does the official name of the corporation that shows on state records match the name shown on the license?
• Is the mailing address, email address and phone number shown on FCC licensing records the most current?
• If the station is operating attended, does the licensee maintain a person on duty at a fixed location, during all periods that the station is on the air where they can either monitor or control the station themselves or be contacted by automated transmitter monitoring equipment within 3 hours after an out-of-tolerance condition arises?*
• If the station is operating unattended, does the licensee maintain either automated equipment or periodic human monitoring that enables the station operation to be corrected or terminated within 3 hours if an out-of-tolerance condition arises?*
• For unattended operation, did the licensee inform the FCC Media Bureau, in writing, of the address and telephone number of a responsible party?*

References

• §73.845 – Transmission system operation
• §73.853 - Licensing requirements and service
• §73.872 - Selection procedure for mutually exclusive applicants (point system pledges)
• §73.877 – Station logs for FM stations
• §73.878 – Station inspections by FCC; availability to FCC of station logs and records
• §73.1212 – Sponsorship identification; list retention; related requirements
• §73.1300 – Unattended station operation
• §73.1400(a) – Transmission system monitoring and control
• §73.1943 – Political file
• §73.3533(a)(7) – Application for construction permit or modification of construction permit
• §73.3536 – Application for license to cover construction permit
• §73.3539 – Application for renewal of license
• FCC 00-19 The original LPFM Report and Order (15 FCC Rcd 2205)
  
  • See paragraph 119 for 2-year record retention policy.
  • See paragraph 117 for notifying the FCC about unattended operation.

Related REC Knowledge Base Questions and Answers

• Are LPFM stations required to maintain a public file?
• What information must LPFM stations keep in the station log?
• Are LPFM stations required to have a “chief operator”?
• Can an LPFM station operate unattended?
• What do I do if a political candidate wants air time?
• Is my station subject to the point pledges such as local programming and main studio?
• Where can I find the rule that requires LPFM stations to operate a certified transmitter?

Let's now move on to Your Broadcast Day.

Information in this document is current as of March 27, 2025.

Information provided by REC Networks is for educational purposes only and should not be construed as legal advice.  For legal advice, please obtain the services of a qualified attorney that specializes in FCC law, especially where it comes to LPFM.