After a review of the Report and Order for the amendment of the Rules to eliminate the main studio for full service AM, FM and TV broadcaters, we find there is no specific impact to the operations of LPFM stations.
While a small number of LPFM stations that used their points during the 2013 filing window to eliminate competing applicants are subject to the pledge that they maintain a local presence for a minimum of 20 hours per week, there is nothing in this Report and Order that rescinds that pledge. The FCC recognizes the fact that the pledge requirements do exist, it had made no positive effort to eliminate the LPFM local presence (main studio) requirement. Nowhere in the Report and Order other than in footnotes was LPFM even mentioned and no part of Subpart G (where the LPFM rules are) was amended in this report and order.
REC's interpretation of the order is that there is no change to the LPFM local presence (main studio) rule and that LPFM stations that are on the pledge list must continue to maintain their 20 hours per week of local presence.
Please note this is not legal advice. For legal advice, please consult an attorney.