LPFM APPLICATION HANDLING DELAYS (12/20/19 UPDATE) & ** FCC LMS BUG LIST ** updated 12/27/2019
The following list are various bugs and other issues of the FCC's Licesnsing Management System that we are aware of at REC. These issues have been already reported to staff.
LPFM APPLICATION HANDLING DELAYS - UPDATE
Updated 12/20/2019: The FCC reports that they have made recent updates that enabled routine processing of a majority of applications filed in LMS. This will result in a slow residual return to pre-October processing levels over time. This is something the Commission is still working on. For now, if you still have an interference or silent deadline to deal with, please contact REC for assistance.
As of 11/25/2019, the FCC has only granted 5 LPFM modification applications and has yet to grant a license application for an LPFM station that was originated in LMS. Staff is aware of this problem. When inquiring on applications, Staff has advised REC that it may take up to a couple of months. One application was granted last week so this may hold some promise. REC is continuing to escalate this issue with staff. Please stay tuned on REC's Facebook Page for updates.
If you have an application already filed that is either to resolve interference or is up against a statutory deadline (i.e. silent station), please contact REC for assistance.
LPFM HAAT/ERP calculations
LMS is not properly calculating height above average terrain on LPFM applications. This is resulting in LPFM stations with higher HAATs being "short changed" on their power.
Recommended workaround is to make a screen shot of the FCC HAAT tool and FMPOWER results in order to justify the ERP that is appropriate for the application.
Licensed antenna data carrying over to modification applications
On LPFM construction permit modification applications, the data about your current antenna make and model is being carried over to the filed form. There is no place in the LPFM application flow where this can be changed on a modification. Traditionally, LPFM stations disclose their antenna types on the license to cover (319) applications. This is creating confusion within staff if the application is also accompanied by a second adjacent channel waiver request that specifies a specific atnenna different than the currently licensed antenna. This has resulted in applications being wrongfully dismissed.
Staff has been made aware of this and will hopefully be more watchful for these applications.
FM translators with LPFM primary stations
(10/11/19) Applications to modify FM translators are currently not able to specify an LPFM station as a primary station.
This has been reported to staff. We are awaiting further guidance and/or a workaround.
Pleadings filed on paper
In CDBS, there was a "correspondence file" that included pleadings (petitions to deny, informal objections, petitions for reconsideration and responsive filings) filed about the facility. Once received at the FCC, they are scanned and loaded. LMS does not have a correspondence file. Electronically filed pleadings show as a pleading record which is supported by FCCdata and FCC.today. Paper pleadings on the other hand are loaded by staff to the application. There is not necessarily any kind of electronic notification in our systems of these filings. Those who need to follow a proceeding may need to periodically review the pending application to assure there are no pleadings filed.
On license to cover applications for LPFM, the form will accept an antenna with one section but will not accept a spacing of 0 (since there's only one antenna, no need to indicate spacing). Lowest value in LMS is 0.1 meters. For applications, REC is using 0.1 spacing on single bay antennas until the FCC ever resolves this issue.
Amendments to pending ungranted CDBS applications
REC has experienced difficulty making amendments to applications originally filed in CDBS prior to September 25, 2019 but have not yet been granted (i.e. they likely have an objection on them). Staff will need to handle these manually by manipulating the data on the existing CDBS application. This means that the update will not create a new application ID and it will also not show application history or change a status date to show when the application was amended.
Facility "active" records are not updating from CDBS when a change was made in LMS.
Each engineering application in CDBS and LMS has an "active" record indicator. This is used to denote whether the record is current and whether the facility needs to be protected in accordance with that record. Customarily, when a license to cover is granted, the previous license record and the underlying construction permit record are made "inactive" (or archive in CDBS-speak). For construction permits and licenses originally filed in CDBS, they are not being made "inactive" in CDBS when a license to cover or other modification is filed or granted in LMS. The status on the older records may change in LMS. This is more of an REC issue than a FCC issue. REC plans a fix to this by early January, 2020. REC has placed our fix however as noted in the 12/27/19 update below, there is also a problem in how CDBS originated applications are handled within LMS.
Updated 12/27/2019: We are finding that even in LMS, previously active CDBS records are not being made inactive/archive in LMS when another application is granted. This creates a situation where a facility location/channel is being improperly protected thus causing false negative results. This is a FCC issue. This will be reported to the FCC.
Please report any known bugs with LMS (for radio services) to REC. If you report directly to the FCC, please cc: a copy to firstname.lastname@example.org. Thank you.