Based on credible reports from Commission staff, REC can confirm that the FCC Media Bureau plans to require the use of the License Management System (LMS) for renewal filings in the upcoming cycle.  The first renewal filings for Maryland, D.C., Virginia and West Virginia must be filed on or just before June 1, 2019.  

LMS has been used primarily by television broadcasters for most of their application needs.  In television, assignments and transfers still go through CDBS.  In full-service radio, LMS has been used only for ownership reports.  LPFM stations are not required to file ownership reports.

The LMS form is called Form 2100.  Similar to the IRS 1040 tax form, Form 2100 uses "schedules" and other variations in order to handle specific needs of the application.  We have not yet seen the presentation of how the form will be laid out.  Since the existing renewal form (Form 303-S) is fairly simple and straightforward, we expect the LMS version of the form to be the same.

Overall, REC does support most of the text contained within the PIRATE Act.  Improperly operated broadcast transmitters can cause interference to public safety and safety of life communications especially in the aeronautical mobile and aeronautical radionavigation services and higher powered transmitters can pose a public health hazard.

On Thursday, February 14, the Federal Communications Commission has adopted a Notice of Proposed Rulemaking in MB Docket 19-3 which proposes changes to various non-controversial administrative rules, most of them would not apply until NCE full-service and LPFM has another filing window.  The proposed changes include:

Updated February 7, 2019:

The FCC will be considering the adoption of MB Docket 19-3 at the FCC Open Meeting, that has been rescheduled for February 14, 2019.  The meeting was rescheduled because of the potential of another government shutdown that cound take place as soon as Saturday, February 16.  On Friday, February 1, REC's Michelle Bradley met over the phone with FCC Audio Division chief Albert Shuldiner and other staff regarding concerns over a proposal in the draft NPRM that would, in the opinion of REC, further endorse and encourage gamesmanship by permitting collusion in the LPFM time-share negotiation process.  REC has proposed an alternate Viable Time Sharing plan that would add fairness to the process and reduce the chances of pre-planned outcomes.  REC has asked that the Media Bureau use their editorial privilege to refer to the ex parte presentation made by REC that details the plan.  

Once the NPRM is adopted by the full Commission and it is published in the Federal Register, the Commission will announce deadline dates for comments and reply comments.