Can a Part 73 CP holder qualify for a Part 74 RPU license?

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Re: Can a Part 73 CP holder qualify for a Part 74 RPU license?

Post by rbhines » Thu Apr 09, 2015 2:47 pm

TPT wrote:NO.
You must go through the prior coordination process for the STL (and RPU, theoretically, assuming you can find a coordinator).
Once that is complete (and assuming no objections) you may file for the STL license (and RPU license for that matter) before filing for the 302 to cover the broadcast station CP. This should be done during the period allowed for the Part 73 construction permit in order that the subsidiary services are licensed before one begins to operate under the automatic program test authority permitted under the rules.

As long as the underlying Part 73 construction permit remains active you can consider the term "licensee" interchangeable with "permittee."

Again, the rationale is that the (part 73) construction permit encompasses those (part 74) subsidiary services needed to make the station ready for operation. Once the license(s) for the Part 74 services are granted for the associated broadcast facility number identified in the construction permit, they remain valid after the 302 application is granted to "cover" the construction permit. They continue to remain valid until such time that the underlying broadcast license expires (e.g.--at the end of the normal license term) At that point, of course, the broadcast license can be renewed which automatically renews the part 74 licenses.

If for some reason the underlying broadcast station construction permit expires without the station being built, any part 74 licenses granted during the construction permit would also expire, as they are tied to the facility identified in the CP.

TPT--who doesn't play an attorney on TV, but who is one in real life.
Thanks, TPT. So much for my guess. :(

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