License renewal season is well under way, Maryland and the Virginias already in progress. First issue that has come up--the pre filing notice. LPFM stations must run these notices, as well as all other commercial and non-coms. Simple to do--only one a day, twice a month, someone can just read it--note the time and you've satisfied the notice requirements. Same for the notice to be aired after the renewal is filed.
The copy for the notice and schedule is at 73.3580. Some things I've run into doing renewals on my stations and a couple of school stations:
1. Everything done through the LMS system--there is no longer a renewal form in CDBS. Each station is a separate renewal form.
2. When you first sign in (FRN + password--or your e-mail and personal password if you've already become a registered user from the last EAS test reporting)--you may be asked to "associate" or "disassociate" FRN's. The LMS database has a lot of outdated information. For one of my stations, the station was still "associated" with an old FRN of the former owner--we bought in 2009. Will also find old stations associated with your current FRN, e.g.--translators that may have been sold.
3. Unless you are dealing with an LPFM, you need to file the Form 396 in the LMS system. Both for commercial and non-com. For most small stations, under 5 employees, this is relatively painless. Write down the file number when you get done, you'll need it later.
4. When you get into the actual renewal form, besides the LMS file number of the Form 396, you should probably do an attachment to answer the question about posting an annual report on the website. If the station qualifies under the 4 and below employee rule, you did not have to post an annual report--so a short note about this would be prudent.
5. Biggest problem for most stations will be if they don't have a complete on-line public file. E.G--missing several quarters of "issues" reports, Best call DC counsel at this point. Same if the station has been off air for long periods over the last 8 years.
6. Translators. You will get to a section where you need to associate translators with the primary station. There are some separate questions for translators regarding being on-air, & aimed at whether the translator meets the requirements for a fill-in translator. These rules are different for commercial or non-commercial translators, so may need exhibits. Boosters do not show up--I've been told that boosters will automatically be renewed with the parent station.
7. Filing fees. $200 for the station renewal, $70 for translators. There is a glitch here when you go to pay--only the $200 ges carried over. The $70 fee needs to be paid separately in fee filer. Media bureau folks had to straighten this one out for me, station wasn't getting credit for paying. I am guessing--but in fee filer there is a question for "FCC code 2" which appears to be the LMS file number. This would look like "LMS 0000012345." I think.
So final tip: Print a copy of the form 159, and get a copy of the payment acknowledgment sent to you by e-mail--then save them. Will help getting proper credit for payments if something gets lost in the system.
Of course, you can run through and save the form before filing. That way, if you come up with questions, you can always call (or hire) your DC counsel & have an idea of possible problem areas.
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