REC has filed comments in response to Bryan Broadcasting Corporation's Petition for Rulemaking to allow AM broadcast stations to voluntarily discontinue all AM analog broadcasting and convert to the HD Radio MA3 mode.  MA3 is an all-digital operation.  Two variants of MA3 will allow AM stations to operate in a 20 kHz wide channel where secondary and teritary sidebands more than 5 kHz from the center frequency are either reduced by 15 kHz or they are completely suppressed.  The MA3 mode is a far departure from the "hybrid" MA1 mode which involves the use of a 30 kHz wide channel.  In the past, the MA1 hybrid digital mode on AM, especially at night, has resulted in substantial first and second adjacent interference to analog AM stations forcing many stations to turn off the digital mode and leaving a bad taste in the mouths of AM listeners and radio enthusiasts across the nation.  MA3 mode uses a narrower channel and therefore reduces the chances of digital to analog interference.  

Today, the Federal Communications Commission Public Safety and Homeland Security Bureau released the Report of the 2018 National EAS Test.  Here are some of the bullet points from that test:

• This year's EAS test was different as it was tainted by political rhetoric surrounding the the fact that this was the first year that Wireless Emergency Alert (WEA) would be integrated into the national test and that the alert would appear on mobile devices as "Presidential Alert".
• Overall, radio had a 78.7% participation in this year's test.  This is a slight increase from 78.5% in 2017.
• LPFM's participation this year was 48.4%, this is a slight decrease from 48.5% in the previous test.  
• Of the 3,802 radio broadcasters that failed to file in the 2018 test, 1,121 (29%) of these stations were LPFMs.  
• LPTV (Low Power Television) had a massive slump in participation this year falling from 66.3% in 2017 to 41.5% in the most recent test.
• For the second year in a row, low power broadcasters (LPFM and LPTV) were called out for "[reducing] the overall participation rate of all broadcasters".
• Of the 962 LPFMs that did participate, 869 (90.3%) successfully received the alert and 789 (82.0%) successfully retransmitted the alert.  By comparison, in 2017, 92.5% of stations received the alert and 83.8% did rebroadcast it.

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.