Advisory Letters

Tenth advisory (3/18/2024)

On March 15, 2024, through public notice, the FCC Media Bureau identified LPFM applications that were mutually exclusive (MX) and assigned them to specific group numbers.  The Bureau also opened a 60 day period in which settlements can be made.  This settlement window will close on May 14, 2024.  According to the notice, the FCC will accept settlement agreements that are universal (involving all applicants) and agreed upon by all applicants.  These settlement agreements can include applicants requesting their applications withdrawn or modified through minor changes (such as moves of up to 11.2 km and/or channel changes of 1, 2, 3, 53 or 54 channels).  Compensation/consideration is permitted and is limited to legitimate and prudent expenses, which at this stage, would be mainly the fees paid to consultants in connection with application preparation and related technical studies.  All such agreements submitted to the Bureau must include:

  • A copy of the settlement agreement and any ancillary agreement(s);
  • A joint request for approval of such agreement; and
  • An affidavit of each party to the agreement setting forth:
    • The reasons why such agreement is in the public interest;
    • A statement that its application was not filed for the purpose of reaching or carrying out such agreement;
    • A certification that neither the applicant nor its principals has received any money or other consideration in excess of the legitimate and prudent expenses of the applicant;
    • The exact nature and amount of any consideration paid or promised;
    • An itemized accounting of the expenses for which it seeks reimbursementl; and
    • The terms of any oral agreement relating to the dismissal or withdrawal of its application.

For unilateral amendments such as site/channel changes or voluntary withdrawals where the other MX Group members are not involved, applicants must also include an affidavit as to whether or not consideration has been promised or received by such applicant in connection with their change or withdrawal.  

We do note that REC does have issues with some statements made in the March 15, 2024 public notice in respect to time share agreements.  This public notice stated that time share agreements will not be accepted at this time, even if those time share agreements are universal and no point aggregation is needed.  This is a complete departure from the 2013 policy and was not changed in 2019 with the adoption of MB Docket 19-3.  REC has escalated these issues to the Media Bureau. 

Keep in mind at this time, the FCC has not announced the number of points each applicant has.  Points will be announced in a future points public notice that will be specific to each MX Group (one notice will have mutliple, but not all groups in it).  At that time, partial settlement agreements involving point aggregation can take place.  

REC will keep LPFM applicants informed of any developments in our escalation and any resulting changes in an update to Advisory Letter #10 and through other REC channels.

Ninth advisory (2/2/2024)

On January 31, 2024 at 6PM ET, the FCC has started to accept amendments to LPFM filing window applications.  On February 1, 2024, the FCC released a public notice to give window applications additional guidance.  The FCC's official designation of MX Groups has not yet been published.  We are predicting that this will be released sometime in mid-February.  Just a reminder, until the FCC releases their MX list, the REC Filing Window Tracking System will use the REC Networks designated MX Group numbers.  These are NOT the official MX Group numbers that you should use with the FCC in any correspondence.  Once the MX list is released, REC will convert all of the MX Groups in the system to the official FCC numbers.  You will know if the group number is the official one as we will refer to it as the "FCC Group" number.

Amendments at this time are limited to minor changes.  This includes:

  • Facility moves of up to 11.2 km (or further if there is 60 dBu contour overlap between the originally filed location and the amended location).  Please note that any amendments will be based on the originally filed location. Therefore, for example, you cannot do two amendments in order to move a facility to 20 km away from its originally filed location.
  • Channel changes that are considered "minor".  Channel changes are limited to first, second, third adjacent channel or intermediate frequency channels.  This means you can change +/- 1, 2, 3, 53 or 54 channels, or in other words, +/- 0.2, 0.4, 0.6, 10.6 or 10.8 MHz.  Like with moves, channel changes will be based on what was originally filed and for example, you cannot file two amendments to change to to the fifth-adjacent channel.  Unlike in the rules for existing LPFM stations, you cannot use a showing of reduced interference to change to a "non-adjacent channel". 
  • Changes in the board members.  You cannot change organizations and any change in board members, especially if it is over 50% of what was originally filed must be for the same organization and does not give the appearance of a takeover.  
  • Other administrative changes, such as correcting spellings on names of organizations and people, telephone numbers, email addresses, etc., improvement of educational statements, adding of state documents when they were not included on the original application (as long as they clearly show that the organization was incorporated prior to the original filing date).
  • Changes in point factors only if you are reducing the number of points you wish to claim.

Things that cannot ever be amended:

  • Attempts to fix a §73.807 short spacing. 
  • Amending signatures from original applications if a officer/board member did not sign the original application.
  • Attempts to remove a board member who was previously engaged in unlicensed broadcasting in violation of §301 of the Communications Act.
  • Attempts to improve comparative standing.  This can include changing "no" point claims to "yes".  This also includes adding documentation to an existing "yes" certification to justify the point claim that was not added on at the time of the original application.  

The amended facility must meet all FCC rules regarding distance separation and localism.

Applicants in MX Groups cannot file settlement agreements at this time.  This can start after the the MX list is released.  We will update this advisory letter when that happens. 

It appears that the FCC is currently accepting unilateral engineering amendments in order for applicants to make minor changes to break out of an MX Group.  If you do make such an amendment, you must include an exhibit stating that this is a unilateral decision and disclose whether or not any consideration (payment, etc.) has been made to or from you in connection with that unilateral move.

Major moves and major channel changes cannot be done for applicants in MX Groups until the release of a points public notice for that MX Group.  The first such notices are expected later in 2024.

Eighth advisory (12/13/2023)

This revision is to reflect that the FCC has extended the filing deadline of the LPFM window to Friday, December 15, 2023 at 12 Noon ET.  We are also clarifying the section on major changes to reflect that if doing a major change, surrender of the previous LPFM license is the only option.  A previous version suggested that assignments can be done.

Seventh advisory (10/17/2023)

This revision to the advisory letter is to reflect a Public Notice released by the FCC Audio Division on October 17, 2023.  At the request of many stakeholders in the LPFM advocacy community, including REC Networks, the FCC has delayed the LPFM filing window dates until December 6 through December 13, 2023.  The filing freeze, discussed in Advisory Letter #19 will also be extended to December 13, 2023.  

In this update to the Advisory Letter, we have also applied strikeout text from previous revisions of this Advisory Letter which no longer apply.

Sixth advisory (8/8/2023)

This revision to the Advisory Letter is to outline a conversation that REC had with FCC Audio Division staff on August 7, 2023.

Clarification on required protections to pending applications

§73.807, subparagraphs (a)(1) and (c)(1) of the Rules stated that LPFM stations are only required to protect applications for existing FM, FM Translator and LPFM stations that were filed prior to the release of the Public Notice announcing the dates of an LPFM filing window.  On June 22, 2023, a Public Notice was released to announce the dates of the LPFM filing window, however that notice did not include any additional instructions.  On July 31, 2023, the Division released a subsequent public notice that announced the procedures for filing in the window.  In the July notice, the FCC included information on how LPFM applications must protect pending applications.  The method announced by the Division were not consistent with the existing rule.  This created some significant confusion.

Despite the wording of the existing rule, the FCC will require protections to be as follows:

  • In respect to full-service (full-power) FM facilities, LPFM window applicants must protect any applications  that were filed prior to July 31, 2023.  We note that while LPFM stations are not required to protect full-service applications filed on or after July 31, 2023, they may receive interference from those applications and there is no recourse for LPFM stations due to the secondary nature of the LPFM service.
  • In respect to FM translator and existing LPFM facilities, LPFM window applicants must protect any applications that were filed prior to September 1, 2023.  A filing freeze will start on September 1, 2023 that will prevent any modification applications being filed by any FM tranlator or LPFM station.  

 For the first time in LPFM, a filing freeze will be used to keep the spectrum "static" to assure that LPFM applicants will know exactly what the spectrum will look like when they file in the window.  We did not have those assurances under the current rule that was practiced in the 2000/2001 LPFM Window Series or the 2013 Window.  With the significant increase of the FM Translator service since the rule being written in 2000 had prompted the FCC to take this measure.  In the long run, the use of the filing freeze is a better option as it makes the overall outcome of an LPFM window application much more predictable. 

In this update to the Advisory Letter, we have also applied strikeout text from previous revisions of this Advisory Letter which no longer apply. 

Fifth advisory (7/31/2023)

On July 31 2023, the Federal Communications Commission had announced through Public Notice some additional policies related to the upcoming filing window for new LPFM stations.  This Advisory Letter also serves as an update regarding LPFM proposals for the 20 reserved band channels from 88.1~91.9 (Channels 201~220).

Reserved band applications

On July 20, 2023, the FCC issued a Report and Order in MB Docket 03-185 regarding TV Channel 6.  In that order, the FCC determined that the 13 low power TV (LPTV) stations that have been engaged in so-called FM6 operations (TV stations that generate an analog carrier for FM radio on 87.75 MHz) may continue to engage in that operation without the need for special temporary authority (STA).  Other than one Channel 6 station that was unable to file at the time the Notice of Proposed Rulemaking was adopted, the FCC will not authorize any additional LPTV stations to engage in FM6 operation.  This is good news for LPFM because with no expectation of the ability to operate FM6, it will not result in LPTV broadcasters changing to Channel 6 in order to engage in FM6 operation.  This will help assure that where there is LPFM availability in the reserved band will not experience a sudden loss as a result of speculation.  LPTV stations are still free to move to Channel 6 for all-digital TV operation.  

The FCC took no actions on the reserved band FM to Channel 6 protection rules (§73.825 for LPFM).  This means that there will be no change in the rules.  Keep in mind that at the request of REC, the FCC did change §73.825 rules and policies in 2020 to allow LPFM proposals in areas that are short-spaced to Channel 6 if they either obtain a letter of concurrence from the affected Channel 6 broadcast station (low or full power) or a contour study, consistent with the translator rule §74.1205 can demonstrate that there is no prohibited overlap.  In the latter case, the Channel 6 station must be notified of the application. 

New LPFM form available in LMS

For the upcoming window, applications will be filed in LMS.  To access the form, log into LMS with your organization's FRN and password.  On the Applications tab (the default tab that shows when you first log in), click on the blue "File an Application" drop down and then click on  "New Low Power FM Station Construction Permit Application".   Please note that as of this advisory, there is an issue on the form that involves applicants that do not qualify for the Established Local Presence point (organizations that have only been locally established since November 9, 2021 or later).  FCC Staff has been notified and has acknowledged the issue.  We are following this specific issue in LPFM Advisory Letter #18 and will update the status of this issue in that letter.

FCC Channel Finder

The FCC Channel Finder has been updated.  The new tool is redesigned from what we had in 2013.  Using the "Basic" option, the tool shows only the channels that may be available while the "Detailed" option shows all 100 channels and the stations that prevent the channel from being used.  While this tool can be used to determine available channels, REC warns about depending on the tool for channels that require a second-adjacent channel waiver.  Second-adjacent waivers require a technical study that shows a lack of interference.  The FCC has specific requirements for these studies.  Please use REC Networks or a consultant of your choice for applications requiring these waivers.

NOTE: Do not use the "Vacant Channels" search at to determine LPFM channels.  This tool is for consumer devices and does not follow the §73.807 rules.

Major Modification of Existing LPFM Stations

Normally, the FCC only allows existing LPFM stations to make the following minor modifications at any time:

  • Channel changes that involve a frequency change of +/- 0.2, 0.4, 0.6, 10.6 or 10.8 MHz; or upon a technical showing of reduced interference, to any channel.
  • A move of transmitter site of up to 11.2 kilometers, or longer if it can be demonstrated that there is 60 dBu service contour overlap between the current and proposed LPFM facility, or longer if the station is proposing to co-locate with a time share partner.

Any other change must be done as a major change.  For this upcoming window, the FCC will not accommodate major changes, per se.  Instead, LPFM stations needing to make a major change should apply for a new station at the new location/channel.  In that application, the certification questions and attached exhibits must clearly state that the applicant is already the licensee of an LPFM station and that prior to the LPFM station engaging in program test operations at the new location, they must divest their current LPFM station, through cancellation of the license.  These LPFM applicants will compete at the same level of new construction permit applicants (which is no different than if we had major changes in this window).   

As this type of modification requires a change in facility ID number, LPFM stations that were clients of REC will have their spend recognized with the change in facility ID number.  A new myLPFM account will have to be created for the new station.  REC client LPFM stations that are granted this "major like" modification should contact REC to assure that our relationship is linked to the new facility ID number.

Organizations with 2021 NCE Window pending applications or pleadings

An organization that has either a pending new station construction permit application from the 2021 NCE-FM Filing Window where no decision has been made or a dismissed NCE-FM application where a Petition for Reconsideration or Application for Review is still pending may still participate in the 2023 LPFM Filing Window.  

Organizations in this situation must include an exhibit that acknowledges the other application, lists the information about that application, such as file number and community of license.  

The divestiture statement must also include language that authorizes the Media Bureau to dismiss the pending NCE FM application in the event that the LPFM application is granted and if the NCE application is granted first, the applicant authorizes the Media Bureau to dismiss the LPFM application. 

In the "Legal Certificiations" section of the LMS application, make sure the yes/no answers are properly filled out. 

Snapshot Date for Establishing Points and Comparing Applications

The snapshot date for this window is November 8, 2023, December 13, 2023, December 15, 2023, the last day of the window.  For the Established Community Presence point, an applicant is qualified if their organization has been active within 20 miles from the transmitter site (10 miles for Markets 1~50) continiously from November 8, 2021 to November 8, 2023  December 13, 2021 to December 13, 2023 December 15, 2021 to December 15, 2023.  

Fourth advisory (6/24/2023)

On September 22, 2023, the Federal Communications Commission had announced through Public Notice that the filing window for new LPFM stations will be from 12:01AM EDT, November 1, December 6, 2023 through 6PM EDT, November 8, December 13, 2023.  Pursuant to §73.807 of the FCC Rules, authorized FM and FM translator stations, applications for new and existing FM and FM translator stations filed prior to the release of the this Public Notice, authorized LPFM stations, LPFM station applications that were timely-filed within a previous window, vacant FM allotments and foreign FM allotments must be protected.  (See sixth revision above for an update)

We do not expect any actions by the FCC to codify rules as a result of any activity in MB Docket 03-185 prior to the opening of the window.  As such, LPFM applications will be required to protect full-service TV, low-power TV and TV translator stations operating on RF Channel 6 pursuant to §73.825 of the Rules.  There were changes in the rules and policies regarding Channel 6 in 2019 which allows short-spaced LPFM applicants to seek concurrence from the affected Channel 6 station to waive the minimum distance separation requirements or a contour study, pursuant to §74.1205 (the FM translator Channel 6 rule) can be used to demonstrate a lack of intereference.  If the latter is used, the affected Channel 6 station(s) must be notified.  The Channel 6 rule only applies to LPFM stations proposing operation on Channels 201 through 220 (88.1 to 91.9 MHz). 

We do warn that while LPFM stations will not be required to protect any full-service FM applications filed on or after July 31, 2023, those applications will continue to be accepted and may result in interference if/when those facilities are authorized and constructed.  We are not sure yet whether the FCC will announce a filing freeze for FM translator applications prior to the opening of the window.  Full-service FM stations will be able to file prior to and during the window period.  

Applications will be filed in LMS.

Once we have more information, we will release an update to this Advisory Letter.  For more information about the LPFM service, please view the wide array of information available at the REC Networks website.  If you want to check for potential LPFM availability and to have REC handle an LPFM application, please visit  

Existing LPFM licensees can use this filing window for major changes to their facility.  A major change is one where the location of the station is moved more than 11.2 km away and there is no 60 dBu contour overlap between the current and proposed facility.  It is also used for a channel change of more than 1, 2, 3, 53 or 54 channels (0.2, 0.4, 0.6, 10.6 or 10.8 MHz) and a showing of reduced interference cannot be made.  Major change applications will be treated the same as applications for new stations and will compete in the point system in the event of mutual exclusivity.  If the major change applicant is unsuccessful in the filing window, their already-authorized facility will remain. 

Third advisory (9/12/2022)

On September 12, 2022, REC Networks had announced that they will start accepting show of interest requests from organizations wishing to participate in the next LPFM filing window.  Even though the FCC has announced previously that following the NCE window there would likely be an LPFM filing window, the FCC has not announced any dates.  We continue to anticiapte a 2023 filing window for LPFM.  Those who are interested in having REC assist them in the next LPFM filing window should visit our Show of Interest website:  More information, including terms and conditions of REC service offerings are available at that website. 

Second advisory (8/18/2022)

REC Networks has been fielding a considerable number of inquiries regarding the next filing window for new LPFM stations.  This updated Advisory Letter will address the current status of the next LPFM window.  As previously mentioned, the FCC did state in the past, the LPFM window is expected to follow when processing of the 2021 Noncommercial Educational (NCE) filing window has calmed down.  The FCC Audio Division staff is very limited and in addition to LPFM, they also work on all other radio broadcast services (AM, full-power FM, FM translators and FM boosters).  Since the close of the NCE window in November 2021, they have performed four Threshold Fair Distribution Analyses to resolve 63 groups (including sub-groups) of mutually exclusive (MX) applications.  They also made two decisions based on Tribal Priority. The FCC also settled 5 disputed MX groups determined in the Fair Distribution Process.  These decisions are handled entirely by the Media Bureau and do not require full Commission involvement.  

For MX groups where Fair Distribution Analysis is not used, the FCC uses the point system.  The comparison of the applications using the point system is considered a "hearing" under FCC rules so therefore, the Media Bureau must prepare all of the information and then it must be circulated to the four FCC Commissioners for an up-vote.  Point hearings are a little more complex as additional research is needed to verify that all documents are in order and that claims of population and land area are correct.  They are also more vulnerable to objections.  So far, the FCC has already conducted one point system hearing consisting of 27 MX groups.  After the 2007 NCE Filing Window, the point hearing decisions normally came out about one to two months apart from each other and the number of MX groups evalulated varied between 24 and 59.

Currently, there remains 5 MX Groups that may be eligible for Fair Distribution, one of which is Tribal Priority and 65 MX groups (including sub groups) that will require a point hearing.  Our general take on this is that it is very likely, especially given holidays and other Audio Division priorities, which competes for staff time, we will likely see two more point hearings this year.  Depending on how many groups they want to take on in these hearings, two hearings may be able to sweep up the remaining pending groups.  However, it may be possible that an additional hearing may be needed in early 2023.  

It is also important to note that at this time, we are still awaiting an outcome on MB Docket 03-185, also known as the "Franken-FM" proceeding.  A part of that proceeding deals with the protection that FM facilities (full-power, LPFM and FM translator stations) must provide to TV Channel 6 stations now that the entire country, including low power TV stations have transitioned to digital.  REC Networks and National Public Radio are both supporting an elimination of these protections on Channels 203~220 (88.5~91.9) but retaining them on Channels 201 and 202 (88.1 & 88.3) due to the adjacent channel relationship with the Channel 6 spectrum from 82~88 MHz.  If the FCC does provide this relief that we are asking for, this will open some additional opportunities for new LPFM stations in certain parts of the country where full-service and low-power TV channel 6 stations currently operate.  Over the next couple of months, REC plans to engage in ex parte communications with Media Bureau and Commissioner staff in regards to this and to express our concern about the timing of this rule change on the timing of the next LPFM window.  Because of the larger benefit that opening a new LPFM window will provide, we do not want to see 03-185 delay the LPFM window.

At this time, can definitely rule out an LPFM window in 2022.  In order to assure that as much work is completed on the NCE window, including resolving objections to tentative selectees in point hearing groups, we are still pushing for an LPFM window in the early second quarter of 2023, with a first notice hopefully coming out in the first quarter.  

Again, other unexpected activities, such as an FM allotment auction, may get in the way.  The FCC was going to hold Auction 106 for FM allotments and revoked AM construction permits on April 28, 2020, but that auction was postponed due to COVID and performed as Auction 109 on July 27, 2021.  The previous Audio Division service auctions were Auctions 99 and 100 for AM Revitalization FM translators in 2018 and 2019 respectively, and the last full-power FM auction, Auction 98, was held in 2015.  Since the last FM auction was held only a year ago, it is unlikely that another one would get in the way between now and an LFPM window, but we must always prepare for it.

In the fourth quarter of 2022, REC Networks will be undergoing IT work to support a future LPFM filing window through the redevelopment of availability checks and other supporting systems.  It is our hope that by December, 2022, we will have a "show of interest" system set up where users can check for potential yes/no availability and then make a show of interest to REC Networks to have us handle the application at the time that it is done.

REC does advise all prospective LPFM licensees to assure that your organization is already registered with the Secretary of State in any state as a nonprofit corporation and to insure that all annual reports and any annual fees that the state may require are paid up.  The FCC will not license an organization that is dissolved, lapsed or delinquent.  In most cases, the state will reinstate inactive corporations retroactive to when they went delinquent.  The FCC will not license LPFM stations to individuals, partnerships, for-profit LLCs or for-profit corporations.  For unincorporated associations that can clearly demonstrate that their association was active at the time of the window may apply, but it is a complex process that, in addition to REC services, also requires the intervention of an attorney licensed to practice in your state in order to testify to the specific unincorporated assocation laws in your state.

Once again, it is our hope that the LPFM window will take place in the second quarter of 2023, but it may happen sooner or later.  Following the LPFM window, REC will be pushing for a filing window for new FM Translators in the reserved band (88.1~91.9 MHz).  There has not been a window for these stations in over 20 years.  It is also likely the FCC may also hold a translator window for noncommercial and commercial applicants in the non-reserved band (92.1~107.9 MHz).  REC is currently developing a plan to assure integrity in the licensing system by preventing speculation by applicants in the trafficking of construction permits like what took place following the 2003 "Great Translator Invasion" filing window. 

Once more information is available on the next LPFM window, we will issue a third revision to Advisory Letter #10.  We advise all parties interested in participating in the  next LPFM window to stay tuned to REC Networks at as well as on our Facebook page  

First advisory (5/29/2021)

In this Advisory Letter, we provide notice that the Federal Communications Commission is definitely planning to schedule a filing window for new LPFM construction permits and major changes to current facilities.  This comes as a result of statements made in an Order on Reconsideration, which as of May 27, 2021 was on a circulation draft and therefore will be voted on by the full Commission on or just before their next scheduled open meeting on June 17, 2021.  We note that this document deals with two reconsideration petitions filed in MB Docket 19-193, but as the Commission had noted in the document and Acting Chairperson Janet Rosenworcel had mentioned elsewhere, the resolution of these two Petitions for Reconsideration will pave the way to the next LPFM window.

The next LPFM window will take place sometime after the FCC holds the full-service noncommercial educational FM filing window, scheduled for November, 2021.  More information about that window can be found in REC Advisory Letter #2.  We currently do not have a date for that filing window.  We will announce that in a subsequent Advisory Letter.

Upcoming filing freeze affecting secondary facilities

Prior to the opening of the LPFM filing window, the FCC may declare a spectrum freeze to assure that the spectrum remains static so new and major modified stations could be planned.  Normally, this will mean that during the freeze that no applications to modify existing LPFM stations nor FM translators will be accepted.  Applications such as license to cover a previously granted construction permit as well as administrative applications involving no modification of the physical facility will also be accepted.  Existing LPFM stations should plan their modifications prior to this freeze (which is normally 30 or more days prior to the open of the window).  The freeze will be lifted the day after the filing window closes.  Primary (full-power) FM stations would not normally be subject to a freeze for LPFM activity and will be allowed to file during the freeze and the window, however, stations that do so will not be protected from LPFM applications filed during the window.

More information about the filing freeze that will run from September 1~November 8, 2023 December 13, 2023 December 18, 2023 can be found in REC Advisory Letter #19.

What can be filed prior to and during a filing freeze and during the window

FCC rules currently define a minor change as a move that is less than 11.2 kilometers or upon a contour study a move beyond 11.2 km when a contour study shows that the 60 dBu service contour of the current LPFM facility overlaps the 60 dBu contour of the proposed facility.  As mentioned above, the FCC is not specifically accepting major modifications in this window.  Instead, applicants should file for a new LPFM station and include documentation that acknowledges the current LPFM station and pledges to divest that LFPM station prior to being allowed to turn on the transmitter at the new location.  A minor change is also defined as a change in channel where the proposed channel is 1, 2, 3, 53 or 54 channels separated (+/- 0.2, 0.4, 0.6, 10.6 or 10.8 MHz). A minor change can be done to any channel if a contour study can demonstrate that the arriving interfering contours on the proposed channel are weaker than those on the current channel (thus a reduction in interference).  Any modified facility must continue to meet the distance separation requirements outlined in §73.807 of the rules and any station proposed for 88.1~91.9 must also meet §73.825 requirements to Channel 6 low power and full power TV stations.

During the filing window, an LPFM station may file for a move of over 11.2 km (where there is no overlap), even if that move is hundreds of miles away.  During the filing window, an LPFM station may request a “non-adjacent” (not 1, 2, 3, 53 or 54) channel without the need for a technical showing of reduced interference.  Again, all §73.807 and §73.825 distance separation requirements must be met.  No minor changes may be filed however license applications to cover granted construction permits and administrative applications not involving the modification of the physical facility may be filed.

Major change applications are subject to competing applications and the point system.

Major change applications will be filed like new stations but with a divestiture pledge.  See above.

If an LPFM station is modified as a major change during the filing window and there are conflicting applications (such as new construction permits) filed where the multiple applications can’t be simultaneously granted, the facility (either a major change to an existing LPFM or an original construction permit application by a new applicant) will be considered mutually exclusive and will follow the FCC’s selection process outlined in §73.872 of the rules which includes the use of the point system.  If a major change application ends up not being the tentative selectee, then the existing LPFM license will remain in force. If granted, the existing LPFM station will remain authorized to broadcast until program testing begins on the new station.  LPFM stations are unable to simultaneously both the current station and the recently authorized changed facility.

Existing LPFM stations making major moves in the LPFM filing window must continue to meet the localism requirements, which for educational LPFMs would be either the headquarters or a campus within 20 miles of the transmitting antenna (10 miles in markets 1~50 or at least 75% of the organization’s board members reside within 20 miles of the transmitting antenna (10 miles in markets 1~50).

The LPFM point system

LPFM applications, including major change applications filed during the filing window will be subject to the Commission's point system for mutually exclusive applications.  Points are given based on the following:

  • Local presence (1 point) – applicant has been established for at least two years prior to filing and either the organization or 75% of the board members are located within 20 miles of the proposed antenna site (10 miles for major media markets 1 through 50).
  • Main studio pledge (1 point) – applicant pledges that if the permit is won on points, they will maintain a publicly accessible main studio that is open at least 20 hours per week.
  • Local programming pledge (1 point) – applicant pledges that if the permit is won on points, they will carry at least 8 hours per day of programming that originated from within 20 miles of the transmitting antenna (10 miles for major media markets 1 through 50).
  • Bonus point (1 point) – A bonus point is given for applicants who can make both the main studio and local programming pledges.
  • Diversity in ownership (1 point) – a point can be claimed if the LPFM station is the applicant’s only media holding.  A major change LPFM applicant will be able to claim this point because even though the applicant already has a media holding already (the LPFM station), that station will be moved and they will not be able to operate both facilities simultaneously.
  • Tribal priority (1 point) – a point can be claimed if the applicant is a tribal enterprise and that the proposed station is located on tribal land.

Major change applicants will be permitted to aggregate points with new entrant applicants to allow for voluntary time sharing and if a major change applicant prevails in a FCC review of the points (such as when no agreement can be made), the LPFM would be subject to the main studio and local programming pledges (if they claimed those points) and may be prohibited from assigning their license to another organization for a period of 4 years following the grant of the license covering the construction permit.  Major change applicants may be subject to involuntary time sharing, where if a voluntary agreement is not reached in the future, could result in a non-renewable license.

REC's services, system support and handling of the LPFM filing window

Revised 6/24/2023

REC Networks is currently accepting intake for prospective LPFM broadcasters. 

Representatives of qualifying nonprofit educational organizations and institutions can visit to read about the service, check for availability and submit a show of interest for REC to handle their application.  

Representatives of public sector entities such as public safety agencies, public colleges and universities and Tribal entities should contact REC Networks at 202 621-2355 for assistance. 

Additional information for new entrants

REC reminds new entrants who wish to file in the LPFM filing window, that prior to filing, their organization must be registered with a state Corporation Commission or similar government entity as a non-profit corporation.  The FCC will not license LPFM stations to individuals, partnerships, for-profit private corporations, for-profit stock corporations, LLCs or any other for-profit entity type.  The organization must be an existing educational organization with an educational purpose and construction permits will only be granted to organizations that can make a satisfactory showing that the proposed radio station will advance the organization’s educational program.  The organization is not required to be a §501(c) non-profit charity. 

For new entrants, please note that this REC Advisory Letter series mainly addresses updated information of interest to existing LPFM stations and does not normally address issues directly affecting new entrant applicants.  Information for new LPFM applicants can be found on the REC website at this URL:

Document History

  • First advisory: May 29, 2021
  • Second advisory: August 18, 2022
  • Third advisory: September 12, 2022.
  • Fourth advisory: June 24, 2023
  • Fifth advisory: July 31, 2023
  • Sixth advisory: August 8, 2023
  • Seventh advisory: October 17, 2023
  • Eigth advisory: December 13, 2023
  • Ninth advisory: February 2, 2024
  • Tenth advisory: March 18, 2024

The following information is from the Society of Broadcast Engineers (SBE).  REC's additional comments are in bold.

On Aug. 1, 2022, The Federal Emergency Management Agency (FEMA) released an IPAWS advisory noting a vulnerability in the Emergency Alert System (EAS). EAS encoder/decoders that have not been updated to the most recent software versions, could allow unauthorized access to issue EAS alerts. 

The vulnerability is public knowledge and will be demonstrated to a large public audience in the coming weeks at a trade convention.

FEMA strongly encourages EAS participants to ensure that:
1. EAS devices and supporting systems are up to date with the most recent software versions and security patches;
2. EAS devices are protected by a firewall;
3. EAS devices and supporting systems are monitored and audit logs are regularly reviewed looking for unauthorized access.

CNN reports that the issue is specific to Monroe DASDEC units. The Indiana Association of Broadcasters (IAB) has confirmed this with FEMA and the NAB.

The IAB notes that this vulnerability is not new. It was first reported in 2013 during the so-called zombie attacks, however, it appears that the security patch provided by Monroe at the time did not completely resolve the problem. Several software updates have been issued since then, and stations that have updated to version 4.0 or higher are secure. However, any device that has not been updated to version 4.0 or 5.X remains vulnerable. The cybersecurity researcher referenced in the CNN article was apparently able to identify a number of EAS devices that could be hacked. He is apparently planning to share his finding at a public conference on Aug. 11-14.

REC is aware that some LPFM stations may be operating a DASDEC EAS with version 3.x.  It is very important that you consider making the upgrade to version 4.x.  This is not a sales pitch.  This is a serious issue.  We are not aware if Monroe will be making an emergency patch for 3.x users, so the most prudent thing for LPFM stations that are on DASDEC II version 3.x or earlier is to upgrade to version 4.x if their equipment is compatible (DASDECs of earlier than 2014 vintage may have a hardware incompatibility).   

For more information on the software upgrade for DASDEC units only, visit:

Regardless of which EAS your station has, you should take the time to determine your current software version and contact your EAS manufacturer to determine if you have the most current version of  your software.   Also, please follow the recommendations above to assure that your EAS is safe from cyberattacks.

EAS manufacturer websites:

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Original version: August 5, 2022
Updated March 10, 2024 to reflect version 5.x from DASDEC.  All stations should be on a 5.X version in order to comply with the new CAP Polling requirements.

Revision #7 - issued February 6, 2024 11:50 AM ET.

Seventh update - February 6, 2024: Availability of Sage Rev96 update

Sage has officially announced the release of the Rev96 update for the Sage ENDEC 3644.  This update is free for those who have purchased an ENDEC new from dealer stock on or after December 12, 2021 (serial numbers B418750~B429999).  The upgrade cost for all others is $159.  Units must already be equipped with Rev95 in order to be upgradable to Rev96. 

ENDEC users that have already paid for the upgrade or have a box in the serial number range shown above can get instructions and the firmware download at:

ENDEC users who have not yet purchased the upgrade will need to purchase it from a Sage authorized distributor:

The Rev96 firmware must be installed by March 11, 2024 in order to remain compliant with the FCC Rules.

Sixth update - December 13, 2023: Extension of deadline for Sage users only

The compliance deadline for the 2023 required revisions has passed. However, on November 28, 2023, at the joint request of REC and the National Association of Broadcasters, the FCC has extended the compliance deadline for Sage users to March 11, 2024.

Fifth update - November 8, 2023: Delay in Sage Rev96 update

REC Networks has received word that Sage expects the release of the Rev96 firmware update to take place in "early December".  REC is continuing to work on this issue and will provide additional updates as they come in.  Please stay tuned to this Advisory Letter and to our Facebook page for updates.

Fourth update - November 7, 2023: Delay in Sage Rev96 update

On November 6, 2023, Sage Alerting Systems released the following update on the Rev96 firmware release:

We continue to work on the Rev96 update. We have made the FCC aware that the update has taken us longer to produce than we had anticipated, and that there will be insufficient time for many of our users to install the update by the December 12, 2023 deadline. This is especially true for users that have a large number of ENDECs, and for users that have contract engineers with many clients to update. We apologize for the delay. We will update this page and keep the FCC informed on the release status as we get closer to a release date.

When Rev96 is released, Email will be sent to those who are signed up for our support email list. If you are not on that list, you can sign up on the support page

Both REC Networks and the National Association of Broadcasters are jointly monitoring the situation and will jointly decide on a course of action based on when the update is released.  

REC does remind LPFM stations that even without any specific action taken by the FCC on this matter, §11.35(b) of the FCC Rules permits stations to operate out of compliance for up to 60 days.  This means that even after the revision is released, stations can remain out of compliance until February 10, which is 60 days from current compliance deadline.  

At this time, we ask stations for their patience.  There is no need to contact either Sage or the FCC on this issue at this time.  

A fifth update to this Advisory Letter will be issued once we have more information on this matter.


On September 29, 2022, the FCC adopted a Report and Order in PS Docket 15-94 to improve the accessibility of the Emergency Alert System (EAS) for persons with disabilities.  Specifically, the FCC mandated that "CAP Polling" be implemented by all radio and television users one year after the new rules are go into effect.    On November 10, 2022, the FCC announced that the new rules have been published in the Federal Register and that radio and television stations must be compliant by December 12, 2023.

The issue

There are currently two types of emergency alerts, legacy and CAP.  Legacy alerts are delivered over the air.  These are the alerts that include the data bursts that listeners will hear.  Encoded in that data includes information such as the date and time of the alert, date and time of the expiration of the alert, the originator of the alert, the type of alert that it is and the areas that are affected by the alert (FIPS codes).  Common Alerting Protocol (CAP) alerts are delivered to stations through the internet and are encoded in XML and carry much more robust information about the alert and also have the ability to carry "attachments" such as recorded audio and graphic images.  

Those with hearing impariments that watch television may currently see a crawl message on the TV screen that includes the emergency information.  On CAP alerts, since the data is robust, it will include the very detailed information about the alert, while in the case of legacy alerts, this information is very generic in nature (e.g. At 7:20PM, A Civil Authority has issued a Tornado Warning for the following areas: Wicomico County MD, Dorchester County MD.  Expires at 7:50PM.)   As a result, those with disabilities may not receive the full message, especally if the TV station is not carrying news coverage of the event and using live captioning.  

The FCC determined that because of the limitations of the legacy alerts, EAS participants must favor CAP alerts over legacy alerts if the alert is received over both sources. 

Not all alerts come over CAP

In most areas, alerts coming over CAP are limited to those released by state and local authorities.  These may include AMBER Alerts, Blue Alerts, local evacuation orders and other similar incidents.  Most notibly, alerts originating from the National Weather Service (where a majority of legacy alerts originate from) are not delivered by CAP EAS, even though weather alerts are still delivered through the Integrated Public Alert and Warning System Open Platform for Emergency Networks (IPAWS-OPEN), but through the "non-EAS" channel.  

During the rulemaking proceeding, recognizing that there may be many radio stations, especially LPFM, small NCE and small commercial stations that may have not upgraded their EAS units to a version that is compliant with the CAP Polling method that was being proposed as well as due to the lack of benefit the change would provide to radio (as the benefits were visual as opposed to aural) and due to the fact that most alerts come from the NWS, which is not on CAP; REC asked for a three year deadline for radio and a one year deadline for television.  The FCC denied our motion and upheld their one year deadline for both radio and television stations.  

What is CAP Polling?

When CAP Polling is activated on an EAS decoder, the system, upon receiving a legacy alert over the air, will wait for up to 10 seconds for a similar alert to arrive by IPAWS-OPEN (known commonly as a "CAP alert").  If a CAP alert is received within that 10 second period, the EAS will forward the CAP alert instead of the original legacy message.  If no CAP alert is received within 10 seconds of the legacy alert, the legacy alert is forwarded.  

Overall, using CAP has its benefits as it would permit for a clearer audio message to be sent over the air either through an attached audio file that comes with the CAP alert or through the use of the EAS decoder's text to speech functionality.   Until the National Weather Service switches to IPAWS-OPEN for EAS alerts, radio stations will continue to receive the inferior quality messages using the NWS text to speech system received from the agency's VHF radio system.  

How EAS decoders can become compliant.

REC has reached out to the four major manufacturers of EAS decoders to determine their plans to make their client's decoders compliant:

Digital Alert Systems / DASDEC

DASDEC users on Version 4 or 5 software already have this capability.  Those who are still on version 3 must upgrade their decoder to at least version 4 in order to be compliant.  While DASDEC has recently released Version 5 of the software, an upgrade to 5 is not required at this time but is recommended sometime in the future to assure that your unit has the latest features and is more "future proof".  The upgrade from Version 3 to Version 4 will run approximately $500.  

DASDEC users on Version 4 or 5 must turn on the CAP Polling functionality.  This is a very easy process:

  • Log into your DASDEC.
  • Click on the "Setup" section.
  • Click the Alert Agent radio button.
  • Click the Alert Policies tab.
  • On this page, look for the "Triggered CAP Polling - Global Settings" section and check the box "Triggered CAP Polling".
  • Under the checkbox, enter the value 10 for Global Window. 
  • The unit is now compliant for December 12, 2023.

Sage Alerting Systems / ENDEC

Sage has announced that in order to meet with compliance, they will be releasing a new Rev96 firmware (current version is Rev95).  This version will only be compatible with the Sage model 3644.  This will be a paid upgrade for $159.  Sage units originally purchased from dealer stock after December 12, 2021 (serial numbers B418750~B429999) will be eligible for a free Rev96 update.   Sage users have until March 11, 2024 to come into compliance.

More information from Sage

List of Sage distributors to get the Rev96 update

Trilithic-Viavi Solutions  / EasyCAP

Viavi has informed REC that they are planning a new firmware release in Spring 2023.  For Trilithic's licensed users, this will be a free upgrade.


REC has reached out to Gorman-Redlich and are still awaiting a response.  When we receive a response, we will update this Advisory Letter.

Why do we need to do this?

Simple, it's because the regulations require it.  Stations not in compliance may be subject to Notices of Violation that will need to be reported come license renewal time and may be subject to forfeitures.  EAS is one of the highest priority of obligations that LPFM stations must adhere to and the FCC does take EAS very seriously. Even though the current alerting environment provides not much benefit to radio stations for implementing this change, it is a required change and it is in LPFM's best interest to assure that 100% of stations are complying with the EAS regulations. 

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The first version of this Advisory Letter was released on November 15, 2022 at 9:00 AM ET.
The first revision of this Advisory Letter was released on November 15, 2022 at 11:00 AM ET to reflect information received from Sage Alerting Systems.
The second revision of this Advisory Letter was released on November 21, 2022 at 8:20AM ET to reflect Trilithic's response to our inquiry regarding any charge for the upgrade.
The third revision of this Advisory Letter was released on February 10, 2023 at 1:45PM ET to reflect the official information received from Sage Alerting Systems regarding the Rev96 update.
The fourth revision of this Advisory Letter was released on November 7, 2023 at 5:40PM ET to reflect the acknowledgement by Sage of the delay in the Rev96 release.
The fifth revision of this Advisory Letter was released on November 8, 2023 at 12:15 PM ET to reflect an update on the expected delivery the Sage Rev96 release.
The sixth revision of this Advisory Letter was released on December 13, 2023 at 11:25 AM ET to advise of the extension of the compliance date for Sage users.
The seventh revision of this Advisory Letter was released on February 6, 2023 at 11:50 AM ET to advise of the Sage Rev96 release and provide information on how to obtain it.


LPFM applicants located within 16 kilometers (10 miles) of a large body of water, such as the Atlantic or Pacific Ocean should be aware that the effective radiated power (ERP) that is automatically assigned by the FCC's Licensing Management System (LMS) may be significantly lower than what the application may be entitled to. 

For most applications filed in LMS for LPFM services, the FCC uses the National Elevation Dataset 1 arc second (NED1) terrain data.  In Alaska, a similar dataset is used at 3 arc seconds (NED3).  

HAAT is calculated by taking the elevations from 50 points along a specific heading/radial between 2 and 10 miles (3~16 km) and then averaging them and comparing them to the radiation center elevation at the transmitter site.  This process is repeated seven more times at equally spaced radials by 45 degrees (e.g. 0, 45, 90, 135, etc.).  The result of each of those 8 radials is then averaged and that average is the HAAT. 

REC has noticed that when calculating the HAAT using the NED1 dataset at locations near the ocean, that extremely high HAATs along certain radials towards the ocean will be registered among certain radials resulting in an overall HAAT that is much higher than expected.  This issue is pronounced most for LPFM proposals in Hawaii.   This issue also impacts the shape of contour maps provided by REC Networks tools such as and other services that use the FCC's Contours API.

REC has researched the issue and we have concluded that the issue is related to oceanic topography.  

Other FCC terrain data sources such as the original FCC30 and the GLOBE terrain data sets will consider oceanic areas as an elevation of zero.  However, the NED1 dataset will consider the actual depth of the ocean floor at a particular point and consider it a negative elevation below sea level.  We have discovered when HAAT is measured along a particular radial that exhibits these very high HAAT calculations, if the distance along the radial is reduced (for example from between 2 and 10 miles to 2 and 6 miles), the HAAT will be greatly lowered and thus resulting in a higher HAAT.   Because of the topograhy off the coast of Hawaii where there are significant cliffs in the ocean floor, the issue is most pronounced there. 

FCC Audio Division staff has been notified of REC's theory on this matter and they state that they will do their own measurements and not depend on the LMS default HAAT.  

To obtain the proper HAAT for a location, tools need to be able to support the FCC30 and/or GLOBE data sets.  This includes the FCC's HAAT Calculator website, V-Soft and ComStudy 2.  Applicants using one of those methods should include an exhibit that includes either a screen shot of the calculator website or data from a third party tool to demonstrate the correct HAAT and thus, ERP.  The REC HAAT Calculator supports NED1, NED3 and GLOBE terrain data but does not support FCC30. 

Locations that are within 10 miles of the ocean and do not have any other terrain past 10 miles but within the 34 dBu interfering contour along the radial in question can reduce the area determined by limting the average elevation along the radial to only the land area from 2 miles from the transmitter site to the shoreline.  In cases where the shoreline is less than 2 miles away, the entire radial can be removed completely from consideration and the average will be calculated based only on the remaining radials. For more information on how to use this method, see §73.313(d)(2) of the FCC Rules.  

Applicants handled by REC Networks full service who are in these areas will be provided with HAAT calculations that apply the §73.313(d)(2) rules if using the rule will result in a higher ERP.

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This LPFM Advisory Letter was originally published on December 13, 2023.

LPFM Advisory Letter #9 (Fourth Update, 08/03/2023) – EAS National Periodic Test

Original version – 05/05/2021 / Updated 06/11/2021 / Second update 07/07/2021 / Third update 06/08/2022 / Fourth update 08/03/2023

The Federal Emergency Management Agency (FEMA) has announced that there will be a National Periodic Test (NPT) of the Emergency Alert System (EAS) in 2023.

The test is scheduled for October 4, 2023 at 2:20 PM EDT.  The backup date is October 11, 2023 at 2:20 PM EDT.  The backup date is only used if there is a major event or any other reason why the October 4 date can’t be used.

Created December 22, 2022

The FCC is currently considering rule changes that would require all EAS participants from iHeart to LPFM stations to have a detailed Cyber-Security Risk Management Plan framework for their station.  For big corporations and government agencies, these types of plans can be dozens of pages long.  REC is currently fighting imposing such a massive requirement on LPFM and other smaller broadcast stations.  Instead, we are calling on the EAS industry to fix their equipment at their own expense by providing additional security features such as two factor authentication and to only require LPFM and smaller stations to utilize a pre-defined simplistic standard of good network security in lieu of creating, maintaining and updating a complex enterprise-based framework plan that is more suited for institutional users such as universities, iHeart, Verizon and Comcast.  

Following a Practice of Good Network Security assures that the assets of an LPFM or other Small Station are properly protected from cyber-attacks and other illicit activity, especially where it comes to the protection of the Emergency Alert System (EAS) decoder/encoder, which if compromised, can result in the initiation of a false alert that can create local panic, alert fatigue and require the station to initiate FCC processes in order to report the false alert.

In addition to making sure that you are running a current version of the EAS software/firmware, REC makes the following recommendations to assure that a station's EAS decoder is best secured on their network to prevent false alerts:

Never use static IP addresses.  A static IP address is an IP address that is specific to the device (such as the EAS decoder).  Static IP addresses are assigned by the internet service provider (ISP) and are normally used only in institutional environments (such as universities or large corporations) or as a feature of a business grade internet service plan.  Even an EAS on a static IP address using a port number other than the standard port numbers 80 and 443 are exposed and are vulnerable.  If a static IP must be used, consider the installation of a router and placing both the EAS and a regular PC on that router.  Have the router set to port forward to the regular PC and have that regular PC running some kind of remote desktop software (VNC can be used but is not as secure as other solutions that may be available).  The user would log into the remote desktop (using a password) and then once there, they can use a web browser to access the EAS decoder's logon screen. 

Avoid using port forwarding directly to an EAS decoder.  Most Small Stations that use regular home or small business class internet service from their ISP will normally use a dynamic IP address.  This IP address is assigned by the ISP from a pool of IP addresses and depending on the provider, can change at any time.  Users from outside would access the router through either the dynamic IP address assigned by the ISP or using a dynamic DNS service which monitors the station's IP address and permits access through using a fully qualified domain name (FQDN).  Using port forwarding in the router, the station can set up a routing based on a "port number" used after the dynamic IP or FQDN to route to the EAS decoder. Even though this method may not make the EAS decoder easily accessed, the EAS decoder remains visible using the specific port number assigned in the router.  Instead of setting up port forwarding directly to an EAS decoder, have the router set to port forward to the regular PC and have that regular PC running some kind of remote desktop software (VNC can be used but is not as secure as other solutions that may be available).  The user would log into the remote desktop (using a password) and then once there, they can use a web browser to access the EAS decoder's logon screen. 

Limit who can access the EAS decoder (DASDEC).  An administrator level password should only be provided to those who have a direct business need to make configuration changes to their EAS decoder.  The DASDEC does provide the ability to add additional user accounts at varying levels of access based on the user's specific business need, including a "view only" level, which cannot originate alerts.  The "view only" level can be given to station staff that may need access to view past alerts or to get EAS log information, especially in the case of an inspection. 

Limit who can access the EAS decoder (Sage).  The Sage has a user level password and an administrator level password.  The user level password permits the origination of alerts so it is recommended that only those who have a true business need to configure or operate the EAS decoder should have access to this password.  Unlike the DASDEC, there is no "view only" level of access in the Sage.

Use third party sources for newsgathering and to elaborate on previous alerts.  If the station receives and forwards an EAS alert on the air and the local air talent wishes to talk more about it on the air, instead of accessing the EAS, they should use a third party source.  REC clients with a minimum spend have access to such a screen through our myLPFM portal that permits air talent to visit a web page without a password requirement to show details of unexpired EAS alerts as well as other National Weather Service bulletins that did not trigger an EAS alert.  Unexpired alert (EAS and non-EAS) details are also available at

Periodically change passwords (Sage).  While this is not as much of an issue with the DASDEC, which can provide access at a specific user level which does not have to be shared between multiple people, this is a major vulnerability for the Sage as it only has a single user and administrative password that must be shared among all users who have a need to know.  Periodic changing of this password at either certain intervals or when someone leaves the station is very prudent to assuring the EAS remains secure. 

Disable the front panel demo alerting function (DASDEC).  The DASDEC offers a method where a demonstration alert can be sent over the air by the pushing of a front panel button.  This functionality can be disabled in the web interface using an administrator level password.  While the demo alert function is good for off-air testing of the equipment, it should not be used.  Even if the front panel function is disabled, these demo alerts can still be initiated by a higher user level from the web interface.

Immediately change default passwords.  EAS units are shipped with default passwords and sometimes systems may revert to default passwords for factory resets and software/firmware updates.  Make sure that as soon as unit is installed or otherwise has the password changed back to the defaults, they are immediately changed back to discrete passwords in order to prevent malicious access.  Also, if your station uses Barix boxes or other equipment that connects directly to the internet, make sure that you change those default passwords before putting the equipment into production service to prevent unauthorized access and program hijacking.

Keeping passwords secure.  Passwords (especially for the Sage) should not be posted in conspicuous places.  They should be kept written in a secure location that is not easily seen by any visitor or any other unauthorized person.  While we all know that keeping a house key under the doormat is not very secure, hanging the key on the front door is asking for trouble.  Same thing here. 

Place the EAS in the studio site instead of at a remote transmitter site. Placing the EAS at a remote transmitter site requires there to be an internet connection established in order to maintain the EAS if the person is not physically at the transmitter site.  Because of limited rack space at some transmitter site installations, there may be no provision to place a computer at the transmitter site to access a remote desktop to access the EAS (plus the presence the equipment at a shared site may pose some additional risks).  It is always best to have the EAS in the audio chain on the studio side before the program audio leaves the main studio location.  If a DASDEC must be installed at the transmitter site, make sure the front panel demo alert mode is disabled.

Use two factor authentication methods if they are ever offered.  Two factor authentication is an additional level of security where if someone does enter the password for the EAS decoder, the system would send an email to the authorized user with a confirmation code that must be entered. Currently, neither the DASDEC nor the Sage provide two factor authentication, but this is something that REC is pushing for as a potential solution to protect EAS decoders from false alerts due to cyber-attacks.  If these features are ever offered, we strongly suggest their use.

Use your EAS decoder's email functionality. Both the DASDEC and the Sage have the capability to email reports to one of more specific email addresses.  Both the DASDEC and Sage can send alert logs, alert notifications and errors.  We strongly recommend that in lieu of accessing the EAS decoder to get log information that the email logs sent by the EAS decoder are printed and retained as part of the station's log.  That way they can be easily reviewed by FCC staff in the event of an inspection or investigation without having to wait for a specific staff member who knows the EAS password.

Practice good common sense network security at the station.  Assure that station assets are only used for station business and that computers are only equipped with the applications necessary to run the station.  Develop policies to make clear that staff or volunteers should not use station computers to access their own emails and download attachments and to use due diligence when receiving an email with an attached file from an unknown external source.  This basic security can prevent stations from experiencing malware, spyware, ransomware and other major security risks. 

The station is your castle, make sure you are protecting it as much as possible.

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REC Advisory Letter #5: Changes to the Assignment and Transfer of LPFM stations

Revision 5 - November 6, 2022

In the context of smaller noncommercial educational (NCE) broadcast stations, including Low Power FM (LPFM), an “assignment” is a transaction where the license is changed (assigned) to another nonprofit entity. A “transfer” is a transaction where the license remains where the license remains with the same entity, but there is a significant change in the persons that control the licensee organization.

(Obsolete) REC LPFM Advisory Letter #12 - Sunset of Analog Low Power TV Channel 6 Operations and Future Protection of Digital TV Channel 6 LPTV Stations (Updated 7/16/21)

This document was declared as obsolete on August 3, 2023.

July 13, 2021 was the final day for analog low power TV (LPTV) stations. A few LPTV stations in remote Alaskan villages were given authority to continue analog service until a time when those sites can be reached to convert to digital.

This also means that the so-called “Franken FM” (or “FM6”) stations (channel 6 LPTV stations that are using their audio carrier at 87.75 MHz to operate like an FM radio station) are also supposed to shut down.


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