All broadcast stations, including LPFMs, must renew their FCC license sometime between July 2019 and 2022. The process includes reading on air announcements at specific dates and times, as well as filing Form 303-S with the FCC. Both Covid and rule changes have made renewal procedures a moving target this time.
|Prometheus Radio Project
These instructions are for Low Power FM non-commercial stations only. This is a guide prepared for LPFM stations by the Prometheus Radio Project to guide you through the process, but is not meant as legal advice. Thorough information about the renewal process can be found at the FCC’s website.
Step 1: Check your information in the FCC database, and find out your expiration date
Strangely enough, the date your license expires has nothing to do with when you got your license. Your expiration date is based on the state your station is located in and occasional accelerated renewal dates. The earliest renewals start in June of 2019, and the process continues until 2022. Find your expiration date by searching the FCC web site for your call letters then click on your station and it will show your “License Expiration Date”, which MAY be different than the expiration date of other stations in your state.
There are many steps to the process, each with a different deadline. Here they all are, in order!
You should also check if you have a current email and mailing address on file at the FCC as soon as possible. If you need to change your contact info, you can log in to the FCC’s LMS website and change it. It will be called an administrative update.
Step 2: Broadcast Pre-filing Announcements on the air (DISCONTINUED)
Pre-filing announcements were waived during the beginning of the COVID stay-at-home, and the FCC rules then changed so they will never be required. Here’s the FCC Announcement.
Step 3: Fill out the renewal, Schedule – 303-S
First: Gather some information in advance to help you navigate the application process more quickly!Previous Application: The questions on the renewal form are the same or similar to the questions you answered when you initially applied for your station, or when you most-recently renewed the license, or perhaps when the license was transferred to you. Search for your station (when you search for your call sign, include -LP at the end) and then grab a copy of your initial new-station application (LPFMs will have the prefix BNPL-, the most-recent renewal (BRL-), or license-transfer (BALL-) previous application and think about what’s changed since then. You need to answer the questions based on your current board of directors. .
Station Information: You will need the legal name of the licensee of your station, your facility ID, your FCC Registration Number (FRN), and your Community of License. These can be found in the same FCC database, and should be on your old application, unless you have changed them through the FCC since you applied.Once you have this info ready, you can take the plunge into the FCC’s website, where you will fill out the application online. But instead of using CDBS, you’ll be the newer system called LMS which is prettier than CDBS, but different. We explain all of the steps and if you’re feeling brave, just log into LMS!.
Filling out the form:
Check out our guide to using LMS for renewal.
Step 4: Broadcast Post-filing announcements on the air
Sample POST-filing Announcement
(The announcement should be in the main language spoken on your station) These instructions apply to renewals on or after December 1, 2020 subject to these newer rules.
One more step, and you’ll be done! After filing your application you must let your listeners know the good news that you’ve applied for a renewal, so they have another chance to object to your application to the FCC. You can read aloud the sample notice.
On [DATE], [NAME OF YOUR ORGANIZATION], licensee of [YOUR CALL SIGN], [STATION FREQUENCY], [STATION COMMUNITY OF LICENSE], filed an application with the Federal Communications Commission for license renewal. Members of the public wishing to view this application or obtain information about how to file comments and petitions can visit www.fcc.gov/stationsearch. You can find this application by searching for [YOUR CALL SIGN].
The scheduling rules are complicated but here’s a schedule which can work for everyone.:
Broadcast the notice once every Monday and Thursday between 7am and 11pm for four weeks, starting the Monday after you file your renewal form.
Exceptions:If you aren’t on the air between 7am and 11pm on Monday and Thursday, you may choose to broadcast the announcement one time on any two different weekdays, Monday to Friday between 7am and 11pm.If you don’t broadcast on at least two different weekdays at some time between 7am and 11pm, a situation which the new rules do not appear to contemplate, then the strictest interpretation says that you must also publish online notices in the same way as silent stations according to 73.3580(b)(2).If your station is currently silent, you must publish the announcements online according to the 73.3580(b)(2).
You should note or log when you make these announcements so that the FCC can ask to see them later. Since LPFM stations aren’t required to keep a “public file” (that’s where other types of stations would make this log), you could write the time&date, that it was a post-filing announcement, and initial it on a piece of paper saved in your internal records, or you might print and initial a log from your automation system. You might use a system like this for recording proof of underwriting announcements.
And you’re (probably) done!
Optional step 5: 1 month before your license expiration — check the FCC’s LMS system to see if anyone filed in protest of your license renewal
If a petition to deny your application is filed within 3 months of your renewal application deadline (which is 1 month before your license expiration), you should contact a lawyer, or contact Prometheus if you do not have one.
Also, the FCC may ask you for clarification on your application through email or by mail. Otherwise, throw a celebration with all the parties to your application, and wait for the FCC to notify you about your status.
Respond to any calls, email, or surface mail from the FCC. That’s why it is important to keep your contact information up to date!
Step 6: Wait for it!
Wait! It is fairly common for license renewals to be granted up to several months after(!) license expiration. Don’t sweat it.
Step 7: You got it — Check it!
You will receive your renewal by email or surface mail.
When is your next expiration/renewal? Sometimes the FCC only grants a 1-year license especially when there were any problems reported on your renewal application. You might have to start the process over in 4-8 months!