For the best interest of our station’s staff/volunteers, we have decided to close our studio. As a result, we are not able to keep our main studio accessible for 20 hours per week as required by the rules. Do we inform the FCC or ask them for a waiver?

How this is handled depends on how your station’s original construction permit was granted in the 2013 LPFM filing window.  If your LPFM station started as a result of the 2013 LPFM window, please first consult the Pledge List to see if your station is subject to the various point pledges.

If the station is NOT on that list or the station was started after the 2000 LPFM window:

• The LPFM station has NO local programming or main studio requirements.  The presence of a main studio for the LPFM has no legal bearing from an FCC perspective.
• The main studio requirement for all LPFM stations is a common myth.  Unless a comparative review of points was used to grant the LPFM application (e.g. another competing applicant was dismissed by points so this station could be granted), there is no main studio requirement.

If the station IS LISTED:

• The FCC has not provided LPFM stations any guidance.  REC has filed a blanket waiver request with the FCC to make them aware of the provisions of §73.872(b) and that at this time due to the many government restrictions on gatherings and in the best interest of public health, LPFM stations subject to the pledges will not be able to make these pledges.
• The FCC has not acted on this waiver request (as of 3/19/2020).
• For now, REC recommends that all LPFM stations on the pledge list maintain in their station logs the dates that the studio remained closed.  If, in the event that someone objects on a license renewal that the station did not maintain their pledge, you have documentation to show the country was in a state of emergency during the time when the studio was closed.