** FCC LMS BUG LIST ** updated 02/23/2020
The following list are various bugs and other issues of the FCC's Licesnsing Management System that we are aware of at REC. These issues have been already reported to staff.
LPFM HAAT/ERP calculations
LMS is not properly calculating height above average terrain on LPFM applications. This is resulting in LPFM stations with higher HAATs being "short changed" on their power.
Recommended workaround is to make a screen shot of the FCC HAAT tool and FMPOWER results in order to justify the ERP that is appropriate for the application.
Renewal applications with multiple facilities on it
This only affects full-service and LPFM stations that have a commonly owned FM translator or booster, even if that translator is not rebroadcasting the commonly-owned primary station that was used for the application.
When searching for a translator in FCCdata or the FCC's LMS Public Search, if the application does not come up. Go to the LMS Public Search page and click on "Group Search". Put in your call sign and it should come up.
This is similar to CDBS functionality (renewal_translator) for which the FCC is not providing
The additional facilities are getting a separate file number but they do not appear in the main LMS search (CDBS behaved the same way) and they are not appearing in the FCC raw data feed (CDBS had this ability). This will result in the renewal not being seen in the various public access tools such as those operated by the FCC and REC when queried by the translator's call sign or facility ID. The FCC will still process the application but it is confusing to the public. You have to use the Group Search at the LMS site for now. It also holds up multiple station renewals when the objection is only against one facility. The lack of a renewal data file is being reported to staff as a bug.
Licensed antenna data carrying over to modification applications
On LPFM construction permit modification applications, the data about your current antenna make and model is being carried over to the filed form. There is no place in the LPFM application flow where this can be changed on a modification. Traditionally, LPFM stations disclose their antenna types on the license to cover (319) applications. This is creating confusion within staff if the application is also accompanied by a second adjacent channel waiver request that specifies a specific atnenna different than the currently licensed antenna. This has resulted in applications being wrongfully dismissed.
Staff has been made aware of this and will hopefully be more watchful for these applications.
FM translators with LPFM primary stations
(10/11/19) Applications to modify FM translators are currently not able to specify an LPFM station as a primary station.
This has been reported to staff. We are awaiting further guidance and/or a workaround.
Pleadings filed on paper
In CDBS, there was a "correspondence file" that included pleadings (petitions to deny, informal objections, petitions for reconsideration and responsive filings) filed about the facility. Once received at the FCC, they are scanned and loaded. LMS does not have a correspondence file. Electronically filed pleadings show as a pleading record which is supported by FCCdata and FCC.today. Paper pleadings on the other hand are loaded by staff to the application. There is not necessarily any kind of electronic notification in our systems of these filings. Those who need to follow a proceeding may need to periodically review the pending application to assure there are no pleadings filed.
On license to cover applications for LPFM, the form will accept an antenna with one section but will not accept a spacing of 0 (since there's only one antenna, no need to indicate spacing). Lowest value in LMS is 0.1 meters. For applications, REC is using 0.1 spacing on single bay antennas until the FCC ever resolves this issue.
LPFM non-adjacent channel changes.
§73.870(a) states that a minor change for LPFM channel changes must be adjacent channels (+/- 1, 2, 3, 53 or 54 channels) however, a non-adjacent channel can be specified upon a showing of reduced interference. LMS is currently editing channel changes to only permit adjacent channel changes. No official word has been yet received by the FCC on how to handle these. REC is issuing these applications at this time specifying the same channel and including an attachment to call attention to the bug and state what channel the application is specifing (in addition to the normal studies that are required for these non-adjacent channel changes).
Amendments to pending ungranted CDBS applications
REC has experienced difficulty making amendments to applications originally filed in CDBS prior to September 25, 2019 but have not yet been granted (i.e. they likely have an objection on them). Staff will need to handle these manually by manipulating the data on the existing CDBS application. This means that the update will not create a new application ID and it will also not show application history or change a status date to show when the application was amended.
Facility "active" records are not updating from CDBS when a change was made in LMS.
Each engineering application in CDBS and LMS has an "active" record indicator. This is used to denote whether the record is current and whether the facility needs to be protected in accordance with that record. Customarily, when a license to cover is granted, the previous license record and the underlying construction permit record are made "inactive" (or archive in CDBS-speak). For construction permits and licenses originally filed in CDBS, they are not being made "inactive" in CDBS when a license to cover or other modification is filed or granted in LMS. The status on the older records may change in LMS. This is more of an REC issue than a FCC issue. REC plans a fix to this by early January, 2020. REC has placed our fix however as noted in the 12/27/19 update below, there is also a problem in how CDBS originated applications are handled within LMS.
Updated 12/27/2019: We are finding that even in LMS, previously active CDBS records are not being made inactive/archive in LMS when another application is granted. This creates a situation where a facility location/channel is being improperly protected thus causing false negative results. This is a FCC issue. This will be reported to the FCC.
Please report any known bugs with LMS (for radio services) to REC. If you report directly to the FCC, please cc: a copy to firstname.lastname@example.org. Thank you.