** FCC LMS BUG LIST ** updated 03/03/2020
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), however the FCC is not providing the raw data cross-reference table for LMS like it did for CDBS.
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. Contact REC or Audio Division staff prior to filing so the FCC can do something on their end. If you contact REC, please remember to provide us with the FRN & password if we don't already have it.
Amendments on LMS originated applications
(2/25/20) When an amendment is filed in LMS, like CDBS it creates a new application ID and uses the same file number, however, it does not automatically change the previous application ID's status to "superceded" and makes in makes it an inactive (or "archive" in CDBS-speak) record. When the amendment reaches staff, they are supposed to "accept" the amendment which they do, however, in appears that at times, the system (on the FCC side) is not granting the amended version of the application, but instead, is granting the original version. REC is recommending that applicants than when an application has been granted and the authorization is generated (which will be e-mailed to the e-mail addresses on the application) that you carefully check that authorization document to assure that the correct version of the application appears in the authorization. If the wrong facilities are on the authorization, then staff may be able to fix it on their end. Please notify REC or Audio Division staff if this happens so it can be fixed.
Auxiliary LPFM facilities
(3/3/2020) Very few LPFM stations have (or have a need for) an auxiliary facility. Briefly, auxiliary facilities are back-up facilities that can be instantly put into place in the event the main station fails. This is how big stations can continue to operate while the main tower or transmitter is being worked on. In CDBS, we were able to file for LPFM auxiliary facilities by filing a Form 318 modification (BPL) and then having staff change the application to an auxiliary facility (BXPL). So far, multiple LPFM applications filed in LMS were dismissed for following a similar process. REC is currently working with staff to determine the process to allow LMS to accommodate a LPFM auxiliary facility. At this time, those applications can't be filed.
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). You should first access LMS and look at the applications as it may already be there. You may try to amend the application through LMS. (It will appear in REC systems with a prefix prior to the original application reference number [i.e. MOD-BPL-20190815ABC, etc.]. If amending does not work, 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. Contact FCC staff or REC for assistance.
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 email@example.com. Thank you.