Revised June 29, 2026
The following rate card is applicable only for applications filed in the 2026 Reserved Band NCE FM Translator Filing Window. The regular FM Translator Rate Card will take effect after the license to cover application is granted.
Please note that we are taking a different approach for this filing window compared to previous ones. In this window, we are unbundling the original construction permit and the license applications. Overall, it results in the same rates we charged in the 2023 LPFM filing window ($1,100). We are also not accumulating charges for different "add ons" (such as second/third-adjacent waivers, channel 6 studies, etc.). We are also doing this because of the higher likelihood of mutual exclusivity. This change in the structure reduces the risk in the event that the application is not successful due to the competitive nature of the window.
| Original Construction Permit application (base rate) - Includes one modification in connection with mutual exclusivity. Does not include the license to cover application post construction. Includes any needed add-ons. | $700.00 |
| License to cover application (base rate) - Payable when construction is completed and the station is ready to go on the air. Rate only applicable to those who used REC to handle their initial window filing. All others would be charged in accordance with the REC FM Translator Rate Card. | $400.00 |
| Minor modification (not as a result of mutual exclusivity) (base rate) - Rate only applicable to those who used REC to handle their initial window filing. All others would be charged in accordance with the REC FM Translator Rate Card. | $600.00 |
Market premiums do not apply for these window filings.
Any unusual circumstances that may be encountered by FCC action or request will be addressed on an individual case basis.
Rates are per proposed translator facility. Due to the low rate, there are no multi-application or LPFM discounts offered in this window campaign. These rates are similar to those we charged in the 2023 LPFM filing window campaign but are structured differently.
REC Transparency Statement/Terms and Conditions for this window offering
In this document, we discuss the various risks that may take place in participating in the 2026 Noncommercial Educational Reserved Band Translator Filing Window (FX2026) and various policies.
By making a payment to Michelle A. Bradley, CBT d/b/a REC Networks (REC), a for-profit unincorporated association, for services related to FX2026, you have acknowledged that you have fully read this statement and understand the risks and accept the liability for such risks.
Due to the extremely low rate that REC is providing window filings for, we must stress that we have a no-refund policy in most situations, including those that we discuss in this statement. Think of it like flying on a cheaper non-refundable airline ticket.
The following listing of risks are the most common situations that may happen and in no way is this list all-inclusive:
RISK: FULL SERVICE FM STATION APPLICATION ACTIVITY
FM Translators are a secondary service. While they are at the same status as LPFM and noncommercial Class D FM stations, they are at an inferior status to full-service (full-power) FM broadcast stations.
Starting on July 10, prior to the opening of the August 11~25, 2026 filing window, the FCC will have a filing freeze. This filing freeze only applies to secondary stations (such as FM Translator, FM Booster and LPFM stations). It does not apply to full-service FM stations. There is a risk that a full-service FM station could modify their facilities before the end of the filing window resulting in contour overlap with the proposed FM translator thus making the translator unacceptable for filing and subject to dismissal with no opportunity to correct.
The actions of full-service FM stations is beyond our control. Also keep in mind that even if the translator is granted, subsequent changes made by a full-service FM stations could impact the use of a FM Translator. The rules that full-service FM stations can utilize in order to displace a translator are much more forgiving to the full-service FM station compared to similar rules that apply for full-service FM changes impacting LPFM.
In the event that there is subsequent full-service FM activity after payment that takes place before or during the filing window (at the time of filing), we can look for alternatives. Any full-service activity that takes place after the window closes would be considered a separate modification and need to be charged as such. However, the FCC normally would still consider a secondary facility after the full-service application is filed, but based on the nature of the applications could result in a future interference complaint, pursuant to §§ 74.1203 or 74.1204(f) of the FCC Rules. There are no situations that would warrant a refund.
RISK: ORIGINAL CONSTRUCTION PERMIT APPLICATIONS FOR TV CHANNEL 6
TV Channel 6 operates in the spectrum between 82~88 MHz, just below the FM reserved band which is the subject of this window. FM Translators in the reserved band (88.1~91.9 MHz) must provide a level of protection to authorized TV Channel 6 facilities including full-service, Class A, low power TV (LPTV) and TV translator stations.
There are currently a considerable number of applications that were filed for Channel 6 as a result of the FCC’s Video Division lifting a filing freeze on new LPTV and TV translator stations, including those on Channel 6. As long as the TV application remains pending, it does not need to be protected. It is very possible that by the time the window closes, the Video Division may take action on a Channel 6 application and thus would make the Channel 6 facility subject to protection. Depending on the various circumstances, there may or may not be a way to resolve the issue through providing an additional study. This is something that is very location and FM channel specific.
In the event the secondary TV facility is authorized after the close of the filing window, the FM translator would still be permitted without any special studies required. Since LPTV and TV translators are also secondary, a subsequently authorized secondary TV facility cannot displace an FM translator. For that matter, a subsequently authorized full-service Channel 6 facility cannot normally displace a translator unless a showing of actual interference can be demonstrated, pursuant to §74.1204(f). I have yet to see this.
Once an invoice is paid, no refunds will be provided by REC due to changed circumstances involving Channel 6 full-service TV, Class A TV, LPTV and TV translator stations (as well as other Video Division services) that impact the FM translator application or resulting authorized facility before, during or after the filing window. If an invoice is still outstanding and REC advises of the Channel 6 issue and the applicant decides to still pay even though the translator may not be possible, it shall be considered a donation and hence, non-refundable.
RISK: MUTUALLY EXCLUSIVE APPLICATIONS FILED DURING THE FILING WINDOW
FM Translator applications use contour overlap methodology in order to protect existing and proposed facilities. For existing facilities, the interfering contour of the proposed FM Translator facility may not overlap the service contour of a previous facility. For other FM Translator applications filed during the window, protection is both ways (outgoing and incoming interference). FM Translators protect full-service FM and FM Translator stations on co-channel as well as first-, second- and third-adjacent channels. FM Translators are required to protect LPFM stations on co-channel and first-adjacent channels only.
FM Translator applications that are filed during the are kept secret by the FCC until after the close of the filing window. Therefore, we cannot see how others are filing in the window. Once the filing window closes, mutually exclusive (MX)/conflicting applications will be placed into a group of applications where each application has a common conflict with another application in the group. These groups can get large. After the filing window is over, the FCC will first assign each application to a “MX Group” and may offer a period of time when technical amendments can be made in order to remove an applicant from the MX Group. Applicants that are MX may also enter into a settlement agreement where one or more applicants can agree to either withdraw their application or make a technical modification to allow the applicant offering the settlement agreement to prevail. Settlement agreements can include consideration not to exceed the reasonable and prudent expenses borne by the applicant in the preparation and prosecution of their application.
REC policy allows clients to make one technical amendment to their application in order to resolve the mutual exclusivity. This amendment must be made during any period that the FCC designates it would be appropriate to file such amendments.
Any request for an amendment (such as a location, height, directional pattern or other technical change that may require new exhibits) that Is not directly an attempt to resolve mutual exclusivity will be considered by REC as a separate modification and subject to the additional $600 modification fee.
Because filing windows are very highly competitive in some areas, we wish to reiterate that there is a significant possibility that an application filed in the window will not get granted. REC NEVER GUARANTEES A GRANTED APPLICATION. As such, REC will not provide refunds due to an adverse outcome in the aftermath of the filing window.
REC has acknowledged that the risk for losing in FX2026 is greater than previous filing windows, we are reducing the risk by “splitting” the REC fee. Specifically, in this filing window, REC will charge fees separately for the original construction permit application and the post-construction “license to cover” application. This is a departure from the method we used in the NCE2021 and LPFM2023 filing windows where the same fee was for both applications, even if the original construction permit application was never granted. In FX2026, clients will pay $700 prior to the filing window and then if their application gets granted and they construct, they can either pay REC $400 for the license to cover application or they can file the license to cover on their own. The combined rate is equivalent to most applications filed by REC in LPFM2023.
RISK: INTERFERENCE COMPLAINTS FROM OTHER STATIONS
As we previously mentioned, FM Translator facilities protect other facilities through contour methodology. Michi’s Rule #19 reads “Broadcast contours can be deceiving.” Broadcast contours are based only on the terrain located between 2 and 10 miles from the subject transmitter site. This means that (1) a contour does not necessarily reflect the actual area where reception is possible and (2) does not guarantee where that a lack of overlap does not mean that there will be no interference in the real world.
§74.1203 addresses predicted interference from a FM Translator while an FM Translator application is pending and §74.1204(f) addresses predicted and actual interference that takes place once the applicant FM Translator facility is on the air. The complaint process protects listeners who are within the 45 dBu service contour of the complaining station. A study that looks at the actual arriving field strength contours of the complaining station (desired) and the applicant’s FM Translator facility (undesired) and triggers if the “desired to undesired” (D/U) ratio meets the complaint criteria as outlined in those rules. The complaining station must have a minimum number of valid disinterested listener complaints that meets the criteria based on the population count of the complaining station’s service contour. Complaints can come in from other FM translators and LPFM stations that were authorized prior to the subject FM Translator’s application and at any time (even years later) from full-service FM stations. FM Translator stations which have been determined by the FCC to be interfering will be required to immediately go off the air and if a technical solution can be worked out, then the subject FM Translator can go back on the air. The rules do require that the complaining station first reach out directly to the subject FM Translator before taking the matter to the FCC.
REC does not provide refunds in the event that an applicant FM Translator is affected by any aspect of the §§ 74.1203 and 74.1204(f) translator interference process. Any applications filed through REC to resolve the issue will be considered as modifications.
POLICY: INFORMAL OBJECTIONS, PETITIONS TO DENY, SOME SETTLEMENT AGREEMENTS AND RESPONSIVE PLEADINGS
In the event that a window applicant needs to make an informal objection or petition to deny against another applicant, such as a dispute relating to the determination of points, technical deficiencies or qualification of another applicant in the same MX Group, REC cannot write and/or submit those pleadings as to do so could be perceived as practicing law without a license and I am not an attorney (and likewise, any advice I give should never be construed as legal advice).
Likewise for the same reasons, REC is unable to file a “responsive pleading” as a result of another party filing an informal objection or petition to deny against the subject FM Translator applicant.
Formal settlement agreements that construe a contract, especially if they are considered contracts will be considered by REC on a case-by-case basis and based on the nature of the agreement, REC has the discretion to refuse the drafting of the settlement agreement and recommend that the applicant(s) utilize the services of a qualified attorney.
Applicants who need to file such pleadings can either do it themselves (representing themselves) or obtain the services of a qualified attorney with expertise on communications law.
REC does not provide refunds in the event that an application is unsuccessful due to an intervening pleading.
POLICY: REFUND OF REC FEES
Depending on the specific circumstances, REC may provide a refund. Such refunds will be provided solely at the discretion of REC on a case-by-case basis without regard to past precedence.
The situations described in this document are not all-inclusive and any funds, including tips and donations shall be construed as non-refundable unless made refundable at the discretion of REC.
Any amount paid in addition to the scheduled fees (such as through the “tip” function on the invoice) is considered a donation to REC’s advocacy efforts and is not refundable even if REC does, at its discretion, refund the scheduled fees.
POLICY: WHOLESALE (“DOCS ONLY”) REQUESTS
REC, at its discretion, may extend a wholesale service where we only provide exhibit documentation without “ownership” of the applicant. This service is available only to bona-fide consultants and engineers who commit to a specific minimum of wholesale requests and such a service is only provided at the sole discretion of REC and is not available to individual applicants.
POLICY: LIMITED OFFERING AND PRIORITIES
For this filing window, REC is limiting the number of original construction permit applications to 40 FM translator facilities. REC will provide priority handling to requests made by full-service FM requests received by a date designated by REC (the priority request date) (which will be announced on the REC Networks Facebook Page). After that date, we will review requests from LPFM applicants received before the priority request date. From that point, we will review requests in the order received but may still provide priority to full-service requests.
The decision to provide priority to full-service is based mainly on the fact that full-service is not subject to the §73.860(b) limitations that apply to LPFM licensees thus giving them much more flexibility for the placement of translators and based on the nature of the LPFM requests already received, are more likely to be successful in the window because of resources available for the placement of translators. (It is important to realize that all full-service requests received by REC have been from small full-service stations that are within the purview of the advocacy and not from the major names. So far, there should be room to handle some LPFM requests.)
Once we have received payment on 40 requests, then we will cut off all intake. Unless subsequently announced by REC Networks through Facebook post, we will not accept any additional requests after July 31, 2026.
POLICY: PUBLIC SECTOR AND MAJOR PRIVATE SECTOR ENTITIES NEEDING A W-9 FORM
Requests for these entities will be handled by Michelle Bradley as an individual and not Michelle Bradley dba REC Networks as an unincorporated entity. A purchase order is required. Requests requiring a W-9 and/or a purchase order are subject to a base rate of 120% of the amounts shown in the schedule above.
POLICY: PRE-PAYMENT REQUIRED IN MOST CASES
Services requested by entities, other than public sector entities and W-9 requests will require payment in advance of filing services. While we may start preparation of materials prior to payment, no disclosure of these materials nor any filing may take place until payment is received. REC may waive the pre-pay policy on a case-by-case basis at REC’s discretion based on past relationships with the requesting entity.
POLICY: “THE ADVICE IS FREE”
REC provides advice to broadcasters and potential broadcasters all the time through our websites, through email and live telephone conversation. REC provides this service at no cost. REC reserved the right to limit the information provided, especially in cases where providing such information would conflict with a paid service. An example is channel availability. While we may provide “yes/no” answers on availability, we may not always disclose channel numbers and/or maximum effective radiated powers without payment of a scheduled service. Existing LPFM stations can use exclusive resources such as myLPFM in order to obtain some information regarding available channels and move potential.
At REC, the advice is free. If you feel that it is worth more than that, please feel free to send us a donation. Donations received through this method are not invoiced and therefore cannot go towards a client’s historical spend amount nor towards the advance payment on a future scheduled service unless specifically authorized by REC.
REC does not provide legal advice. Michelle Bradley is not an attorney and as such, does not provide legal advice or shall any advice (written or verbal) provided by any aspect of REC Networks be construed as legal advice. Many questions of an administrative nature can usually be answered by a subject matter expert and does not necessarily require the services of an attorney. If REC determines that your situation would be best answered through consultation with counsel, then REC may decline to provide advice and will refer the inquirer to seek the services of a qualified attorney.
POLICY: FORM OF PAYMENT
With the exception of purchase orders by public sector and select private sector applicants, REC will send an invoice using PayPal as the service provider. The system will accept a major credit or debit card as well as PayPal balance for payment. The broadcast station is not required to have a PayPal account. REC recommends that for the best PayPal experience to pay invoices using a desktop computer as opposed to using a mobile device.
Those who wish to pay by check as well as all payments that involve purchase orders, checks must be payable to Michelle Bradley (do not make them out to REC) and then mail to:
Michelle Bradley
11541 Riverton Wharf Rd.
Mardela Springs, MD 21837
Payments using Zelle are also possible. Please contact REC before attempting the transaction so arrangements can be made.
MAKING A PAYMENT TO MICHELLE BRADLEY DBA REC NETWORKS CONSTITUTES YOUR UNDERSTADING AND ACCEPTANCE OF THESE POLCIES AND WAIVES MICHELLE BRADLEY DBA REC NETWORKS OF ALL LIABILITY, INCLUDING CONSEQUENTIAL DAMAGES. THIS UNDERSTANDING AND ACCEPTANCE IS NON-REVOCABLE.
If you have any questions regarding the policies, please contact REC Networks via email at lpfm@recnet.com or call 202 621-2355.
Updated June 29, 2026
