“The 396-A is on file so I’ll go ahead and push the button on the 314.  Then I’ll draft the 323.”[1]  Was a finer sentence ever uttered by a broadcast attorney?  Probably, but such roll-off-the tongue eloquence will soon be a thing of the past as the FCC embraces the brave new world of the LMS filing system and Form 2100.

On September 29, 2014, the FCC announced the availability of the first phase of its new e-filing system, the Licensing and Management System (LMS).  LMS will eventually replace CDBS as the e-filing system for all radio and TV broadcasters.  Those familiar with the FCC’s Universal Licensing System (ULS) will notice similarities between the two systems.  Both require an FCC Registration Number (FRN) and FRN password to log-in and use one common form with different tabs or schedules to complete depending upon the type of application/authorization requested.

The initial phase of the LMS roll-out applies only to full-power TV stations seeking to file applications for construction permits or a license to cover a construction permit.  Both of these applications (formerly Form 301 and 302-DT, respectively) will now be part of a new single form – Form 2100.  The new form will consist of two sections.  The “main portion” of the form will ask for general information common to all broadcast applications. Information specific to particular applications will be completed on associated schedules for each type of authorization being requested.  Schedule A will need to be completed by those broadcasters seeking to obtain a construction permit for a full power TV station.  Schedule B will be required for a license to cover.  Additional schedules will be released in the future.

As of October 2, 2014, existing full power TV station permittees and licensees will be required to use the LMS system to file applications for construction permits and licenses and any amendments to pending construction permit and license applications using Form 2100 Schedule A or Schedule B.  Form 2100 is available here, and the LMS system can be found here.


[1] Translation: “The Model Equal Employment Opportunity form has been filed, so I’ll go ahead and submit the Assignment Application.  Then I’ll draft the Post-Consummation Ownership Report.”

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