Can an LPFM station still earn a point for pledging to broadcast 12 hours per day during the application window?

No, an LPFM (Low-Power FM) station cannot earn a point for pledging to broadcast 12 hours per day during the application window. This particular point system for broadcasting hours is not applicable during the LPFM application window.

The point system for LPFM (Low-Power FM) applications has evolved. The current point system, as of June 2019, is as follows:

1. Established Community Presence: The applicant must qualify as local for a two-year period before filing, defined as being within 20 miles of the transmitting antenna (except in markets 1 through 50, where the distance is reduced to 10 miles). The organization must maintain this local presence afterward.
2. Local Program Origination: The applicant pledges to carry a minimum of 8 hours of programming per day originating from any point within 10 miles of the transmitting antenna, regardless of market size.
3. Main Studio: The applicant pledges to maintain a publicly accessible main studio with local program origination capability. It must be accessible by phone for at least 20 hours per week and be located within 20 miles of the transmitter (except for markets 1-50, where the distance is reduced to 10 miles). This point still applies despite the FCC’s elimination of main studio requirements for full-service broadcast stations.
4. Local Program Origination and Main Studio Bonus: If both points 2 and 3 are claimed, a bonus point can be earned.
5. Diversity of Ownership: An applicant must not hold any attributable interest in any other broadcast station.
6. Tribal Applicants Serving Tribal Lands: The applicant must be a tribal applicant, and the transmitting antenna must be located on tribal land.

LPFM stations are only required to fulfill the local program origination and main studio pledges if, at the end of the filing window and subsequent remediation windows, their points were necessary to eliminate another applicant from contention. If, before the original grant, the applicant makes a move to break out of the mutually exclusive (MX) group of applicants, or another applicant in the same MX group makes a change or is otherwise dismissed before the Commission’s final decision, thus making your application a “singleton,” you are absolved of meeting those pledges.

Additionally, if a time-share agreement is reached that involves all applicants in the group and does not result in the elimination of any applicant, then the group is absolved from the pledge requirements.

It’s important to note that LPFM stations that regularly do not operate 12 hours a day are subject to mandatory time sharing if a challenging application is filed during the renewal cycle.