I've always thought LPFMs should bet technically indistinguishable from a translator - and the FCC has a precedent in the AM-on-FM rules. A daytime AM station continuing to be heard via a translator after local sunset or before local sunrise is a de-facto LPFM - and a commercial one, to boot. Since it's in "fill-in" service, the protected contours are also usable, rather than straight mileage separations - the only limitation is the AM's 2 mV/m contour or 25 miles - and that 250-watt cap - in determining coverage as long as the actual contours don't overlap. As to the rest - I think I agree with John. Throw out any patently-defective and all MX applications form the 2003 GTI, and start over. But let's note what exists with the AM-on-FM translator... and remove the non-commercial-only requirement. Perhaps, to keep the megacasters from grabbing them, commercial ownership could be restricted to sole proprietorship applicants.