The FCC's DTV trick or treat

It's that time of year again. Your doorbell rings and when you answer, you're greeted with little costumed munchkins begging for candy and promising tricks if you don't deliver. Looks like the FCC is about to do much the same. In midsummer the commission announced that TV broadcasters would be required to file a status report on their DTV build-out.

This document, called FCC Form 387, is due Dec. 1, 2007. If your station is already at full, post-transition channel and power, you'll get a treat: no governmental hassle. If not, look out. This form is full of tricks for the unwary applicant.

The FCC calculates completing the form will require two hours each of legal and engineering assistance at an estimated cost of $700. Don't believe it. Similar bureaucrats required six months and 175 work hours to produce a brownie recipe that ended up being 22 pages long!

While the DTV status report form isn't terribly lengthy, it does require some data gathering. For instance, you'll need to know your current and future power and channel of operation. In addition, you'll need to supply the ethnicity of your current and future viewers along with their household income, the ages of each household member, the type of car they drive and, oh, their shoe sizes.

That won't be as hard as you first might imagine. Homeland Security and the NSA have been gathering this information for several years. Unfortunately, you'll need to submit a Freedom of Information request to get it.

Upon close examination of the questionnaire, it may appear that the commission is setting a trap for unsuspecting engineers and managers. Some example questions:

Are you operating:

a) post-transition PTA

b) post-transition STA

c) a TV station without a license or permit of any kind? Note: Don't check answer C. If your station is not yet at full DTV power, look out because the FCC wants to know why.

Are you not at full post-DTV operation because:

a) the station hasn't yet started building

b) the station is in the midst of construction

c) you don't plan on doing anything because you still think the politicians will put the kibosh on the whole DTV idea?

Section four is a labyrinth of other gotchas just waiting to snare station personnel. The form wants you to specify exactly what equipment you need to finish construction. It asks: Do you need an antenna, transmitter, tower crew or any other equipment we could sell you? Personally, I think someone at the FCC is collecting this information for resale to vendors.

Now, we're down to the last question, and if answered properly, you're off the hook. That question is: Are there any environmental issues beyond your control that are preventing you from completing your DTV facilities? Here's your out. Just answer yes, and say that global warming is the reason you haven't finished construction. Say you've complained to Al Gore about it but haven't heard back.

So, there you have it, the FCC's DTV trick-or-treat examination. If you're lucky enough to have finished your DTV transition, congratulations. If not, hurry up, or you could be left holding an empty DTV bag.

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