If your station is in one of the larger TV markets and you are giving up an in-core allocation (channels 2-51), chances are you’ve been contacted by an LPTV station looking for permission to file an application for your analog channel.
Although these channels are still occupied, applicants have specified very low power transmitters and used an OET-69 interference study to show their use of an occupied analog channel will not cause more than the de minimis interference allowed under FCC rules, even if the analog station hasn't ceased operation. It’s important to note that the DTV-to-analog interference ratios used in OET-69 allow for some degradation of analog picture quality. This allowed degradation of analog picture quality was necessary to provide enough channels to provide every authorized analog station a separate DTV channel when the first DTV Table of Allotments was generated.
In its Public Notice DA 09-1299 released on Wednesday, the FCC said it “has received existing analog and digital Class A, low power and translator displacement, minor modification and flash-cut applications that do not comply with the Commission’s interference protection requirements because they are in conflict with pre-transition full-service stations’ operations.”
The Public Notice also states that many applications will comply with the FCC’s interference standards after full-service DTV broadcasting commences on June 12, and that “any such Class A, low power, or translator application filed prior to the end of the full-service digital transition, on June 12, 2009, through June 30, 2009 will be treated for cut-off purposes as being filed on June 30, 2009.”
One interpretation of the Public Notice is that it opens a short window for Class A, LPTV, and TV translator licensees to file minor modifications or displacement applications now for analog channels that will be available after the DTV transition and analog nightlight service is finished. Since the cut-off date will be June 30, regardless of when the applications were filed, mutually exclusive applicants will have to settle or be placed into an auction.
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