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FCC DTV Transition Rules Outline Broadcaster Responsibilities

The FCC last Friday released its final rules for shutting down analog TV broadcasting. The order, which also revises station requirements for DTV consumer education, requires all full service TV stations that had not already shut off their analog transmitters to file the FCC's Analog Service Termination Form, specifying a firm date for termination of regular analog broadcasting,

Stations will also have to provide the FCC with a telephone number through which viewers can reach someone with sufficient technical knowledge to answer DTV-related questions and resolve problems about reception of their specific stations. This number will have to be included in station announcements. The FCC's DTV call center staff will use these numbers to link callers with technical questions they can't answer to the station itself.

It sounds as if those calls could keep the technical staff at stations very busy around June 12.

While broadcasters can organize market-wide or state-wide call centers to take the calls, finding people with sufficient training to help viewers with reception problems may be difficult. One option might be to enlist amateur radio operators. They provided valuable assistance during the early analog shutdown in Hawaii.

I did not find the information provided in the Analog Service Termination on the FCC CDBS Public Access Web page as of Thursday. A list of stations planning to terminate analog service on June 12 is available in Excel and Acrobat formats. Also available is a list of stations planning to terminate regular analog service prior to June 12 in Excel and Acrobat formats. Stations had the option of shutting down regular analog programming any time on June 12 and were required to list the time period, or state 11:59:59 p.m. as their shutdown target. This information wasn't available in Tuesdays' releases but I expect to see it on CDBS soon.

On Tuesday's filing deadline, the FCC identified 927 stations that had notified the Commission that they will continue to provide regular analog broadcast programming to viewers until June 12. A total of 158 stations said that they intended to terminate analog service prior to June 12, 2009.

Stations affiliated with PBS accounted for 58 of the 158 stations shutting down early. TBN was next with 26 affiliated operations pulling the switch early. There were also 21 independents that indicated they didn't want to wait until June 12. There were less than 10 stations affiliated with other networks that announced intentions of giving up analog early. Almost half the stations picked April 16 as their analog shutdown date.

The order includes instructions for new DTV education programming. Stations will need to include information on antenna selection, converter box rescanning and, if they are changing from VHF to UHF or vice versa, information about the channel change.

I don't envy having to explain to a viewer that they need to purchase a UHF antenna and manually enter channel 36 in their DTV converter box in order to receive channel 4.1. The best approach may be to first explain that with the conversion to DTV, in many cases the channel numbers displayed on the TV set identify the station, but not necessarily the channel on which it's really transmitting.

There are now 319 stations that expect to lose more than two percent of their analog coverage areas when digital-only transmission begins, as based on studies done by Hammett and Edison for the FCC.

These operations are required to run announcements describing their loss of service areas so that prospective viewers won't spend money on converter boxes and outdoor antennas that will be of no use.

Some confusion exists over this "significant loss" list, as some station are not expected to lose viewers, and may actually gain some audience. This is because the FCC is looking only at the subset of population currently receiving the analog signal, not the entire DTV coverage. The FCC posted maps by market showing Full-Power Digital Television Stations Having Significant Changes in Coverage. Stations that want to use a distributed transmission system (DTS) to replace missing analog coverage have been given until Dec. 14, 2009 to file "waiver policy" applications allowing them to extend DTV coverage enough to match analog coverage, even if it exceeds their DTV service area.

Another provision of the rules has broadcasters concerned too.

According to the order, stations may rely on the provisions of its section 73.1615 for brief interruptions or "reductions of service" due to technical causes. The order states, however, that stations may not rely on that provision to completely end analog service "even in the days immediately prior to June 12, 2009."

It goes on to say that "barring Commission action, a station may only terminate analog service on the date it elects to do so on the analog service termination form."

This implies a station experiencing a major failure with its analog transmitter or antenna could be forced to repair or replace the equipment even if only a few days remained until the June 12 analog shutdown!

There are many more requirements and much more information in the Third Report and Order and Order on Reconsideration (FCC 09-19) than I can summarize here. To avoid problems later, take time to read through it now.

Doug Lung is one of America's foremost authorities on broadcast RF technology. He has been with NBC since 1985 and is currently vice president of broadcast technology for NBC/Telemundo stations.