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FCC Takes Up DTV Transition Review, Part Two

Scores of trees will have been sacrificed next week when the FCC issues its Report and Order on the Second Periodic Review of the DTV transition. The commission will issue the review at its regularly scheduled monthly meeting Aug. 4.

The resulting document is sure to be the mother of all doorstops, covering everything from simulcasting, PSIP, signal replication, V-chips, closed captioning, channel election, translators, satellite stations and what to do with those pesky stations in the 700 MHz beachfront band.

There are indications that the FCC may abandon all or part of the simulcasting provision that requires stations to simultaneously transmit their analog programming in digital format. Stations are currently required to simulcast 75 percent of their schedule in both analog and digital formats; with a 100-percent quota kicking in April 1, 2005. Full-schedule simulcasting is antithetical to the development of the type of alternative services that just may induce people to watch over-the-air television.

The end of simulcasting may, however, mark the beginning of cranking up the amps. An ex parte filing from Association for Public Television Stations indicates the commission will do away with the low-power loophole and start making stations replicate their analog coverage with their digital transmissions. To which the APTS cried, "Cart before the horse! Cart before the horse!" Channel selection ought to come before replication, the APTS said.

"Thirty public television stations have DTV allotments outside the DTV core [Channels 2-51] and have no choice but to relocate their DTV operations either to their former analog channel -- if in the DTV core - or another channel," APTS lawyers wrote, adding that still other stations planned to voluntarily relocate to core channels after the analog shutdown, so as not to baffle long-time viewers.

"In both cases, a replication and maximization requirement that would apply prior to the return of one of a station's dual channels would require redundant and wasteful expenditures, as a station is required to replicate and/or maximize twice," the filing stated. "... consider the case of KCTS, Seattle. Its DTV channel 41 operates at 427 kW. If required to replicate the analog service area prior to transition, it would have to operate at 1,000 kW, which would require it to spend an additional $500,000 to $700,000 on supplemental transmitter equipment."

When KCTS ultimately uses Channel 9 after the transition, that supplemental equipment will be worth approximately nothing to the station, except perhaps what they can get for it on eBay.

"For these reasons, public television stations support requiring replication and/or maximization only after digital transition is complete," the APTS filing said.