Press coverage of the FCC Further Notice and Proposed Rulemaking and Memorandum Opinion and Order (FCC 10-172) regarding the transition of LPTV, TV translator and Class A stations to digital has focused on the FCC's proposal to require these stations to shut off analog transmissions sometime in 2012.
A closer reading of FCC 10-172 reveals additional proposals that will impact LPTV, Class A and TV translator channel options, interference studies and filing requirements.
LPTV and TV translator stations have been allowed to continue operations on out-of-core channels 52-69, as long as they do not cause interference to new licenses in the 700 MHz band. The FCC’s 10-172 proposes setting a Dec. 31, 2011 deadline for LPTV and TV translator stations to move to channels below 52.
This would be before the proposed 2012 (or later) deadline for LPTV and translator stations to transition to digital, but well before the full impact of the proposal in the National Broadband Plan to eliminate all TV channels above 30, as is required to provide the 120 MHz of UHF spectrum the FCC wants to take away from broadcasting.
As participants in the FCC Broadcast Engineering Forum demonstrated, such a drastic reduction in broadband spectrum would not allow enough channels for all full power TV stations in many markets and would almost certainly leave most, if not all, LPTV, TV translator and even Class A TV stations in major markets and densely populated areas without a channel.
Those LPTV, TV translator and Class A stations willing to take the risk of building a facility on a channel that they might lose would face more complicated engineering and more limited options when moving facilities under a minor change application. The FCC proposes requiring that new low power, TV translator and Class A applications include actual antenna elevation patterns (a good idea in my opinion for all broadcast filings). Minor change applications would not be allowed to specify new transmitter locations more than 30 miles from the current transmitter location.
In FCC 10-172, the Commission recognizes the challenges LPTV, TV translator and Class A stations face in funding a DTV transition, even with the money available through NTIA, and suggests that in some cases, individual stations may be allowed to continue analog broadcasting past the yet-to-be-determined deadline.
While most of FCC 10-172 ignores the threat the National Broadband Plan's reallocation of almost half the usable TV spectrum poses to LPTV, TV translators and Class A TV stations, the FCC recognizes it will have an impact on available channels and asks whether the transition deadline should be delayed until the end of 2015, “or after the recommended reallocation of spectrum from the broadcast TV bands is complete....”
Perhaps people submitting comments to FCC 10-172 will highlight the threat that the loss of 120 MHz TV spectrum poses to the continued existence of many LPTV and Class A stations and, in some areas, even TV translator stations.
It amazes me that the FCC, while expressing concern for TV viewers, does not acknowledge engineering realities and continues to ignore the huge negative impact such a loss of spectrum would have on broadcasting, for both full power and low power operations.