FCC Denies Petition for Amateur Radio Assignment Inside TV Channel 4

The Chief of the FCC's Office of Engineering and Technology has released an Order denying a petition for rulemaking filed by Glen E. Zook proposing the commission add a “4-meter” radio band (70.0-70.5 MHz) to the list of bands available to amateur radio operations in the U.S. and areas under the FCC's control.

The Order lists several shortcomings in Zook's petition, including a lack of technical data to justify statements, including assertions of no interference to adjacent channels, made in the request. What I found interesting were statements in the FCC's Order relating to the use of low-VHF channels, including channel 4, for DTV broadcasting.

The Order states, “Based on data compiled by the Commission’s Media Bureau, Channel 4 is currently populated by three full-power TV stations, 110 low-power television (LPTV) and TV translator stations, and six Class A TV stations.”

It continues, “The Commission also has an ongoing incentive auction proceeding that, among other things, will repurpose a portion of the TV band for broadband operations and repack the remaining TV stations into a smaller frequency range. The incentive auction proceeding does not eliminate the use of TV Channel 4, and envisions a number of voluntary options for full power and Class A TV stations – including relocation from a UHF channel to a VHF channel and relocation from a high VHF channel (Channels 7-13) to a low VHF channel (Channels 2-6). Under such circumstances, Channel 4 could become even more robustly used for broadcast purposes than it is now. Even if such an outcome is not realized, there is no reason to expect that full power, Class A, and LPTV stations will not continue to make use of an available television channel. The Zook Petition, in dismissing such continued broadcast use of TV Channel 4, fails to show how harmful interference to broadcast operations by new amateur users would be avoided.”

Regarding the incentive auction, the Order states, “Given the complexity of the incentive auction proceeding, we also conclude that it would not serve the public interest to further complicate that unique undertaking by proposing to introduce a new service into the broadcasting frequencies at this time. We note, in particular, that the Zook Petition does not address whether amateur use of the 70.0-70.5 MHz band would preclude the ability of LPTV and TV translator stations to operate on (or migrate to) TV Channel 4. There is no reason why we would want to introduce such uncertainty into the band.”

While I can see the benefits of a 4-meter radio band (the wavelength of the 70 MHz band) to amateur radio operators, I'm happy to see the FCC's Office of Engineering and Technology protecting broadcasters from interference, but also recognize that denying a single amateur radio operator's petition is a lot easier than denying a petition or application from a well-funded and politically connected corporation or organization.

See the Order (DA 14-134) for additional information on Zook's petition, the FCC's analysis of it, and justifications for denying it.

Doug Lung

Doug Lung is one of America's foremost authorities on broadcast RF technology. As vice president of Broadcast Technology for NBCUniversal Local, H. Douglas Lung leads NBC and Telemundo-owned stations’ RF and transmission affairs, including microwave, radars, satellite uplinks, and FCC technical filings. Beginning his career in 1976 at KSCI in Los Angeles, Lung has nearly 50 years of experience in broadcast television engineering. Beginning in 1985, he led the engineering department for what was to become the Telemundo network and station group, assisting in the design, construction and installation of the company’s broadcast and cable facilities. Other projects include work on the launch of Hawaii’s first UHF TV station, the rollout and testing of the ATSC mobile-handheld standard, and software development related to the incentive auction TV spectrum repack.
A longtime columnist for TV Technology, Doug is also a regular contributor to IEEE Broadcast Technology. He is the recipient of the 2023 NAB Television Engineering Award. He also received a Tech Leadership Award from TV Tech publisher Future plc in 2021 and is a member of the IEEE Broadcast Technology Society and the Society of Broadcast Engineers.