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LPTV and Class A Transition Rule Set by FCC

Yesterday, the FCC set the new rules that will apply to LPTV and Class A stations in making a final transition from analog to digital operations by the end of 2015. While the full document is available at this link, I have decided to break the important points out of the legalese and try to make them a little more accessible.

  • According to the document, 60% of low-power stations already hold permits to transition to digital in one way or another. 2980 flash-cuts and 1354 companion channels have been granted, out of 7240 low-power stations total.
  • September 1, 2015 has been set as the deadline for transition. This date was chosen for several reasons. First, and most important, is the hope that the National Broadband Plan will have progressed enough that low-power stations will not be forced to build twice. The FCC also noted the preference of a summer transition date to facilitate easier roof antenna adjustments for viewers and tower work for stations, an argument that should have been made for the full-power transition's original February date. Finally, the FCC rejected the arguments of several Franken FM operators on channel 6 that no hard deadline should be set.
  • All existing permits for low-power digital TV conversions have been automatically extended to September 1, 2015. No extensions are required between now and the transition date.
  • The FCC will grant a single extension beyond September 1, 2015 to March 1, 2016, but all analog broadcasts must cease on the original expiration date. This means any station not operating digitally by September 1, 2015 must remain off the air until a digital facility is constructed. Additionally, any requests for extensions must be filed by May 1, 2015. After that date, stations must use "tolling" to receive an extension, a process which is not often used and thus I will not go into detail here.
  • No specific consumer education requirements were adopted, but the FCC does suggest that their 888-CALL-FCC number will make information available.
  • Stations operating in the out-of-core channels 52-69 have until September 1, 2011 to file for displacement into the core, and all stations must cease operation in that band by December 31, 2011. The FCC states that if a permit is not granted by that date, stations will be granted STAs to use the applied-for in-core channel.
  • The power limit for low-power VHF stations has been increased to 3 kW ERP, up from the previous rule of 0.3 kW ERP.
  • All pending applications for new analog stations that were not modified to specify digital facility have been dismissed.
  • Stations which have not made their digital transition plans clear by a date within about 30 days of the September 1, 2015 deadline must file a notice with the FCC stating their intent. Stations currently operating on digital companion channels may operate them up until the deadline, and given that they were listed in this section of the document, I assume that means they would have to file such notices.
  • If a station is silent in analog for more than a year, or holds an unbuilt analog permit that goes unbuilt by the end of the three year deadline, the presence of an unbuilt flash-cut or digital companion channel will NOT save the license.
  • Stations are required to provide notice of impending transitions from analog to digital. If a station can locally originate such a warning, then it should do so on-air during period of high viewership. Otherwise, notice in a local newspaper or, in the case of a translator, notification on the parent station are both acceptable options.
  • Currently-licensed Class A companion channels will be allowed to file a license modification to specify the companion channel as their new protected channel. No permit process will be required.
  • Low-power stations operating under STA are now subject to the 5% fee regarding ancillary services, joining licensed full- and low-power broadcasters.
  • Minor change rules now require new transmitter sites be specified within 30 miles of existing stations, as is the case with displacements. If the need for a move of more than 30 miles is demonstrated, waivers of the rule will be granted. Coverage contours are still required to overlap.
  • Low-power stations are now optionally allowed to specify vertical antenna patterns.
  • Low-power and class A stations are now allowed to use full-service mask filters without seeking a waiver.

I think that about covers it. Please feel free to either e-mail or comment with any questions, omissions, or errors that you find.

Comments

1. On Saturday, July 16 2011, 12:27 by w9wi

I'm rather surprised they're allowing this much time. I expected a drop-dead date late next year or sometime in 2013.

Otherwise, I don't see anything surprising here.

I suppose the "FrankenFM" operators will launch a complaint storm. But I don't think most of them really believed they'd be allowed to continue in analog forever. And I suspect many of them are actually happily surprised they're getting this much time.

2. On Saturday, July 16 2011, 17:45 by re_nelson

>> Otherwise, I don't see anything surprising here.

I think the increase to 3 kW from 0.3 kW is rather noteworthy if not surprising. A 10 dB upgrade just *might* be enough to encourage some LPTVs to migrate away from UHF back down to VHF, saving a few dollars in monthly electric bills.

3. On Saturday, July 16 2011, 21:32 by w9wi

>>be enough to encourage some LPTVs to migrate away from UHF back down to VHF, saving a few dollars in monthly electric bills.

(and making it easier to hand over the UHF spectrum to land-mobile...)

4. On Sunday, July 17 2011, 00:09 by dhett

And you know *that* is the end-game here. The FCC desperately wants TV stations down on VHF so they can reappropriate UHF.

5. On Sunday, July 17 2011, 09:54 by w9wi

After further reading of the full release, it turns out the reallotment of UHF is also the reason for the lengthy transition period.

LPTV operators don't want to be forced to convert to digital next year, only to learn a few months to a year later that their new DTV channel is to be reallocated to mobile broadband.

By delaying the transition, the Commission hopes the reallocation plans will be known by the time LPTVs are forced to convert.

Of course, that will be scant comfort if there is no TV spectrum left for LPTVs to digitize on.....

6. On Sunday, July 17 2011, 09:56 by w9wi

Darn. My above comment is a bit misleading, in that it suggests Trip's summary of the proceeding doesn't mention the reason for the lengthy transition.

That's not true, he fully & prominently discussed it.

7. On Monday, July 18 2011, 00:57 by dhett

What does surprise me is the swift order to clear the 700 MHz band. Granted, it's not that LPTV operators haven't known for years that this was coming, and it makes the FCC's favored children - broadband operators - happy, but to give them six weeks to file displacement applications with the consequence that late applications will be dismissed and those stations will forfeit their licenses on December 31...wow.

Still, there are many good things in this order. I'm glad to see the FCC finally set down rules for LPTV.

8. On Monday, July 18 2011, 01:54 by Gilbert Sebenste

They darn well had better boost the full power VHF limits by 10 db in at least the eastern U.S. They're ridiculously low...and the channel repacking that they're going to do in this economy will kill off some full-powers.

9. On Tuesday, July 19 2011, 00:12 by Jim

From the article: Low-power stations are now optionally allowed to specify vertical antenna patterns.
----------------
In my minds eye I can see neighborhoods full of low-band VHF multi-bar vertical Yagis ... Let's see how well the OTARD rule works.

Jim in Seattle / FringeReception@yahoo.com

10. On Tuesday, July 19 2011, 02:52 by w9wi

Jim: I don't think that's what they mean by vertical antenna patterns. They mean LPTVs will be allowed to consider the directivity of their antennas in the vertical plane when considering whether interference is caused.

The antennas will still be expected to be horizontally polarized. (or at least, have a horizontal component greater than the vertical)

Transmitting antennas generally radiate more power along the horizon than they do above or below it. You can manipulate that characteristic to put more power in a place where you want it -- or less in a place where you don't. A crude -- and popular -- technique is called "mechanical beam tilt", where you actually physically tilt the antenna. More sophisticated and wholly electronic methods are possible.
===========================
Gilbert: A power increase is indeed on the table for full-power stations. Engineers have told the FCC it won't do much good: the real problem with VHF is noise & interference from poorly-shielded consumer electronic gear. The FCC has said they don't intend to fix that problem because it would drive up the cost of gear.

Interference between VHF DTVs on the same channel is also part of the equation. An across-the-board 10dB (or whatever) power increase will make no difference whatsoever, the desired-to-undesired ratios will remain unchanged.

*At least at this time* surrendering one's channel for repacking is to be voluntary. (We'll see if that holds..) I can see some also-ran stations volunteering to "commit suicide", finding that the auction revenue on the table for their channel is worth more than the station.
===========================
dhett: Agreed that the LPTV operators deserve a bit more than six weeks to get their displacement applications on file. I'd give them to the end of the year to file and until next March to get it on the air.

But really, might one imagine the vast majority of those LPTVs that plan to convert have already filed their paperwork, if not actually converted?

11. On Tuesday, July 19 2011, 11:45 by dkreichen1968

Repacking isn't going to kill off full-power stations unless they volunteer because the government is going to pick up the tab for rechanneling. At least that is what NAB is pushing for, and what I'm sure they will get. LPs, because they are "secondary" services can be killed off with just a word.

12. On Wednesday, July 20 2011, 16:19 by Ryan N2RJ

Franken FM, heh. That means WNYZ-LP is going bye bye here.

13. On Wednesday, August 10 2011, 08:59 by mark

we are a 2 person owner of a small lake havasu city lptv station and it looks as if we don't qualify for any rembusment grant. we are looking for a digital 30watt tx . we currently own an old armstrong uhf 100 (928-454-8888) any help or other forums appreciated