RabbitEars Knowledge Base

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====== Channel Changes for Full-Service Stations ======

//Please note that it is advised to consult with a communications attorney and consulting engineer to verify your filings are all complete and meet all requirements, though people have done it in the past without such support. Additionally, the FCC sometimes freezes acceptance of such requests, though as of this writing in September 2023, it is accepting them at this time.//

When a full-service station wants to change its channel, it first prepares a "Petition for Rule-Making," which it submits to the FCC.  The FCC needs to know a few things.  First, it needs to provide full technical parameters of the proposed facility on the new channel.  Second, it needs to provide an [[https://transition.fcc.gov/oet/info/documents/bulletins/oet69/oet69.pdf|OET Bulletin No. 69]] analysis using the FCC's [[TVStudy]] software, in order to demonstrate that it will not create excessive new interference to any other full-service or Class A station and otherwise complies with FCC rules.  Third, it should show that its proposed new facility's principal community contour ([[https://www.ecfr.gov/current/title-47/part-73/section-73.618|47 CFR 73.618]]) will completely encompass its community of license.  Finally, it should show that its new facility will not create more than a "de minimis" loss, which is defined by a [[https://digital.library.unt.edu/ark:/67531/metadc770882/m1/247/|1980 precedent]] as 556 or fewer people.  

Should the FCC determine that all of those criteria are met, it will issue a "Notice of Proposed Rule-Making" or "NPRM."  At this point, it is open for public comment, and then there's a period for additional comments replying to the initial comments. During the comment period, the petitioner is expected to submit comments affirming its desire to implement the channel change.

Usually, these are not controversial. In that case, the FCC follows up with a “Report and Order” which then alter the allotment in the Table of TV Allotments.  If by some chance there are objections, the FCC may seek more information, or may rule based on what it has already received.  In either case, it will decide in a Report and Order. 

Shortly after the Report and Order, the station then files for its construction permit to move to the new channel.  After the permit is granted, it has three years to construct, as is the case with any other modification a station might seek to make.
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