[opendtv] FM Group Requests Emergency Freeze on TV Filings

From: "Manfredi, Albert E" <albert.e.manfredi@xxxxxxxxxx>
To: <opendtv@xxxxxxxxxxxxx>
Date: Fri, 7 Aug 2009 17:00:21 -0400
If I were the FCC, I'd say absolutely not, concerning handing over Ch 5
and 6 to FM radio. Especially in view of the fact that coverage of DTT
stations is till being tweaked, and that low power translators may be
required to fill gaps. And of course, LPTV stations are likely to opt
for these channels too.

And even more because there should be no excuse for such requests.

TV has already had to give up spectrum, whereas radio has not. The
excuse for TV was that they could make better use of their existing
spectrum with the digital switchover (and in my case, they certainly
have done so). Guess what? FM radio has the same opportunity.

There are no existing FM radios that can tune down as low as 77 MHz
anyway. If new radios are a prerequisite to benefit from this expanded
FM radio band, might as well make those new radios HD radios, and not
expand the spectrum at all. Matter of fact, if FM went through a similar
digital transition as TV has done, they could gradually increase their
radio offerings many time over. I'd estimate at least 6 radio programs
in each channel now used in hybrid mode, if analog were shut off. And
this can be done gradually.

Bert

-------------------------------
http://www.tvtechnology.com/article/85032

FM Group Requests Emergency Freeze on TV Filings
08.06.2009.

The Broadcast Maximization Committee (BMC), in a communication to the
FCC dated Aug. 5, has formally requested an "emergency freeze" on
filings for operation of digital low power television transmitters,
including translators, on either Channel 5 or 6.

The BMC is a Gaithersburg, Md.-based group of consulting engineers and
other broadcasting industry representatives that was formed to promote
the use of that part of the spectrum (76-88 MHz) to accommodate low
power FM, non-commercial and AM broadcasters in the post-DTV transition
environment.

It is concerned that the FCC's recent Public Notice (June 29) announcing
a window for filing applications for DTV low power and translator
operations could jeopardize the group's proposal for expansion of the
present U.S. FM band downward to create more room for radio
broadcasters.

The BMC's letter to the FCC's Secretary, Marlene H. Dortch, noted that
the FCC is still requiring non-commercial educational FM stations, which
operate at the lower end of the current 88-108 MHz FM band, to protect
Channel 6 television operations "until further notice." The BMC termed
this "disparate treatment," as new LPTV and translator applicants were
not required to provide such protection. The BMC letter further stated
that it was "likely that new digital television stations on Channel 6
could cause interference to existing FM stations" due to the FCC's DTV
emission mask requiring that signals only be attenuated by 47 dB within
500 kHz of a TV transmitter's band edge.

The group also noted that in the post-DTV transition television world,
"the spectrum for Channel 6 is widely available across the country" and
that "it is expected that many [television] applicants will be
submitting applications for this channel in the hope that they can
operate the audio in an analog mode for some period of time." The BMC's
letter said that while it was outside the scope of their current
emergency freeze request, they did encourage the commission to rule on
the legality of such "Franken-FM" broadcasting activities.

The BMC's emergency freeze request called for a halt to filings for
Channel 5 and 6 TV applications beginning on Aug. 25, and continuing
until the FCC makes a decision on the use of this spectrum for FM
broadcasting purposes.
 
 
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[opendtv] FM Group Requests Emergency Freeze on TV Filings

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