[opendtv] Doug Lung on digital replacement translators

  • From: Albert Manfredi <albert.e.manfredi@xxxxxxxxxx>
  • To: <opendtv@xxxxxxxxxxxxx>
  • Date: Thu, 25 Dec 2008 18:03:56 -0500

It seems to me that if an existing translator is allowed to flash-cut to 
digital using the same ERP as it was using in its analog service, coverage 
increase would be greater than "de minimis."
So it must be up to the owner of the translator, in the application, to specify 
the corrected ERP, to equal as close as possible his current analog signal 
This would of course also apply to existing analog LPTV stations.
Limited Window for Stations to Build Out 'Replacement Translators'
by Doug Lung, 12.24.2008
One of the items on the canceled Open Commission meeting last week was the 
creation of a new “replacement” digital television translator service.
Late Tuesday (the evening before Christmas Eve), the FCC issued a Notice of 
Proposed Rulemaking (NPRM) (FCC 08-278) to establish rules for replacement 
digital low power translator stations. Since the analog shutdown is less than 
two months away, it isn't surprising the comment period is only 10 days after 
publication in the Federal Register with reply comments due only 10 days after 
the comment period ends.
The comment period isn't the only thing accelerated in this NPRM. Licensees 
would have only six-months to build out the replacement DTV translators after 
the CPs were granted. In the case of mutually exclusive applications, 
applicants would have 10 days to settle or find an engineering solution; 
otherwise the winner would be determined by the FCC's broadcast competitive 
bidding rules. 
The NPRM proposes limiting the service area of the translator to a demonstrated 
loss area, but the FCC is open to allowing the replacement translator to 
nominally expand the full-service station's analog service area in order to 
fully cover the loss area. The FCC asked for comment on how to define this “de 
minimis” expansion area.
Replacement DTV translators would be secondary to full-service TV stations, 
certain land-mobile radio operations and other primary services. However, for 
application processing, replacement DTV translator applications would take 
priority over all other secondary applications except LPTV displacement 
applications, which would have equal priority.
Replacement DTV translators would be allowed on Channels 2-59, although 
applicants proposing use of Channels 52-59 would have to demonstrate that no 
in-core channel was available.
Unlike current translators, replacement DTV translator licenses cannot be 
separated from the full-service station license. The NPRM states, “The license 
for the replacement digital television translator will be associated with the 
full power station’s main license and may not be separately assigned or 
transferred and will be renewed with the full-service station’s main license.” 
One option for stations wanting to take advantage of the rules would be to use 
their current analog channel or the analog channel of another broadcaster in 
the market for the digital replacement translator. For this reason, the FCC 
should consider whether it is appropriate to allow current LPTV stations, 
especially Class A stations which have primary status, to apply for these not 
yet vacant full service analog channels until full-service stations have had an 
opportunity to use these channels to maintain service to analog viewers unable 
to receive their post-transition DTV channel.
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