[opendtv] Re: Doug Lung on digital replacement translators

  • From: "John Willkie" <johnwillkie@xxxxxxxxxxxxx>
  • To: <opendtv@xxxxxxxxxxxxx>
  • Date: Thu, 25 Dec 2008 21:32:33 -0800

I tend to get tired over trying to move you from absurd positions.  This
isn't about flash cutting any translator.  It's about using NEW translators
to replicate any missing coverage areas after the transition to digital.

Note the word "REPLACEMENT."  As in replacement translator.

The OWNER of the TRANSLATOR in almost all circumstances, is the OWNER of the
full service station.  Indeed, the replacement NPRM talks about -- for the
first time -- associating the replacement translator with the main station's
license.  Actually, this would be something that has only happened with
auxilarry stations, and only before about 1964.

This is my second attempt at trying to get you to understand this NPRM.

John Willkie

-----Mensaje original-----
De: opendtv-bounce@xxxxxxxxxxxxx [mailto:opendtv-bounce@xxxxxxxxxxxxx] En
nombre de Albert Manfredi
Enviado el: Thursday, December 25, 2008 3:04 PM
Para: opendtv@xxxxxxxxxxxxx
Asunto: [opendtv] Doug Lung on digital replacement translators

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 coverage.
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.
It's the same HotmailR. If by "same" you mean up to 70% faster.
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