John J. Mullaney of Mullaney Engineering has filed an intriguing proposal with the FCC under the umbrella of MB Docket No. 87-268, Advance Television Systems and their Impact Upon Existing Television Broadcast Service. The basis of his testimony is that Channel 6, 82-88 MHz, is not particularly well-suited to television broadcasting and as such has been largely ignored by stations selecting their ultimate DTV home — only eight are asking for Channel 6 and only 38 of 302 located between Channels 2-6 are asking to remain in that band of spectrum. Mullaney says why not repurpose Channels 6 and 5 (76-82 MHz) to FM radio. He said you can fit 30 FM stations into the slot occupied by one television station, and the result would be "a staggering expansion of the existing FM band." It would allow grandfathered short-spacings to be eliminated; provide a migration point for challenged AM broadcasters; open the possibility of a digital-only FM band, upgrade the radio fleet of states like New Jersey which is currently hemmed in by major markets in neighboring states; enable contiguous channels for LPFM and translator use; open the possibility of a "pirate zone" where unlicensed operators can operate as long as they obey ERP and HAAT restrictions.
RBR/TVBR observation: We think this proposal speaks for itself. Our thanks to Garrison C. Cavell of engineering firm Cavell Mertz & Associates, who spotted this and brought it to our attention, and of course to Mullaney for posting it in the first place.