Full power stations will soon be ending a turbulent journey — their transition to digital operations. But there is a still often unrecognized group of broadcasters whose transition has not only been turbulent but may well become a hideous plane crash. Class A and LPTV stations make up 80% or more of the television broadcast facilities in America and most of these stations have not yet transitioned to digital. If the fact that the majority of TV stations in the country are still operating in analog, combined with the a government hell-bent on suggesting that June 12th will be the “end” of the digital television transition, is not frustrating enough, now Class A and LPTV broadcasters may be facing yet another massive challenge.
The CBA has been advised that the FCC is contemplating the creation of a rolling application filing window for new LPTV and TV translator stations. Such a window could impose a serious hardship on existing stations as they begin their transition to digital operations. The problems faced by existing stations are considerable, and we likely do not yet know their full scope, because the FCC has not yet even proposed, let alone adopted, final rules for a mandatory DTV transition for these stations. Some stations are likely to find that they cannot flash cut to digital on their existing channel without a significant reduction in coverage, so they will need time to find new channels. Class A stations were frozen from expanding their coverage for many years during the full power transition; and during that time, many LPTV stations, which were not frozen, moved in close and precluded Class A expansion. Further, distributed transmission systems, which may be essential for some LPTV facilities, may be difficult to implement without changing channels. And of course, any LPTV station can be displaced at any time by a new full power station, and some of our stations are likely to face that predicament in the future. Finally, non-displaced stations, or stations facing a shrunken flash cut digital service area, will not have time, and may not be able to command the financial and technical resources, to apply to move to abandoned full power analog channels before the “rolling window” opens, leaving them to compete with newcomers, including spectrum speculators, in seeking the best channels to serve their communities.
Many of our members are disturbed by the idea that existing full power stations were given a decade to find the best digital channels, while all changes in the service area of full power and Class A stations were frozen, but our stations will essentially be thrown into what could be an application maelstrom before they have time to settle into a permanent digital home. While there is nothing wrong with new people entering our industry, there is a strong case to be made that much more time than a month or two must be allowed for those who have endured application freezes, a cold shoulder on cable carriage, digital converter boxes that block their signals, displacement by full power stations, and many other disadvantages in the struggle to reach viewers.
The CBA will continue its fight to bring reason and logic to a digital TV transition which is now recognized by all as having been flawed and mismanaged from the start. Let us hope as the real DTV transition, one that includes all broadcast television stations and not just full power stations, continues to unfold, that our government will heed the suggestions of the CBA and will work to protect and not burden to the point of destruction the many small, often minority and woman owned businesses which currently operate Class A and LPTV stations.
The Government undertook three significant steps to help full power stations succeed in their transition: (1) Deployment of significant FCC resources to ensure a second channel for every station, to allow simultaneous analog and digital operation during the transition; (2) an opportunity for every station to apply to replicate its analog service area with its digital signal, including “fill-in” translators that have priority over all LPTV and TV translator applications; and (3) an opportunity for stations to maximize their service area so that smaller stations could expand their coverage to match the largest station in their market. None of those things have been done for LPTV stations. Only one companion channel application window was opened, over two years ago, with a prohibition on applicants changing channels to avoid conflicts that crippled the settlement process. No consideration has been made in giving priority to replication applications by existing LPTV stations.
Incumbent Class A and LPTV licensees must be enabled, through intelligent and well considered steps by the Government, to infuse even greater value to the incomplete and ongoing digital television transition in the United States. Any further failure to assist our industry in a meaningful way and the specter of an uncontrolled and unfair “rolling filling” window will likely further weaken, if not crush, an already beleaguered industry.
Vice President of Technology
Community Broadcasters Association