deadlines established for comments on proposed digital transition deadline for Analog Class A, LPTV and TV Translator Stations Comments due:  December 17, 2010 Reply Comments Due:  January 18, 2011
As we recently reported here, the FCC is seeking comments on proposed deadlines and procedures for Class A, low power television (“LPTV”) and TV translator stations (collectively, “low power television stations”) to cease over-the-air analog broadcasting and transition to digital operations.  Notice of this proceeding has been published in the Federal Register, establishing December 17, 2010 as the deadline for filing comments and January 18, 2011 as the deadline for filing reply comments. Among the issues being considered in the proceeding are: Whether a 2012 deadline should be established by which all low power television stations would be required to terminate analog service – or whether it would be more appropriate to establish an analog termination deadline by the end of 2015 or after the reallocation of spectrum from the broadcast TV band recommended in the FCC’s National Broadband Plan is complete. Whether “out-of-core” stations operating in the 700 MHz band (channels 52-69) should be required to terminate all operations, analog and digital, by December 31, 2011 so that commercial wireless and public safety entities can continue to deploy their services in that spectrum. Whether the construction permit for an unbuilt digital companion channel should be forfeited if the paired, unbuilt analog construction permit has expired. The treatment to be afforded to a constructed digital companion channel station where the construction permit for the paired unbuilt analog station has expired. A proposal to modify the definition of a “minor change” for low power television stations to permit transmitter site location changes of no more than 30 miles (48 km). Whether to evaluate proposed digital low power television facilities using actual vertical antenna patterns instead of assumed vertical antenna patterns, which may differ substantially from actual vertical patterns. Whether the current power levels and interference protection criteria for digital low power television stations are appropriate to ensure that post-transition service will be of an estimable quality, and if not, what modifications are needed. Whether to adopt rules allowing the use of full power DTV emission masks by low power television stations. Proposed procedures for Class A stations to secure primary, protected status on their final digital channels. Whether digital low power television stations operating pursuant to an STA or other authorization should be required to pay an annual fee of 5% of the station’s gross revenue received from any subscription-based ancillary and supplementary services it provides. If you have any questions concerning the proposed deadlines and procedures for the low power television station digital transition, or wish to file comments in this proceeding, please contact your primary attorney in this office. November 5, 2010
This memorandum is intended only as a general discussion of these issues and should not be regarded as legal advice. We would be pleased to provide additional details or advice about specific situations if desired. Copyright © 2010, Lerman Senter PLLC 2000 K Street NW, Suite 600 | Washington, DC 20006-1809 tel. 202.429.8970 | fax 202.293.7783 | www.lermansenter.com To Unsubscribe: Unsubscribe  |   To Update Client Info: Update Client Info