Thursday, May 27, 2010

Analog LPTV Stations

We have just returned from the National Translator Convention, where members of the FCC urged LPTV and translator station owners who operate analog-only facilities to apply for digital operation either on the present channel (“flashcut”), file for a digital companion channel (which would allow both analog and digital operation for the time being), or a displacement application specifying operation on a new in-core channel (Channels 2 – 51). There are three reasons to consider submitting such an application to the FCC as soon as possible. First, large numbers of applications for new facilities in rural markets are being filed every day. These filings, once granted, will reduce the available spectrum for flashcut, companion channel and displacement proposals from existing analog stations. Second, the Commission is going to open a filing window for the major television markets in July. It is expected that a significant number of applications will be filed at that time. While an existing analog station might not be located in such a market, any application for a new LPTV facility that will be located within 70 miles or so of the existing analog facility could preclude consideration of that channel for flashcut, companion channel or displacement purposes. Third, the FCC has indicated that it may soon set a hard deadline for translators and LPTV stations to cease analog operation.

For all of the above reasons, analog stations should consider filing a digital application with the FCC sooner rather than later. Once granted, the station will have three years to construct the digital facility. Two 6-month extensions of the construction deadline can also be requested of the Commission.

It is also important to note that, if the station meets certain rural coverage requirements, it may be eligible for reimbursement of a significant portion of the digital construction costs by the NTIA. More information on that program is located on the NTIA web site (

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