The Community Broadcasters Association urged the FCC to limit replacement translators to filling in coverage of full-power broadcasters and not allow such translators to expand their service area in comments filed this week.
The CBA called on the FCC to recognize that authorizing anything more will limit the chance for new Class A and LPTV entrants into the market and reduce the options existing Class A, LPTV and translator stations have in completing their DTV transition.
The association filed the comments on Jan. 12 regarding a Notice of Proposed Rulemaking released Dec. 23, 2008, examining how to implement replacement digital TV translator service. The aim of the rulemaking is to provide a way for full-power stations to continue providing service to viewers living in areas that will lose reception following the DTV transition.
In its filing, the association reiterated points it raised in a Dec. 17 letter to the commission regarding the rulemaking. Among the recommendations the CBA laid out in the letter are:
- Only full power TV stations should be allowed to apply for replacement translators, and those translators must only be used to translate their own full power primary station.
- Translators should only be allowed when it can be demonstrated that an on-channel booster or a distributed transmission system will not be effective.
- Serving areas beyond the primary station’s predicted noise-free digital service area or predicted Grade B analog service area should not be allowed.
- Translators authorized for this limited fill-in use should not be allowed to convert to LPTV operation.
The association also emphasized that the commission should not give replacement translator applications priority over Class A and LPTV displacement applications. According to the comments, “where the alternative is between enhancing a voice or silencing a voice, no voice should be silenced.”
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