The Association of Maximum Service Television (MSTV) and the National Association of Broadcasters (NAB) have filed comments in the FCC's Notice of Proposed Rule Making to establish rules for digital television translator, booster and LPTV stations and amend rules for digital Class A television stations. NAB and MSTV are strongly opposed to granting any second channels to existing television translator, LPTV and Class A stations. The comments note that section 336(f)(4) of the Communications act makes it clear the FCC "is under no obligation to award a second digital channel to Class A, LPTV or translator stations during the transition." The comments do allow, however, that the commission should permit these stations to transition on channel, providing technical rules for the low power/translator services are strengthened.
According to MSTV and NAB, the commission's technical proposals to protect the digital broadcast facilities of full service stations from the operations of digital Class A, LPTV and translator stations are inadequate. "Many of the proposals advocate further erosion of protections afforded under the existing analog rules," the associations said in their comments. "The tolerances the commission affords in the analog world are not adequate for the digital world, and technical requirements adopted in this proceeding should take into account the new environment."
The comments indicated existing interference standards may need to be revised and stated the commission "should not rely solely on the D/U ratios proposed in the Notice to evaluate applications from secondary service providers because they are inadequate for protecting full service stations." The comments explain that the D/U ratios used in the DTV Table of Allotments "were based on limited and incomplete data" and a single prototype DTV receiver, noting that broadcast and consumer electronics industries are actively working to recommend receiver performance standards that will help to refine the initial D/U ratios. "Six years worth of laboratory and field trials have confirmed that today's commercial receivers do not achieve the performance measured with the initial prototype receiver."
MSTV/NAB insist any DTV service by LPTV or translator stations has to be secondary to full service stations and, as a secondary service, interference from these stations to full service stations has to be treated differently than interference between full service stations. MSTV and NAB proposed that co-channel and first adjacent channel Digital Class A, LPTV or translator stations not be permitted to locate their transmitter inside the noise-limited contour of the full power station. Other spacing rules would apply to Digital Class A, LPTV or translator stations operating on a UHF channel two, three, four, seven, or eight channels removed from a full power analog or digital station or operating on a UHF channel fourteen or fifteen channels above a full power analog or digital station.
The comments also insisted that LPTV stations "should be held to the same transmission standards as full power stations and equipment certification requirements should be the same as for full power stations because of the potential for interference, particularly adjacent channel interference."
The MSTV/NAB comments also cover less technical issues such as interference agreements between stations -- they shouldn't be permitted for digital LPTV -- and service rules for digital Class A, LPTV and translator stations. Analog rules "should flow through to the digital world, except where technology or the requirements of the digital transition indicate a difference," the associations said. Use of broadcast auxiliary spectrum, special status for noncommercial stations and two-way services are also addressed.
The MSTV and NAB Comments are 28 pages long and address DTV transition issues critical to full service stations as well as operators of LPTV, translator and Class A stations. DTV boosters and on-channel repeaters were not addressed in the comments, except to say that the FCC's efforts should be focused on establishing rules for distributed transmission systems instead of creating a new class of service for low power on-channel boosters.
