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Graham Brock, Inc. |
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Broadcast Technical Consultants |
| Vol. XIV, No. 7 |
R. Stuart Graham, Jr. |
| July 2007 |
Jefferson G. Brock |
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Several months ago we noted that the FCC was accepting
comments on the final DTV Table for TV Allotments and
post transition requests for changes as part of its
periodic review. The Notice has now been published in
the Federal Register. Comments in MB Docket 07-91 are
due by August 8, 2007 with reply comments due by August
23, 2007. You can view the proposal in this proceeding
at the Commission’s website, www.fcc.gov. |
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Non-Commercial Window in October |
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As we reported several months ago, the FCC announced
the opening of a window for non-commercial
applications in the reserved band (Channels 201-220;
88.1 MHz through 91.9 MHz) from October 12 -19,
2007. While there has been no official announcement,
it is anticipated that a freeze of the submission of
minor change applications (including city of license
change applications) will be announced in advance of
the window. We cannot speculate on the duration of
the freeze, but it could be as long as 30 days. This
freeze will allow the FCC’s database to be updated
in order for potential applicants to verify the
proposals will not conflict with any previously
filed minor change applications. For those parties
who have already identified possible channels, these
channels should be reviewed again after the freeze
begins to verify the channels are still viable. |
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Has this happened to you? You receive a Prior
Coordination Notification (PCN) from a nearby
broadcaster indicating they are proposing a
change to one of their stations’ STL systems. A
change in frequency could put the competitor on
the same frequency as your STL system, and the
potential for interference is great. While you
are operating on this frequency, your STL
license shows a completely different frequency
and is licensed at a location removed from your
present site. Time to punt. While you can
contact the party requesting the change in
frequency and request they move to different
frequency, they may not be accommodating. It is
possible this is the only viable frequency for
the path. In order to protect your STL system
from changes that may have a detrimental effect,
you need to take action before this can happen.
Unfortunately, there are many broadcasters in
this position. Studio and ownership changes over
the years have left many STL systems at the
wrong location and on the wrong frequency.
Occupying the frequency, even when local
coordination was done years ago, does not
protect your system if the license is incorrect
or non-existent. Using the latest FCC
rules, a frequency analysis is needed to
determine if the existing/proposed system would
have an adverse impact to other nearby systems.
If the frequency you are operating on cannot be
used, it may be possible to seek coordination on
a local level, but local coordination alone
cannot be used, unless the local coordinator can
accurately review all systems and frequencies.
Once a frequency is identified, a Prior
Coordination Notice for your proposal must be
sent to all potentially impacted stations within
a 125 mile radius (250 miles in the direction
your system’s antenna is pointed). If there are
no responses from the PCN within 30 days, an
application can be submitted to the FCC. You may
then commence operation with the proposed system
while the FCC processes your application. At
this point, your system will be protected, since
your STL’s operating parameters will be
correctly reflected in the FCC’s database. After
the system is granted a license, you have 18
months to notify the FCC that the system is
operational; if not, the permit is cancelled,
and you are once again not protected. |
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What Would You Like to See? |
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If you have a suggestion of a topic for an
upcoming newsletter, just send us a note or
email. Also, if you would like to receive the
newsletter via email, rather than postal service
delivery, please send an email to cathy@grahambrock.com. |
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