Does this plan call for the removal of all Channel 5 and 6 TV stations?
Not all stations. All full-service and Class A TV stations are considered primary and will be protected in the plan. LPTV, TV translator and digital replacement translators are secondary services and could be impacted and can only be displaced by full-service FM operations. LPFM and FM translator stations cannot displace a secondary TV station. The plan calls for full-service FM stations to go into the Channel 6 spectrum unless it is an "exclusion zone" for TV Channel 6. In those cases, full-service FM stations would be placed in Channel 5 spectrum, unless it is also in an exclusion zone for Channel 5.
What is an exclusion zone?
In the plan, the exclusion zone is an area where full-service FM stations cannot be placed on a particular channel. In areas that are outside of a Channel 6 exclusion zone, Channel 6 spectrum will be used for full-service FM stations. In areas inside of Channel 6 exclusion zones but outside of Channel 5 exclusion zones, the Channel 5 spectrum will be used for full-service FM stations. In areas that are within both exclusion zones, no full-service FM stations would be available. The exclusion zone is defined as the 26 dBu F(50, 10) interfering contour of the full-service or Class A TV station facility, and then extended another 5.636 kilometers from that contour (5.636 km is the minimum 60 dBu contour for a nondirectional minimum Class A FM station operating at 100 watts at 30 meters HAAT).
How will a full-service FM station protect a full-service or Class A TV station?
We will use the industry standard 2 dB D/U ratio for analog into digital protection. Full service FM stations operating on 83.1~86.9 and 87.7 MHz would be required to not overlap a 26 dBu F(50,10) interfering contour into the 28 dBu F(50,90) noise limited contour of the protected Channel 6 TV station. Likewise with 77.1~80.9 MHz in respect to Channel 5.
Can a secondary service like LPFM be able to operate from inside an exclusion zone?
Yes. The exclusion zones are designed for primary to primary where both inward and outward interference protection is required. LPFM and other secondary facilities will be required to protect full-service and Class A TV facilities as well as LPTV, TV translator and DRT stations that have not been displaced by a full-service station. Like with full-service, they will use the 2 dB D/U ratio analog to digital standard and must maintain a 26 dBu F(50,10) interfering contour outside of the 28 dBu F(50,90) noise limited contour of the TV station.
Which LPTV stations would be displaced under this plan?
Most Channel 6 LPTV (translator, DRT) stations will be impacted this plan as their spectrum will be used by primary FM stations. Channel 5 LPTV stations would only be displaced in those areas that would be impacted by full-service FM stations operating inside of Channel 6 exclusion zones. Channel 5 LPTV stations in all other areas will be protected by LPFM and other secondary stations.
We are a Channel 5 LPTV station that would not be displaced by full-service FM, and we noticed the plan calls for LPFM/translator stations to have access to both Channels 5 and 6. How will this impact us?
In this case, LPFM/secondary stations would not be allowed to use Channel 5 spectrum as they would have to place a 2 dB D/U ratio to the LPTV station which cannot be achieved when the LPFM/secondary station is located inside the LPTV's noise limited contour.
How will an LPFM station protect a TV station?
As part of the simplified rules, a 100-watt LPFM station wishing to operate on the same channel as the TV station would be allowed if they are at least 205 km from the full-service TV station or 165 km from a LPTV station without any additional studies required. LPFMs wishing to operate less than 205 km/165 km from a TV facility must include an engineering study to demonstrate that the 26 dBu interfering contour of the LPFM will not overlap the 28 dBu noise limited contour of the TV facility. For determining these radii, we take into consideration the standard distance of a worst case TV station's noise limited contour (based on 100 kW at 600m HAAT) and we include the standard distance to a LPFM's 26 dBu interfering contour and may pad in an extra kilometer or two. We do note that for many situations within the 205/165 km radius, the LPFM station would either have to run at a reduced ERP, use a directional antenna, or both. These can be expensive or impractical for some LPFM budgets. In addition, directional antennas for LPFM for the purpose of protecting a TV station will require a proof of performance/computer modeling for the antenna and a certification from a surveyor that the antenna was installed correctly. Again, these may be impractical for some LPFM budgets. LPFM stations will have access to most of the FM channels in the TV channel being used for full-service FM including access to LPFM-only channels in that band. On the channel not being used for full-service, LPFM stations will have access to most channels and FM translators would have 20 channels (again, subject to the protection of both primary and secondary TV facilities).
How will an FM Translator protect a TV station?
Under our plan, the same way LPFM stations do.
How will a TV station be required to protect an FM station?
Full service TV will only be required to protect full-service FM. Secondary TV will be required to protect both full-service and secondary FM. Protection from TV to FM is defined by a digital-into-analog 34 dB D/U ratio. This would mean that the 26 dBu F(50,10) interfering contour of the TV facility cannot overlap the 60 dBu F(50,50) service contour of the protected FM facility. Full-service and Class A TV will not be required to protect LPFM stations or FM translators.
If a full-service TV station makes a modification into an area where there are already LPFM/translator stations, how does FM displacement work?
A secondary LPFM/translator station will be considered subject for displacement if the full-service TV station modification results in the FM facility's 26 dBu interfering contour overlapping into the 35 dBu F(50,90) minimum field strength contour for community coverage. This is similar to a rule for full-service FM modifying towards an LPFM station. The LPFM/translator can be notified of the interference and be required to immediately cease broadcasting until a technical solution can be found (i.e. change transmitter site or move to a channel in the other band if available).
Will new TV stations be allowed in Channel 5 and 6 spectrum?
We are proposing a freeze on any new TV stations (full service and low power) as well as any modifications where Channel 5 or 6 is specified as the new channel. Existing channel 5 and 6 stations can modify on their own channels, except for channel changes from 5 to 6 or vice versa.
For WPVI, a major ABC affiliate in a top-10 market with major reception issues, FM radio stations near us could deeply impact the station. How far away from Philadelphia can FM stations operate on Channel 6?
For full-service, the nearest non-directional full service class C2 stations would likely be in Richmond, Virginia and Boston. Due to other Channel 6 TV stations, there is a lot of shielding of WPVI from the west. For secondary services, they would be available in the Baltimore/Washington and New York City areas, but with some massive restrictions regarding antenna directionality and antenna installation verification requirements. New York City LPFMs will also have access to Channel 5 without the antenna and verification requirements. Most LPFMs may not be able to meet or afford the antenna and verification requirements to operate on 6 in those areas.
