curmudgeonThis is a tale of two cities and a case of monumentally stupid broadcast regulation by the FCC that has afflicted their region of the country.  The story in Part I will make a small point, but one which has larger ramifications that will be developed in Part II.

The Curmudgeon lives in a mid-sized city, an amiable-enough place that we will call Pleasantville.   Pleasantville has its own full complement of local broadcast media, AM and FM radio plus broadcast television (as well as the usual cable and Internet distribution, local newspapers and magazines, etc.).  Pleasantville’s long-established broadcast media are about average in quality, no better and no worse than those in comparably-sized cities.

Pleasantville lies about one hundred miles from the center of a very large city, one of the “top 5″ in population in the United States, a metropolis which we will call Gotham City.  Gotham City is the center of an entire geographical region, with a total regional population more than fifteen times larger than Pleasantville itself.  Gotham City does have major broadcast outlets (typically, network-owned) which, within their daily programming, do a good job of covering both its local news and regional events.   While the Curmudgeon doesn’t often travel into Gotham City, he does have family and friends living there, and for that reason news from Gotham City is of more than passing interest to him.

By virtue of favorable topography and atmospheric conditions, it has always been possible to receive many of Gotham City’s broadcast outlets at the Curmudgeon’s home.  AM radio reception, of course, doesn’t need any special help, but with good quality, properly installed outdoor receiving antennas, the Curmudgeon has historically received good service from a number of Gotham City’s FM and television stations on many days of the year.

And so the situation stood in the “good old days,” before the FCC’s Media Bureau poked its witless paws into the long-standing regional allocation of TV station assignments.  In the days of analog (NTSC) television Gotham City had a full complement of VHF TV channel assignments as well as many other UHFs, and Pleasantville had its own several VHFs and UHFs, mostly network-affiliates.  Generally the regional raster of channels was such that stations from the two cities (and elsewhere) didn’t interfere with each other, and many of Pleasantville’s residents could receive both sets of stations.  There was a similar situation with FM radio, as at least some of Gotham City’s high power stations provided usable coverage out to Pleasantville, whose residents could enjoy the best of both radio worlds.

Enter the transition to digital television (ATSC) in 2009.  Immediately Gotham City’s “low band” television licensees (i.e., Channels 2 through 6) abandoned their analog VHF assignments and set up permanent digital camps on UHF (the engineering behind ATSC strongly argues for doing just this).  That cut the total number of Gotham City’s VHF TV allocations, the very ones most receivable in Pleasantville, almost in half, and presented Pleasantville’s residents with fewer possible choices for service from Gotham City (note that Pleasantville’s cable TV operators do not carry any of Gotham City’s stations).  And more “consumer choice” in the free marketplace is good, isn’t it?  But this was still not a problem worthy of much attention.

However a dark cloud soon began to float in the broadcast air above Pleasantville.  As part of the “DTV transition,” the FCC also reduced the total amount of spectrum allocated to TV broadcasting (“Honey, I shrank the band!”).  This was done to provide a new spectrum allocation for the Public Safety “700 MHz band,” to be specifically dedicated to a nationwide, integrated, interoperable dispatch radio network, a network that might yet actually be constructed and put into service sometime within the next two decades!

But one little Pleasantville UHF Low Power TV (LPTV) analog station, we’ll call it WT(i)NY-LP, was faced with an immediate problem.  WTNY was then operating on a high numbered UHF channel which lay within the soon-to-be 700 MHz band that was being cleared for Public Safety.  The LPTV was on the air then with very low power and with a service area of perhaps five miles in radius; the Curmudgeon could not receive it across town.  However, now WTNY would have to take a new channel assignment, lower in the UHF band, and move.

WTNY did use the opportunity to propose a change of its transmitter location to a higher-elevation site as it filed with the FCC for a “displacement channel” within the (now smaller) UHF band.  Clearly it wanted to re-use as much of its existing transmitter plant as possible.  But the cretinous automatons in the Media Bureau, toiling in their anoxic, windowless cubicles in Washington, D.C. had “a better idea!”  Although these Gov’mint life forms live and work far away from the Gotham City region, they could, of course, apply their hugely superior collective intelligence to create a masterful solution to this straightforward pending action.

Big brother knocks out local TV reception
Big brother knocks out local TV reception

The Media Bureau mollusks ultimately acted, but WTNY did not get its expected UHF displacement channel.  Instead it received a low-powered VHF-TV assignment, co-channel with a Gotham City high-band, network owned-and-operated, regional-coverage digital station!  We’ll call that station WBIG-DT.

“Informed sources” (not as yet confirmed) have said that the owners of WTNY had not themselves requested a VHF displacement channel, but they received one anyway!  The key point here is not whether the LPTV itself had made the original choice of a VHF channel, but rather that the Media Bureau approved the assignment in the face of the existing regional channel raster.  Twenty years earlier, the same Media Bureau had, in fact, rejected an almost identical proposal involving re-using many of Gotham City’s active VHF channels for LPTV service in Pleasantville.

The network owner of WBIG appealed the Media Bureau’s decision, and the appeal included an engineering analysis showing that WBIG’s authorized signal coverage (service) area would be infringed by the new WTNY-LP co-channel assignment.  And the Media Bureau actually agreed with the network that infringement would occur.  WTNY countered that initial decision with some kind of engineering presentation that showed that “terrain shielding” would somehow protect WBIG’s authorized coverage.  (The Curmudgeon, who understands regional VHF propagation quite well, strongly doubts this.)  The Media Bureau then said, “That’s sufficient proof for us,” and made the final assignment on VHF.  And that blunder brings on two (and quite possibly three) new problems that are paralleled by zero discernable benefits!

First, WTNY, a financially marginal operation at best, has had to purchase and to install a VHF transmitter plant, completely new from the master crystal oscillator through to the antenna.  This certainly did not help their overall financial viability.  But somehow they have managed to do this, and they are on the air in test mode now.

Second, a strong possibility exists that the new operation of WTNY in Pleasantville will destroy the existing reception of WBIG there.  And this has already begun; the Curmudgeon notes considerably impaired reception of WBIG when co-channel WTNY is on-air.  The puny analog signal from WTNY (with its 3 kW ERP at twenty miles distance) is too weak most of the time to provide a usable picture at the Curmudgeon’s house, but it is still strong enough to severely degrade reception of the otherwise usable co-channel digital WBIG signal from Gotham City.  Where once one station on this VHF channel provided good, usable service, now there are two stations providing a total of no usable service!  Thus there are no service benefits at all accruing from this assignment!  Consumer choices have been reduced not increased.   Brilliant, Media Bureau, absolutely brilliant!

The third (at least potential) problem is that there are several more of Gotham City’s high-band digital TV channels that are now “ripe for the picking!” by Pleasantville’s cadre of LPTV broadcasters and associated wannabees.  Soon enough under the aegis of an “inspired” Media Bureau these channels too will fall, and Pleasantville will be entirely “cut off” from service by Gotham City’s major stations.  By promoting “choice,” the Media Bureau has magnificently restricted viewer choice!

The situation on the FM radio band is really not much different.  The same Media Bureau “advanced thinkers” have allocated a number of Low Powered FM or FM translator stations on just about any (ostensibly) vacant channel in and around Pleasantville.  These are either co- or adjacent-channel to the major Gotham City outlets.  While few people listen to these flea-powered local “stations,” the LPFMs’ and translators’ local signals have systematically blocked reception of many of the major Gotham City FM stations and Pleasantville is largely isolated on FM as well.

The FCC apparently looks at this broadcast channel allocation scheme as simply “just an abstract task involved with filling in the missing pieces in the jig saw puzzle,” It must be only a sterile, academic exercise to them (with ever-constant political overlays as well, of course), entirely divorced from any considerations of citizens’ needs.  But it has real ramifications for the citizens of Pleasantville and all the other mid-sized and smaller cities that exist within larger regional matrices.  Next time we’ll look at those practical ramifications and at the larger considerations of broadcast channel allocation policy.

What do you think?

“Let’s keep the universe safe for RF!”

The Old RF Curmudgeon

About The Author

LBA Group, Inc. has 60 years of experience in providing RF asset solutions and risk management for industrial and telecommunications infrastructure assets. The group is comprised of LBA Technology, a leading manufacturer and integrator of radio frequency systems, lightning protection and EMC equipment for broadcast, industrial and government users worldwide; the professional consultancy Lawrence Behr Associates and LBA University, providing on-site and online professional training. The companies are based in Greenville, N.C., USA.

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