On May 29, 2024, the Advanced Television Broadcasting Alliance (ATBA) filed an ex parte letter with the Federal Communications Commission (FCC), addressing the Draft Notice of Proposed Rulemaking (NPRM) concerning political programming and online public file requirements for Low Power Television (LPTV) stations. The letter, submitted by ATBA Executive Director Lee Miller, outlines critical considerations and requests for additional questions to be included in the NPRM to ensure a comprehensive review of the issues affecting LPTV stations.
Key Points from the Ex Parte Letter
Recognition of LPTV Service: ATBA commends the FCC for acknowledging that LPTV stations are a vital part of the nation’s television service. The letter emphasizes that LPTV stations have consistently provided “needed and meaningful service” with minimal regulation, which has been in the public interest.
Community of License Designations: The FCC’s Draft NPRM proposes to formalize the community of license designation process for LPTV stations. However, ATBA questions the necessity of this requirement, given the limited service contours and relocation restrictions for these stations. The letter requests the FCC to consider whether eliminating community of license designations could reduce administrative burdens without impacting service quality.
Channel Sharing Rules: ATBA highlights concerns about the current interpretation of channel sharing rules, which prevent LPTV stations that have opted for channel sharing from reverting to their own channels. The letter argues that this restrictive approach lacks justification and calls for flexibility to allow stations to move back to full channels if available.
30-Mile Relocation Rule: The FCC’s existing 30-mile rule for displacement and minor change applications is also scrutinized. ATBA urges the Commission to reevaluate whether this distance limit remains appropriate and to explore alternative methods to prevent major site relocations without relying solely on mileage-based limits.
Maximum Power Levels: Additionally, ATBA suggests that the FCC review the maximum power levels of 3 kilowatts for VHF stations and 15 kilowatts for UHF stations to determine if these limits are still suitable.
ATBA’s Requests to the FCC
ATBA’s letter requests the inclusion of several key questions in the NPRM to develop a complete record:
- Community of License Necessity: Should Class A, LPTV, and TV Translator stations have a designated community of license?
- Impact of Eliminating Community of License: What would be the effect of eliminating these designations?
- Channel Sharing Flexibility: Should the rules be amended to allow stations to revert from channel sharing to having their own channel?
- 30-Mile Rule Reevaluation: Is the 30-mile limit still necessary, and are there better ways to achieve the goal of preventing major site relocations?
- Power Levels: Are the current maximum power levels for VHF and UHF stations appropriate?
ATBA appreciates the FCC’s ongoing support of the LPTV community and values the opportunity to contribute to the policy-making process. The ex parte letter reflects ATBA’s commitment to ensuring that regulatory changes benefit the LPTV industry and its viewers.
For more information and to stay updated on this and other advocacy efforts, please visit our website or contact the ATBA office.
