The FCC’s proposal to expand the use of Distributed Transmission Systems by television stations operating with the new ATSC 3.0 transmission system was published in the Federal Register today (here). That publication announces that the comment deadlines on the FCC’s DTS Notice of Proposed Rulemaking are due by Friday, June 12, 2020, and reply comments will be due by Monday, July 13, 2020. While we mentioned this proposal in passing when discussing a proposal to allow FM stations to use boosters to provide an FM version of a distributed transmission system, we have not written in detail about this proposal. With the comment deadline now set, let’s look at some of the questions asked in the rulemaking proposal.
First, it is worth explaining the concept of a distributed transmission system (sometimes referred to as a “single frequency network” as it uses multiple stations on the same frequency to reach its audience). Traditionally, television stations have operated with a single high-power transmitter from a location central to their coverage area. Thus, viewers close to the transmitter get the strongest signal, and that signal dissipates the further that a viewer gets from that central transmitter site. Station signals are protected from interference to a certain contour where it is assumed that the majority of viewers will be able to receive over-the-air an acceptable signal most of the time. But even at the edge of these protected contours, the FCC’s projections assume that many viewers will not be able to receive an acceptable signal at all times. Distributed transmission systems are already in use by television stations in certain markets to fill in holes in station coverage – and have been particularly useful in markets with irregular terrain where mountains or other obstructions preclude one centrally located transmitter from reaching audiences far from the transmitter site. Locating a second transmitter on the same frequency behind the terrain obstruction allows better reception for viewers who might otherwise not receive an acceptable over-the-air signal. However, currently, the DTS transmitters cannot extend the noise-limited protected contour of a station “more than a minimal amount” beyond that which the TV station would be predicted to have from a single centrally-located transmitter site. The NPRM in this proceeding, based on a petition filed by the NAB and America’s Public Television Stations (see our article here on the Petition for Rulemaking filed by these groups), looks to allow for wider use of DTS.
Continue Reading Comments Due June 12 on Proposal to Expand the Use of Distributed Transmission Systems by TV Stations Operating with ATSC 3.0 Transmission Systems – What is Being Asked?