On Friday, the Commission released a Further Notice of Proposed Rule Making (FNPRM) seeking input on completing the transition of all low power television stations (LPTV) and TV translator stations to digital operations. Driven by the transition of all full power TV stations last year and the guidance from the National Broadband Plan, which recommended setting a deadline of 2015 for the transition of LPTVs to digital in order to increase efficiency in the TV bands and assist in the reallocation of those bands, the Commission’s rulemaking turns to the remaining analog television operations in the spectrum, i.e. LPTV and TV translator stations. The Commission, having noted a significant increase in the past year of LPTV stations obtaining authority for, and actually switching to, DTV operations, concludes that "low power television stations should now begin to focus their time and resources on developing and implementing a digital conversion plan."
In response to the main question of "when?", the Commission suggests a date in 2012 as the hard date by which all LPTVs and TV translators would have to complete the construction of digital facilities and cease analog operations. While a specific date in 2012 is not offered, the Commission believes that three years after the June 12, 2009 full power transition should be a sufficient time period for completing the transition. And of course, given that it is now September 2010, that really means that LPTV stations would have between 15 and 27 months from today to complete the transition. The FNPRM does seek comment on alternative time frames or transition mechanisms, but notes that an adoption of an earlier transition date in 2012 might adversely impact some LPTV stations, which could "transition to digital only to find that their digital channel is no longer available as a result of the spectrum reallocation that is one of the recommendations in the Broadband Plan." Such stations would then be forced to transition a second time. Given that the Commission has not yet actually commenced a proceeding to implement the spectrum reallocation recommended in the Broadband Plan, this comment is a bit troubling. Clearly, if the Commission is actually going to reallocate the spectrum as suggested in the National Broadband Plan, it should do so first before it mandates a DTV transition for LPTVs. Or at the very least, it shouldn’t mandate such a transition until it can ensure that LPTV stations are transitioning to digital on a channel that won’t subsequently be reclaimed and re-purposed for a competing wireless broadband operation. In acknowledgment of this, the FNPRM seeks comment on whether the analog termination date should be by the end of 2015 or after the "recommended reallocation of spectrum from the broadcast TV bands".