It’s time to drop radio’s protections for TV Channel 6 and re-purpose that spectrum to the FM band. So says engineering consultant John Mullaney.
In a filing to the FCC for MB Docket 87-268, “Advanced Television Systems and Their Impact Upon the Existing Television Broadcast Service,” Mullaney says adding 82 to 88 MHz to the bottom of the FM band would ease overcrowding; the time is also right for the agency to decide if TV Channel 5 should be reallocated to radio as well, he said.
“The assumptions that Channels 2–6 are technically equal to the remaining Channels 7–51 has proved not to be totally accurate,” says Mullaney in the filing.
“We believe the problems associated with impulse noise and greater difficulty in compensating for signal cancellations are some of the major reasons why there are only 38 potential [TV] digital allotments under consideration while there are currently 302 analog full-service analog allotments.”
Because only eight digital allotments are proposed for TV Channel 6, Mullaney believes, based upon this “extreme underutilization of TV 6, the commission could also consider a shared use of the channel but limit the sharing to just those full-service digital TV allotments currently under consideration.”
Many of the recently filed NCE applications for radio allocations either ignored Channel 6 protection or curtailed their proposed power levels to protect those analog channels, he said.
The thousands of applications filed in the recent window, as well as more than 14,000 applications filed in the 2003 FM translator window, demonstrates pent-up-demand for FM spectrum, he argues.
One allocation for a TV channel could be used for up to 30 FM radio stations; such additions could go a long way towards easing short-spacing conditions on the FM band, he states.