THE MAY 29TH DEADLINE IS FAST APPROACHING TO QUALIFY YOUR ANALOG CLASS-A FOR THE AUCTION.  DO YOU NEED EQUIPMENT FINANCING FOR YOUR CLASS-A DIGITAL BUILD-OUT?  WE CAN HELP YOU FIGURE IT ALL OUT!

UPDATE FROM YESTERDAY'S STORY...

THE GRAY TELEVISION PROPOSAL TO THE FCC TO OPEN A CLASS-A WINDOW UNTIL THE END OF 2015 FOR THOSE LPTV LICENSEES WHICH CAN DEMONSTRATE SUBSTANTIAL LOCAL CONTENT DISTRIBUTION AND MAKE A COMMITMENT TO IT. 

1)  Gray's 100+ stations are all from markets 64 and above, and as such, their proposal is not reflective of the major market LPTV, where the channel leasing model is dominant.  So their proposal disadvantages many of the largest LPTV with the largest population coverages.  It can be said that the Gray proposal is counter productive to both the protection and enhancement of the public interest in sheer numbers of communities and people served (although in the Gray communities it will be served - is this a "gray area"?

2)  By having a short qualification period, and basing it on a calendar date, and not a "process date", Gray is dramatically limiting who, when, and where the qualification can be used.  The qualifying date should be linked to a date which is related to the auction and repacking itself.  If the Coalition backed the concept of a priority for the repack concept, which we at this time just do not, we would suggest that a Class-A window for repacking priority be just before the FCC runs the optimization model for the repacking, which will be some time 3 months post auction.  From today, this could be at the earliest 18 months from now.

3)  We think Gray is making a big miscalculation by looking to the past to gauge how they should protect their assets in the future.  No one ever thought Class-A status would be a qualifier for the auction and the huge windfall it would yield its users. (and shouldn't think will happen again in the future).  If we all knew that, we all would have become one.  Class-A was suppose to be about serving the community through a required public interest obligation, not as a way to make that windfall.  Gaining a primary status of protection was what it was suppose to be about (as Gray states is their intent).   But going forward post Incentive Auction, all remaining LPTV should have that protection, and not just those who can afford to quickly squeeze through an short window.  

4)  Our newsletter article about this issue was viewed over 1000 times already, and more than 200 readers wanted more information about it.  But only 14 of you actually took the survey we have posted.  This small number of respondents does however represent 12 existing Class-A's, more than 75 built and operating major market LD's, and over 200 new construction permits.  The total population count of these few but large respondents far exceeds 2X the Gray 29 million pop count of their 100+ stations.  

So we urge more of you to take the survey so that we can expand the sample size as see if the results so far continue as a trend or change.  We welcome any new ideas about how to help us all, and let's see if this one has the legs to get us to the finish line in this marathon. And again a hat's off to Gray for helping promote solutions for LPTV.

Current Results (without the comments which are key, and we will share next week.)

PLEASE TAKE THE CLASS-A SURVEY

REMEMBER, IT IS ALL ABOUT WHO SHOULD GET A PRIORITY 

AND WHEN,  IN THE POST AUCTION CHANNEL REPACKING

SAVE LPTV RALLY SPONSOR & COALITION MEMBER

With over 150 years in combined development experience, Anywave is proving to be a world leader in the design and manufacture of broadcast transmission equipment.  We supply LPTV and TV translator stations throughout the country.

LPTV DDSA-QUALIFIED STATION BACKER ASKS  FOR  A PRIORITY IN THE POST AUCTION REPACK

from the letter...

"U.S. Television, LLC ("USTV") has participated in the above-referenced proceedings to defend the rights of low-power television stations identified by Congress in the LPTV Pilot Project Digital Data Services Act (the "DDSA"). The DDSA grants certain LPTV stations the right to use low-power TV spectrum to distribute two-way wireless data services, directing the FCC to maintain a pilot program that authorizes these stations to provide such services to viewers in their services areas. 

USTV has advocated in this proceeding that the FCC must follow Congress's directive in the DDSA by ensuring that all stations covered by the DDSA have first priority access to displacement channels during the TV spectrum repack that will follow the upcoming TV broadcast incentive auction.2 In previous filings, USTV has emphasized that granting the requested priority will not restrict the FCC's flexibility in the post-auction repack because the statute was designed to protect only thirteen (13) low-power television stations in the entire country. In fact, due to changes in circumstances for some stations since passage of the DDSA, as set forth on the attached summary, grant of the priority requested by USTV (and mandated by the DDSA) actually would require displacement priority for at most nine (9) low-power stations."  

read it all here...check out the charts of the licenses which have NEVER done anything with their unique status and opportunity...the Coalition has literally been the biggest backer of using the DDSA as a vehicle for all of the LPTV to gain flexible use status.  But we have filed comments into the LPTV NPRM challenging this blanket priority status, and we think that if any of these do not want to continue to have this status they should simply declare it so that others, which we know there is a long line of, would do build out systems.  

Build it out now or let someone else do it!

U.S. Television, LLC ("USTV") LETTER

DDSA FCC ORDER FROM 2001