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Nevada Broadcasters Association

In January, the FCC adopted new rules for Distributed Transmission Systems (DTS) for TV broadcasters (the FCC’s order is available here).  Last week, the rules were published in the Federal Register, setting the effective dates of these new rules as May 24, 2021 (except as they apply to Class A TV, LPTV and TV translators, where new rules are subject to further review by the Office of Management and Budget under the Paperwork Reduction Act before they become effective).  The FCC yesterday released a Public Notice confirming that effective date.  The new rules for DTS will allow over-the-air TV broadcasters to provide stronger, more uniform coverage throughout their service areas, rather than having coverage strongest near to a station’s transmitter site and decreasing as the distance to the viewer increases (or as terrain obstacles intervene).

DTS, also referred to as Single Frequency Networks, allow TV stations to, instead of having one large transmitter in the center of its market area, use multiple transmitters throughout the service area to provide more consistent coverage throughout the market.  The new ATSC 3.0, Next Gen television transmission standard that is being rolled out throughout the country was designed for this kind of operation. This transmission model is more akin to the operation of cellular telephone networks than to the old broadcast model.  ATSC 3.0 uses a transmission system in which multiple signals on the same channel that are receivable at the same location reinforce each other.  Older broadcast transmission systems face issues when trying to operate multiple transmitters on the same channel, as these transmitters can cause destructive interference in areas where their coverage overlaps, making coverage worse, not better  (see, for instance, the concerns about the proposals for the use of “zonecasting” for FM stations, where arguments have been raised that multiple FM same-channel boosters rebroadcasting a primary FM station will create pockets of interference within a station’s market – see our references to such comments in articles here, here, and here).  The new DTS rules allow TV broadcasters to take advantage of the new ATSC 3.0 transmission characteristics to provide uniform, strong signals throughout a station’s market, without the destructive interference.

Currently broadcasters can operate with DTS, but the signals from DTS transmitters must be restricted to the station’s existing protected contours.  DTS coverage outside the protected service contour, even if within the TV station’s designated Nielsen market, cannot be provided.  The new rules, however, provide broadcasters with a bright-line rule that will expand the permissible range of “spillover” by DTS facilities to areas outside of their current protected contours.  Specifically, the new rule will permit DTS transmitters to be located in any location so long as, for UHF stations, the 41 dBu F(50,50) contour for each DTS transmitter does not exceed the primary station’s current 41 dBu F(50,50) contour.  The relevant contours are 28 dBu for Low VHF stations and 36 dBu for High VHF stations.

The promise of ATSC 3.0 includes not only linear television programming but also enhanced data transmission capabilities.  Since   Next Gen TV allows for the transmission of data using standard Internet Protocols, the information transmitted can interact with all sorts of devices if the devices are designed to receive the new transmissions.  Stations using ATSC 3.0 will theoretically provide to smart devices everything from audio services to updates throughout a station’s service area.  The ability to provide such services to large areas through these Single Frequency Networks that reach entire markets is seen by the technology’s proponents as being far more efficient for many of these uses than the one-to-one Internet transmissions provided by other transmission systems.

While these rules will become effective in May, there still is a period for the filing of reconsideration petitions, and the Democratic commissioners still on the Commission expressed doubts in January about the adoption of this order and its potential impact on other spectrum users in these areas where greater coverage by television stations will be permitted (questions about that impact were raised in the Notice of Proposed Rulemaking that led to the rule changes – see our article here).  So, while the rules will become effective, it will be important to watch if there are future developments on this issue when all of the new Commissioners are in place.

Courtesy Broadcast Law Blog