(Obsolete) REC LPFM Advisory Letter #12 - Sunset of Analog Low Power TV Channel 6 Operations and Future Protection of Digital TV Channel 6 LPTV Stations (Updated 7/16/21)

This document was declared as obsolete on August 3, 2023.

July 13, 2021 was the final day for analog low power TV (LPTV) stations. A few LPTV stations in remote Alaskan villages were given authority to continue analog service until a time when those sites can be reached to convert to digital.

This also means that the so-called “Franken FM” (or “FM6”) stations (channel 6 LPTV stations that are using their audio carrier at 87.75 MHz to operate like an FM radio station) are also supposed to shut down.

Some FM6 stations remain on the air

The FCC has granted Special Temporary Authority to two FM6 stations operated by Venture Technologies Group in San Jose, CA and Chicago, IL to continue operating as a part of a test using the next generation ATSC3 technology.  The FCC has still not reached any different final decision on the future of Franken FM stations in MB Docket 03-185.  This is a proceeding that REC is closely watching.  On July 16, 2021, with LPTV stations converting to ATSC3, the FCC has granted more STAs to stations in Denver, Atlanta and Norfolk, VA to resume analog carriers on 87.7 FM.

Digital LPTV channel 6 stations must remain protected by LPFM

It is important to realize though that even though most of the FM6 stations were supposed to cut their analog carriers today, this does not mean these facilities no longer have to be protected by LPFM applicants seeking to operate in the reserved band (Channels 201~220, 88.1~91.9).  Many of these stations were given authorization to “flash cut” to digital on Channel 6 and are either currently off the air (as a silent station) or they have made the conversion to a digital television service.  In these cases, you will not hear a carrier on 87.7 and you will likely just hear static like if a station did not exist. 

Only if and when the FCC makes a Channel 6 LPTV license record “inactive” is it no longer eligible for protection.  You can use REC’s FCCdata.org website to check on the status of your local channel 6 LPTV station.  The Application Search on the FCC's LMS public access system is the most authoriative information.

How LPFM stations protect LPTV channel 6 stations

LPFM stations are required to protect LPTV channel 6 stations using minimum distance separation pursuant to §73.825 of the rules.  As per §73.825, the LPFM station can get a letter of consent from the LPTV channel 6 licensee to waive the distance separation requirements.  

In an arrangement negotiated by REC with the FCC, the Audio Division will also entertain waiver requests of §73.825 if it can be shown through a contour study that the LPFM station would not interfere based on the FM translator method in §74.1205.  In that case, the LPFM station would be required to send a notification to the LPTV licensee.  Concurrence is not required, but the LPTV station could object.  Note that if a directional antenna is needed to show this contour protection, the LPFM station will be required to include a proof of performance for the antenna and a certification from a licensed surveyor that the antenna was properly installed and oriented at the time when the LPFM station files their License to Cover application.

The “Frankies” may still come back.

There is still a chance that FM6 analog carriers may come back based on the outcome of MB Docket 03-185.  But even if the station is now digital and has no aspiration to operate an analog FM service, they must still be protected by LPFM stations.

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Original version published July 14, 2021.

First revision July 16, 2021.  Obsolete August 3, 2023.