LPTV licensees do not wish to be mandated to convert facilities to ATSC 3.0. To start, LPTV stations are small business operations on very tight budgets. To mandate LPTV stations to convert to ATSC 3.0 is a financial hardship unless the FCC will subsidize the costs and distribute converter boxes so no viewer is left behind. Secondly, we strongly believe that TV broadcast facilities should be able to use any standard that best serves the public interest of their communities, be it ATSC 1.0, ATSC 3.0, or 5G Broadcast. 

In advance of the Incentive Auction and repacking, the Media Bureau in 2010 announced a freeze on applications for major changes to existing LPTV and TV translator stations.  Last summer, the Bureau lifted the major change freeze with respect to channel changes, and that window was a tremendous success in which more than 200 stations were able to change from low VHF to high VHF or UHF channels to better serve their communities.

But LPTV stations are still hamstrung by the artificial contraints imposed by the continuation of the FIFTEEN YEAR freeze on the relocation of facilities that are otherwise permissible under the following rules:   

74.787(b)(1)—LPTV/TV Translator major changes include: (ii) Any change in transmitting antenna location where the protected contour resulting from the changes does not overlap some portion of the protected contour of the authorized facilities of the existing station; or

(iii) Any change in transmitting antenna location of greater than 30 Miles (48 kilometers) from the reference coordinates of the existing station’s antenna location

73.3572(a)(2) )—Class A major changes include: (ii) Transmitting antenna location where the protected contour resulting from the change is not predicted to overlap any portion of the protected contour based on the station's authorized facilities. 

The LPTVBA respectfully requests that the Media Bureau open a window, pursuant to Section 74.787(a)(3) and Section 73.3572(d)(1), to permit LPTV and TV translators and Class A Television Stations to relocate existing station facilities in accordance with the major change rules.

The LPTVBA agrees with the Chairman that regulations must adapt to the changes in technology.  LPTV power limits were established over 30 years ago and reflecte the technology of the time. To place in perspective, AOL just rolled out emails and internet access in 1994. Broadcast technology has come a long way and the technology exists to allow LPTV/Class A stations to increase their power while keeping their signal within the licensed contour. This would result in much improved reception for consumers and/or first responders, definitely serving the best interest of the public.

We agree with Chairman Carr the Commisison has an obligation to modernize the broadcast regulatory regime to allow licensee to compete in in the current media marketplace. The LPTVBA supports many of the technical and ministerial rules changes proposed in the pending NPRM and looks forward to working with the Media Bureau to come to consensus. A separate ex parte letter will submitted to identify the items we support.

The LPTVBA appreciates the support of the Media Bureau with experimental licenses for 5G Broadcasting. 5G Broadcast is the first worldwide broadcast standard published by 3GPP. The LPTVBA respectfully requests the Media Bureau consider allowing LPTV,  TV translator, and Class A stations to flash cut to 5G Broadcasting, particularly for first responder solutions and emergency alerts. New development phones have been released by Xiaomi, Motorola, Samsung, and One Plus, and commercially available 5G Broadcast smartphones and CPEs are expected in Q2 2025. In late 2025/early 2026, new smartphone and CPE chips will be released that will combine 5G Broadcast reception on a smartphone or CPE with a return path via cell or WiFi. Many countries around the world are testing 5G Broadcast or looking to commercially deploy the standard with commercial receivers coming to the market, and LPTV is perfectly situated to implement this exciting new delivery system for programming and data here in the US.

The LPTVBA is requesting a window to apply for new low power television station Construction Permits after the major change filing window. If the Media Bureau were to consider imposing a limit on the number of applications to be filed by a single entity, or affiliated entities, LPTVBA respectfully proposes that such limit be no less than 25.