Planning to turn off your analog on February 17, regardless of any Congressional extension? Here’s what you need to do.

Even if Congress finally gets its act together and extends the DTV transition date, we expect that many, if not most, TV licensees will still be inclined to shut down their analog operations as of February 17 anyway. (The “DTV Delay” bill already passed twice by the Senate specifically contemplates such pre-June 12 analog turn-offs.)

If you’re one of those planning to permanently cease broadcasting your analog signal as of February 17 (assuming the transition date does get delayed), you need to do a couple of things and you need to do them quickly.

First, you need to file with the FCC a suspension of operations notice with the FCC through its CDBS online filing system (check with your favorite FCC counsel for assistance) to notify the FCC that you will cease transmitting in analog as of February 17.

Second, you need to immediately begin running notifications on both your analog and digital signal that contains the following information:

  1. The station’s call sign and community of license;
  2. The fact that the station is planning to or has reduced or terminated its analog   operations before the transition date;
  3. The date of the planned reduction or termination;
  4. What viewers can do to continue to receive the station (like how to receive the digital signal);
  5. Information about the availability of digital-to-analog converter boxes in the station’s service area; and
  6. The street address, email address (if there is one) and phone number of the station where viewers may register comments or requests for information.

Note – this viewer notification requirement is in addition to and separate from the DTV Education Initiative required announcements.

You must run 120 of these announcements between the time you file your notification with the FCC and the date you plan on terminating analog service.  In addition, at least 30 of the 120 announcements must be in prime time.

One final important piece. If your post-transition DTV channel is different from your pre-transition DTV channel you may have to continue to operate on your pre-transition channel until your post-transition channel clears (for example, the analog station in the neighboring market that must shut down before you can begin operating your post-transition channel).

And one final, final important piece. If you terminate your analog and your pre-transition DTV coverage is significantly smaller than your analog coverage, you may be losing viewers entirely and the FCC would frown on the loss of coverage.  So make sure your coverage areas are comparable before terminating analog service.