The Federal Communications Commission (“FCC”) has invited a new round of comments on the fate of analog Low Power Television (“LPTV”) stations that transmit on Channel 6 and target their audio channel to FM radio receivers.

Nearly all of the television broadcast industry has already converted to digital operation. There are no more analog full power or Class A television stations, but a few analog Low Power Television (“LPTV”) stations remain on the air. They face a deadline imposed by the FCC –as specified in this Public Notice from April 2017– of July 13, 2021, to convert to digital or to shut down.

Many of the remaining analog LPTV stations transmit on Channel 6. The audio carrier of an analog TV Channel 6 station is frequency modulated (“FM”) and is centered at 87.75 MHz. Because that is just below the 88-108 MHz FM radio band, the TV audio is receivable by many FM radios. Analog Channel 6 LPTV stations often focus their service on their audio carrier and compete with local FM radio stations for listeners. Many serve minority communities and have achieved notable audience ratings.

Channel 6 LPTV licensees have mounted a strong lobbying campaign to be allowed to continue their analog audio services after July 13, 2021, especially in light of the popularity and minority orientation of some of those services. Some FM interests have argued that it is an inefficient use of the spectrum for a TV station to occupy a full 6 MHz channel when only 0.2 MHz is used for the audio carrier. Others have argued that all of TV Channel 6, if not Channel 5 as well, should be removed from TV service and opened up for applications by existing AM stations to get FM licenses. Others have noted that there is no rule currently in effect protecting adjacent FM stations from interference by LPTV stations, and a pending FCC proposal to repeal the rule protecting TV stations from FM interference assumes that all TV stations will be solely digital.

The FCC has now decided to refresh the record and to get all interested parties to state their up-to-date positions. It appears that the agency wants to resolve the overall analog issue and any separate Channel 6 aspects far enough in advance that it will not have to extend the July 13, 2021, deadline. It is likely that extensive comments will be filed, and striking a compromise to accommodate all interests will take some creativity on the FCC’s part.

Comments will be due 30 days after the FCC’s Public Notice is published in the Federal Register. Watch for the comment deadline when it is announced.