DTV: You Snooze, you lose.

[DeadElvis]

Looks like Mid-South Public Communications Foundation, the licensee of WKNO TV/FM will NOT be getting its second TV station.

WKNO's CP for a second DTV station has been dismissed.

The Channel 10 people got a CP for an analog on channel 56 quite some time ago, but did not construct as the death of analog TV was quickly approaching. The pendant digital CP was for RF channel 10, once WKNO-TV abandoned that channel for full-time DTV on RF 29.

WKNO hoped to wait until after transition to construct the digital facility and applied for a CP to do so. That last-minute application has finally been dismissed:

http://www.fcc.gov/Daily_Releases/Daily_Business/2010/db1227/DOC-303796A1.pdf

I am not sure that WKNO was really that excited about ever constructing this station. But, that seems now to be an academic question. The FCC was really pretty clear that those DTV CPs were hard dates. I guess they meant it.

DE

 

[w9wi]

Looks like Mid-South Public Communications Foundation, the licensee of WKNO TV/FM will NOT be getting its second TV station.

WKNO's CP for a second DTV station has been dismissed.

...

The FCC was really pretty clear that those DTV CPs were hard dates. I guess they meant it.

I suppose WKNO's point was, why bother building a channel 56 facility that they knew would be valueless after the transition.

I don't know of any other precedent.

If I were "god of WKNO" at the time, I think I would have:

- Asked for Special Temporary Authority to operate the permitted ch. 56 analog station with a reduced-power facility. 100 watts ERP from an antenna sitting on the roof of the studio building.
- Asked whoever I was buying the post-transition digital ch. 10 transmitter from if they would loan me the low-power ch. 56 analog rig. (they're making enough $$ from my full-power purchase!)
- Used analog 56 to simulcast one of the ch. 10 subchannels.

It would have cost little to build & would have kept the channel 56 permit alive through Transition. By doing it as a STA it wouldn't have risked losing protected coverage for the post-Transition ch. 10 digital facility.

 

[tripinva]

The loan part of your plan doesn't work if their plan was simply to repurpose the WKNO-10 analog transmitter for digital operation. That said, I agree fully with the rest of it.

- Trip

 

[w9wi]

The loan part of your plan doesn't work if their plan was simply to repurpose the WKNO-10 analog transmitter for digital operation. That said, I agree fully with the rest of it.

- They still would have needed to buy a digital exciter for the ch. 10 transmitter.
- The ch. 56 CP was granted in 2004; if they bought a convertible ch. 10 transmitter after that date, they could have made the loan of a LP ch. 56 rig part of that deal.

But yes, if they had a pre-2004 convertible ch. 10 transmitter they may not have had much leverage for a loan.

 

[fybush]

The loan part of your plan doesn't work if their plan was simply to repurpose the WKNO-10 analog transmitter for digital operation. That said, I agree fully with the rest of it.

I agree partially with it, and here's why: a CP has to receive a license to cover within three years or it's dead. So it would have taken more than just an STA to keep channel 56 alive. Instead, WKNO would have to have reapplied to the FCC to license channel 56 with minimal analog facilities while awaiting the conversion.

Another option, and one that might have worked out better in the long run, might have been to do an early DTV transition on the WKNO-TV license...move it to DTV-only on RF 29 a month or two or three before the transition date in order to get the new license on the air on RF 10 before transition day. We know the FCC was willing to work with new stations like KDMI in Des Moines that chose not to build a pre-transition analog facility so long as they were able to get their DTV facility on the air before transition.

Here we had the complication of the post-transition DTV channel not being available. I wonder if they could have taken yet another different approach: designating the built facility on RF 29 as the DTV facility of "channel 56" during transition, flash-cutting WKNO-TV from analog to digital on RF 10 on transition day, and then, like KTXA/KTVT or Wichita, swapping RF channels between the two licenses after the fact?

 

[DeadElvis]

If one goes back and reads some of the applications filed during this errand, it is clear that WKNO's point was exactly what is opined here -- it was too crazy expensive to construct a facility on channel 56 that had virtually no shelf life. Still, I did wonder why they didn't do just what Doug wondered -- assemble a minimal station to satisfy the FCC. There was a lovely free-standing tower next to the building on U-of-Memphis South Campus (they have moved since).

But, it was an interesting legal exercise. The CP for the analog was allowed to expire. But, if the DTV CP was truly pendant to the analog CP, it would necessarily have to expire, too. I suppose we now see that it was, despite the fact that the dismissal filing for *56 from the FCC was silent on that question.

BTW, Scott... WKNO-10 did, indeed, go off early. I think it was March 1, 2009, though my memory may be off just a bit. But, it would have allowed a new DTV plenty of time to jump in before the drop-dead date in June, 2009. And, WKNO did not plan on converting the old analog transmitter (actually transmitters; they had two of 'em). The DTV-10 transmitter was to be a simple 1 kW rack-mount, from what the engineer (a very competent guy) told me.

So, I wonder what happens now. Is the DTV allocation to *10 just deleted without prejudice?

DE

 

[fybush]

The *10 allocation should still be there, and if and when the FCC reopens applications for new stations, WKNO would presumably be able to apply for it. That "if" may turn out to be a big "if," though, since the Commission doesn't seem to be in much of a hurry to add more stations to the spectrum it's trying to clear out for other uses.

 

[mikl73]

It is a really big mess. Of all operators here WKNO would have used that spectrum to offer something watchable. Who really watches the 3 religious ABN channels and the 5 on WBUY. I hoped the new RF 10 would actually come on and offer up something worth watching like PBS World.

 

[w9wi]

To make this make more sense, I'm going to assign the "fake calls" WKNN to the deleted DTV-10 permit. Please understand (I know Trip, Dead, and Scott understand) that the "WKNN" calls do not exist, at least not on this station.

The loan part of your plan doesn't work if their plan was simply to repurpose the WKNO-10 analog transmitter for digital operation. That said, I agree fully with the rest of it.

I agree partially with it, and here's why: a CP has to receive a license to cover within three years or it's dead. So it would have taken more than just an STA to keep channel 56 alive. Instead, WKNO would have to have reapplied to the FCC to license channel 56 with minimal analog facilities while awaiting the conversion.

(again, remember "WKNN" is shorthand for the second WKNO station, these are NOT real calls)
WKNN's facilities were (presumably) based on replication of the theoretical channel 56 analog coverage. Would modifying the analog-56 permit have prejudiced the DTV-10 facility? I suppose not, as they already had a CP for it...

Here we had the complication of the post-transition DTV channel not being available. I wonder if they could have taken yet another different approach: designating the built facility on RF 29 as the DTV facility of "channel 56" during transition, flash-cutting WKNO-TV from analog to digital on RF 10 on transition day, and then, like KTXA/KTVT or Wichita, swapping RF channels between the two licenses after the fact?

I like this option.
File a "silent STA" on WKNO-DT; modify the WKNN permit to specify the channel 29 facilities WKNO-DT had been using; modify the WKNO-DT permit (or was it already licensed? - doesn't much matter) to specify RF-10; take out a license-to-cover on WKNN-29 (after all, the transmission facility has already been proven); not sure how much time they'd have to flash-cut WKNO from analog to digital on 10, but they would have had more time than they did the way they did it! Would there even be a point to swapping RF channels between WKNN and WKNO after everything was built?

_________________________________________________

Given the FCC's desire to continue clearing out the UHF band, I wonder if, in the end, we'll see a WKNO signal on RF-10 anyway? (but with RF-29 deleted)