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HD Radio call letters text display -- FCC required?

Are HD Radio stations required by the FCC to display their call letters in the text display? "Star 99.1" WAWZ is showing their call letters in the HD Radio text display as "STAR-FM" instead of "WAWZ-FM". Every other HD station on the dial is showing their actual call letters in this text field. So does "STAR-FM" count as an incorrect legal ID?
 
A few years ago I briefly picked up 94.9 from Little Rock, AR strong enough to get the HD call letters to decode and it showed "TOM-FM".
 
A few stations around here only have HD as the txt display on HD signals.
 
There has been some discussion about whether using your call letters in the PAD removes the requirement of ID'ing as "KXXX and KXXX-HD1, Anytown". See the note here:

http://lists.bostonradio.org/pipermail/boston-radio-interest/2008-June/016282.html

and a different interpretation here:

http://lists.bostonradio.org/pipermail/boston-radio-interest/2008-June/016283.html

To the best of my knowledge there hasn't been an official response from the FCC on it, but I also know that there are many stations that broadcast in HD that don't audibly ID as such at the top of the hour. I think it's a general belief that "either/or" is OK.

Dave B.
 
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