K.M. Richards
Program Director, The Eighties Channel™
Channel 1 as a virtual designation should be commonly allowed. No technical reason to restrict it.
KAXT-CD in San Francisco is virtual channel 1. It was the compromise reached because KRCB, also in the S.F. market, is virtual channel 22. There are areas where both signals overlap and digital tuners got confused.
(Both stations were on analog 22, but KRCB's transmitter back then was farther north, near Santa Rosa, and they did not have overlapping contours back then.)
I also think channel 37 should be allowed for PSIP identification.