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Wednesday, May 17, 2006

HD Radio Operations in a Nutshell

As digital HD radio gains popularity, many station owners are contemplating the initiation of HD operations. Some station engineers, unfortunately, have initiated such operations without following the FCC's requirements.

There are two ways to initiate HD radio operations:

  • If the same antenna will be used with a combiner to transmit both the analog and digital signal, the FCC allows stations under its March 20, 2003 Public Notice to commence digital HD Radio operations with a notification letter to the FCC. A sample notification letter is contained in the March 20, 2003 Public Notice.
  • If, however, separate antennas will be used for the analog and digital signals, the FCC's requirements are more involved and are described in a March 17, 2004 Public Notice. The separate digital antenna must be located on the same tower as the main antenna or on a tower within three seconds of latitude and longitude, and must be at a height above average terrain between 70% and 100% of the main antenna. Most importantly, the separate antenna must be licensed as an auxiliary antenna and once licensed, a request for special temporary authority (STA) must be granted by the FCC prior to the initiation of HD radio operations.

It is the second mode of HD operations that appear to get most station licensees into trouble. Once the HD radio equipment arrives, some licensees are simply putting up the antennas and commencing HD operations without regard to the licensing and STA requirements.

The STA requirement, in particular, is burdensome on licensees as STAs are issued for time periods of 180 days. Thus, under the FCC's present scheme, once HD Radio operations are initiated, the licensee every 180 days must re-apply for an STA and pay the requisite FCC filing fee.

For those licensees who wish to broadcast multiple audio streams over HD radio, the Commission's March 8, 2005 Public Notice requires that experimental authority be requested which is an informal application contained in a letter form. No FCC filing fee is required to apply for this HD radio multiple audio stream experimental authority.

In 2004, the FCC released a Further Notice of Proposed Rule Making which remains pending. Once the issues in this proceeding are presumably clarified by the release of new rules and procedures by the FCC, it is hoped that the continuing STA requirement, in particular, will become a thing of the past.

HD radio operations are on the cutting edge and stations who go forward with this new technology are to be commended. Broadcast licensees need to be sure, however, that they fully comply with the FCC's rules and policies in initiating HD radio operations.

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