Citing a ‘critical’ lack of federal, state and local funding, pub...

modify its financial hardship standard for granting extensions to the construction deadline to “reflect the unique and diverse ways in which PTV stations are funded.” Saying 24% of PTV stations that had sought extension had cited funding difficulties, APTS said the federal govt. had appropriated only 13% of PTV’s total conversion costs of $1.8 billion. It said 40% of the federal funding was contained in the FY 2003 appropriations that wasn’t enacted until Feb., just 3 months before the May 1 deadline for PTV stations and “too late for disbursement in time to help stations meet that deadline.” Many stations also didn’t get the NTIA-administered Public Telecom Facilities (PTFP) grants for FY 2002 because of the high volume of applications and the policy that gives the highest priority in funding to stations that provide either a sole digital service to their market or a statewide digital service, APTS said. Because of the budget crises in many states, funding has been delayed or reduced for many stations, they said, and even after federal and state funds were released to stations, many state and university licensees had to go through a bidding process to award construction contracts, which in some cases took more than a year. “Unlike the technical obstacles to constructing digital facilities that face public and commercial stations alike, these funding issues are unique to public television stations,” APTS said. Therefore, it said, it would be “reasonable and appropriate” for the Commission to consider changing its financial hardship standards for extensions to take into account the funding issues of PTV. Besides reiterating the need for “reasonable and limited” interim cable carriage rules, APTS said the FCC also should ensure that the entire free broadcast signal of a station should be carried for a successful digital transition. Public broadcasters also sought rules to help the operation of digital translators and on-channel repeaters for the transition to be carried out in rural as well as urban areas. With the conversion of its full-power transmitters and more than 700 translators, PTV would be able to provide “powerful and cost-effective nearly universal” last-mile services to meet educational and public safety needs, APTS said. However, translators are threatened because they're considered a secondary service and because the Commission has yet to implement federal law that allows licensees to operate digital translators on their present analog channels, APTS said. Public broadcasters also urged the Commission to: (1) Delete the simulcast requirement on the ground that it didn’t serve its purpose. (2) Base the definition of market-by- market extensions on Nielsen Designated Market Areas (DMAs) while interpreting rules for the return of analog spectrum and extensions. All stations in a DMA must benefit from any extension, it said, and where a station’s signal reaches multiple DMAs, the return of analog spectrum should be only when the last DMA had reached the 85% threshold. (3) Count only those Multichannel Video Programming Distribution (MVPD) providers that carried all local must-carry eligible digital broadcast stations for the 15% MVPD digital subscription test.