Alternate Spectrum for Broadcasting: 76~88 MHz

Alternate Spectrum

Revised May 22, 2023

This spectrum is the current TV channels 5 and 6.  This spectrum is directly adjacent to the FM broadcast band (88~108 MHz).  Channel 5 is from 76~82 MHz and Channel 6 is from 82~88 MHz.

Who uses it?

Domestic incumbent users:  Channel 5: Full service TV (20), Class A TV (2), LPTV and TV translators (66).  Channel 6: Full service TV (8), LPTV and TV translators (90), no Class A Channel 6 stations. One FM translator on 87.9 MHz (channel 200).

Foreign incumbent users:  (In border area) Canada: Channel 5: 13 full-service DTV stations or allotments and 16 lower power digital allotments. Channel 6: 7 full-service DTV stations or allotments and 26 lower power digital allotments.   Mexico has no digitial stations or allotments on Channels 5 or 6 in the border region. 

How do they use it?

ITU Region 2 allocation: Broadcasting on a primary basis, fixed and mobile on a secondary basis.  An international footnote elevates fixed and mobile to operate on a primary basis in the United States, Mexico and the French Overseas Departments (including St. Pierre and Miquelon near Canada) but not Canada.

FCC allocations: Broadcasting (Part 73), LPTV, TV Translator/Booster (Part 74) and Low Power Auxiliary (Part 74).  TV broadcaast stations may use subcarriers on a secondary basis for both broadcast and non-broadcast purposes.  TV stations may use a portion of the television vertical blanking interval for the transmission of telecommunications signals on a non-interference basis. Wireless microphones are authorized in this spectrum on a non-inteference basis.  Subscription television operations are permitted in this spectrum.

Federal Government allocations: (none)

Canada/Mexico allocations: Canada allocates this spectrum to broadcasting with  no footnotes.  Mexico allocates this spectrum to broadcasting on a primary basis and fixed and mobile on a seocndary basis.  Mexican footnotes specifically permit digital television and define 76~82 as Channel 5 and 82~88 as Channel 6.

REC analysis and opinion for use as alternate spectrum

Being directly adjacent to the FM broadcast band, this band would hold the most promise for alternate spectrum barring other activities taking place in the industry.  While not intended for sound broadcasting, there are some low power TV stations that have exploited the audio carrier at 87.75 MHz and are operating audio only services in order to reach FM radio listeners.  Some of these operations have shifted their center carrier frequency to 87.7 MHz and are running a stereo pilot tone thus questioning the legality of these so-called "franken-FM" stations.  Due to the resistance by the major owners of these "franken-FM" stations, the FCC has been delaying the mandatory shutdown of analog LPTV stations which would, without any further rulemaking, result in these audio services to be shut down.  87.9 MHz is also known as "Channel 200".  This channel is intended for Class D secondary non-commercial educational stations that are very distant from a Channel 6 TV station and nowhere near an international border to be able to use in the event of displacement due to changes by a full-power FM station.  For many years, a small high school station in Mountain View, CA had operated on 87.9 before moving to a commercial channel.  A translator in Nevada has also been permitted to migrate to 87.9 as a result of displacement.  During the original LPFM proceedings, REC had recommended allowing LPFM stations on 87.5, 87.7 and 87.9 and referring to 87.5 as "America's Channel" as it would be the most available channel for LPFM due to a third-adjacent channel relationship with the nearest FM channel, 88.1 MHz.

Consumer grade radios are widely available for this spectrum but not in the United States.  Japan has historically used 76~90 MHz for FM broadcasting.  Japan had recently extended the FM band to 76~95 MHz in order to allow existing AM broadcast stations to obtain a high powered FM signal within their service areas.  As a result of this expansion and the potential for more expansion based on the public acceptace of "multi-media broadcasting" which has authorized in Japan in the 95~108 MHz spectrum, radio are being marketed that cover the entire 76~108 MHz band.  These radios, referred to as "Wide-FM" (ワイドFM) are available in all types including portable, stereo component and mobile radio.   It is not believed that any of these radios with the full 76~108 coverage would include HD Radio capability.  There are no known DRM+ capable consumer grade receivers for this spectrum yet however it could possibly be covered using the SDR-based prototype models.  Even though DRM+ is an accepted worldwide standard for on-band digital radio, most nations are not willing to embrace on-band digital audio broadcasting (DAB) and are favoritng the world standards for off-band DAB. In the western hemisphere, Brazil has already announced the use of the 76~88 MHz band for FM sound broadcasting as part of a transition of AM stations to FM.  CITEL, the international agency that handles spectrum standards in the western hemisphere reached a resolution on a recommendation that 76~88 MHz could be used for FM sound broadcasting, but done so in a matter that takes into consideration, the nations that use the spectrum for digital terrestrial television.  Other South American nations are moving forward with plans to allocate the spectrum to FM sound broadcasting.

Recently, the potential demand for this spectrum for television broadcasting has been increased as a result of the development of the ATSC 3.0 broadcast standard.  ATSC 3.0 promises ultra high-definition television and other imporved services within a 6 MHz television channel.  ATSC 3.0 is not backwards compatible with the current ATSC 1.0 standard.  As a result, TV stations and consumers would need to migrate to the new standard.  The FCC is allowing TV stations wishing to adopt the ATSC 3.0 standard the ability to obtain a "companion channel" with no real schedule to shut down their ATSC 1.0 channel.  This use of a companion channel was also done during the original DTV transition with a hard analog shutdown date.  In this case, the FCC is taking a "let the market decide" approach on whether ATSC 3.0 is accepted.  Obviously since there needs to be a companion channel to viably deploy ATSC 3.0 and with the recent repacking of all TV staitons to channels 36 and below, it is very likely that TV stations will be running ATSC 3.0 in the low band VHF spectrum (54~72, 76~88, channels 2~6).   As of May, 2023, there has been no increased demand by full-service TV stations to use Channels 5 or 6.

A new plan for Channels 5 and 6

In MB Docket 03-185, the FCC is going to consider NPR's concept for sound broadcasting in the Channel 6 spectrum.  This is something that we have been pushing for quite awhile.  NPR states that it is needed for the expansion of educational broadcasting. Any new plan must take into consideration the 8 existing primary Channel 6 TV stations and must afford them considerable protection.  With that, we have already taken some recent (May, 2022) positions on the concept:

  • REC agrees that while radio receivers are currently not available in the US market, they are available in the Japan and Brazil markets (with the latter having 10 kHz AM spacing).  Like with any other new service, it will take a long period of time before there is a considerable saturation of radios.  But those radios can be on a boat tomorrow.  We must also convince the auto makers to not only keep radio on the dashboard but to also embrace the new extended FM band in their infotainment systems. 
  • REC can see an application for this spectrum for various expat communities; communities that are close but do not have a real voice.  The new radios can be sold in "mom and pop" shops in those neighborhoods and lower powered FM stations can broadcast to their community. 
  • While we recognize that streaming is gaining in popularity, radio is still holding on and for some, radio is the only form of affordable entertainment and information.  The Extended FM Band will further the programming choices available. 
  • REC does not support any forced relocation of any existing station on 88~108 into the extended band.  The band must work around the legacy stations. 
  • REC recognizes the trend among full-service TV stations on Low VHF (channels 2-6) and High VHF (channels 7-13) are migrating to UHF.  The main motiviation for the move is reception issues and the increase in use of smaller over the air antennas in a new wave of "cord cutters".  These small antennas are not designed to work with low VHF.  In the past 5 years, two Channel 6 TV stations have already migrated to UHF, leaving on 8 stations in 3 clusters of the country with no channel 6 stations west of the Nebraska/Colorado border.
  • Since the already manufactured radios cover the 76~108 MHz spectrum, REC also supports the ability for FM broadcasting in the Channel 5 spectrum (76~82 MHz).  In areas where Channel 6 is not available due to a full-service Channel 6 TV station, but where there is no full-service TV activity on Channel 5, the proposed bandplan would shift to the 76~82 MHz band instead of the 82~88 MHz band.  In areas where both channels 5 and 6 are available, the bandplan will exist in Channel 6 spectrum (82~88 MHz) and in the channel 5 spectrum (76~82 MHz), secondary services may propose service there with no protection from future primary Channel 5 TV operations.
  • If primary FM broadcasting is allowed in the 82~88 spectrum, it could spell the end of the FM6/Franken FM stations because as soon as one NCE FM station is authorized in the area around a FM6, that FM6 (which is secondary) is subject to displacement.
  • In the 13 markets that were identified where FM6 operations are taking place, the FCC should amend the table of allotments and allow for a commercial station on 87.7 (and 87.9 as an alternate).  That allotment can't be moved to another area and no new commercial allotments would be added to 87.7 or 87.9.  These allotments would be considered "grandfathered" and will have no second or third adjacent channel protection requirement to existing FM stations.
  • The FCC needs to freeze the assignment of new primary and secondary TV stations or the channel changes of existing primary and secondary TV stations to Channel 6.  
  • The FCC needs to freeze the assignment of new secondary TV stations or the channel changes of existing secondary TV stations to Channel 5.
  • REC supports the elimination of the protection requirements between FM stations on 88.1~91.9 with TV Channel 6. 
  • REC supports that the FCC adopt the existing FCC and ITU standards and apply them to FM broadcasting.  This would mean a 2 dB desired to undesired (U/D) ratio for analog into digital and a 34 dB D/U ratio of  digital into analog.  This will mean that in order for a FM radio station to protect a TV station on the same channel, the FM station's 26 dBu (F50, 10) interfering  contour cannot overlap the DTV station's 28 dBu (F 50,90) noise limited service contour.  DTV stations would protect primary FM operations through the DTV station's 26 dBu (F 50,10) interfering contour not overlapping the FM station's 60 dBu (F 50,50)  service contour.  Primary FM applications will need to demonstrate a lack of overlap in both directions while secondary FM applications only need  to show a lack of analog to digital interference.
  • REC supports 20 channels between 83.1 and 86.9 to be assigned to full service NCE broadcast stations.   In areas where Channel 6 is not available but Channel 5 is, this will be the spectrum from 77.1~80.9 MHz.
  • In areas where Channel 6 is used for primary FM stations, REC supports the reservation of 82.1~82.9 and 87.1~87.9 for secondary services such as LPFM and temporary special event services.  We note that in some areas, 87.7 may be used for commercial services.  In these areas, the entire Channel 5 spectrum (76.1~81.9) would be available for secondary LPFM and special event services where full-service Channel 5 TV stations can be protected.
  • In areas where Channel 5 is used for primary FM stations,  REC supports the  reservation of 76.1~76.9 and 81.1~81.9 for secondary services such as LPFM and temporary special event services.
  • REC supports the ability for commercial and noncommercial applicants to request temporary low power (10 watts or less) operations on 82.1, 82.3 and 82.5 and in the entire  Channel 5 spectrum (except in areas where  Channel 6 is not available, then it will be 76.1, 76.3 and 76.5).  These temporary permits can be used for sports arenas, stadiums and other major events (such as those that are covered by Live Sports Radio) as well  as for commercial and noncommercial events such as music festivals, scouting jamborees, etc.  These services can promote venue safety while entertaining the public and providing additional auditory assistance to attendees with disabilities.
  • REC supports the creation of a 250 watt at 30m LPFM service in this spectrum.  In areas west of the Mississippi River, except in California south of 40 degrees latitude,  REC supports the creation of a "LP-250 Plus" service class which would permit up to 250 watts at 107m HAAT.
  • REC does not support any LPFM levels above 250 watts ERP at 107m HAAT.  Those desiring higher power should apply for a full-service NCE station.
  • REC recognizes that any  LPFM stations operating in the Extended FM Band would be subject to the Local Community Radio Act.  Distance separation would be required between LPFM stations and full-service FM stations in this spectrum, but we are calling on the FCC to allow for LPFM stations using contours to protect other LPFM stations, FM translators and TV channel 6 stations.
  • It is REC's position that in the first two primary FM filing windows for this spectrum, that licensing be limited only to organizations that have an established local presence.
  • REC feels that this band would be the best place to test liberalization of third-adjacent and second-adjacent channel protections.  At this time, REC supports full second and third adjacent protection to broadcast stations on 88.1 and above (with the exeception of the 13 FM6 allotments).