HD Callsigns

[Scott Fybush]

I disagree, and rather strongly at that, with Dan's assertion that 
"WBZ-HD" or "WVEI-FM-HD1" constitutes a "callsign" within the meaning of 
73.1201.

Fact is, I see nothing ANYWHERE in 47CFR73, or in the FCC's own 
databases, for that matter, that codifies the "WXXX-HD" naming 
convention that the industry has chosen to employ, and the most current 
wording of 73.1201(b)(1) certainly doesn't mandate it, either:

"A radio station operating in DAB hybrid mode or extended hybrid mode 
shall identify its digital signal, including any free multicast audio 
programming streams, in a manner that appropriately alerts its audience 
to the fact that it is listening to a digital audio broadcast."

Perhaps one of the lawyers on the list could tell me why it would be a 
violation of the letter of 1201(b)(1) to identify thusly:

"850 WEEI Boston, 1440 WVEI Worcester, 103.7 WEEI-FM Westerly, and 105.5 
WVEI-FM Easthampton, now broadcasting in HD Digital radio."

In summary: my contention is that "WVEI-FM-HD1" is simply an identifier 
("in a manner that appropriately alerts its audience...") for one of the 
digital audio streams of the station whose callsign remains simply 
"WVEI-FM," and that the "WVEI-FM Easthampton" legal ID, with the 
"permissible insertion" of the digital broadcast identifier, is 
perfectly adequate and legal.

Similarly, it's my understanding, from seeing the way the FCC handles 
such matters internally, that the digital TV signal now operating on 
channel 30 in Boston is actually part of the license whose facility ID 
is 25456 and whose callsign is "WBZ-TV," and that such license also 
includes (until 2/17/09) authority to operate in the analog mode on 
channel 4, and therefore that any identification as "WBZ-DT" is simply a 
means of alerting the audience that it's viewing a digital broadcast, 
and not a legal station identification under a strict interpretation of 
73.1201. I suspect this piece of the rules will be massively 
misinterpreted come 2/17/09; I'm already seeing some signals that have 
gone digital-only identifying exclusively as "WXXX-DT Wherever," which 
is not at all what it says on their licenses.

Personal opinion: I don't think the latest revisions to 73.1201 were 
handled well at all. There's far too much confusion right now about what 
is and is not a legal callsign, particularly in light of the fact that 
the FCC really doesn't care that much about calls anyway, having gone to 
internal identification by unchanging facility numbers. The 
"appropriately alerts its audience" language is painfully vague, leading 
to massive amounts of, IMHO, on-air clutter that's neither in the letter 
nor the spirit of the rule.

IANAL, etc...

s