Federal Communications Commission
Washington, D.C. 20554
February 4, 2014
Released: February 4, 2014
General Manager, KLCS
Los Angeles Unified School District
1061 West Temple Street
Los Angeles, CA 90012
Vice President and General Manager
2323 Corinth Ave.
Los Angeles, CA 90064
Vice President, Regulatory Affairs
CTIA – The Wireless Association®
1400 16th Street, NW
Washington, DC 20036
Re: Request for Special Temporary Authority and
Channel Sharing Experimental Authorizations
KLCS (Fac. ID 38430) & KJLA (Fac. ID 14000)
File number: BPEXDT-20140128AHV
This is with reference to the Request for Special Temporary and Channel Sharing
Experimental Authorizations filed jointly by the Los Angeles Unified School District, licensee of
noncommercial station KLCS, channel 41, Los Angeles, CA (the Sharer) and KJLA, LLC,
licensee of commercial station KJLA, channel 49, Ventura, CA (the Sharee). KLCS is a primary
PBS station while KJLA is the flagship station for a network distributing multicultural and
multilingual content serving that area’s Latino population. The stations state that they are
responding to the Commission’s expression of interest in authorizing one or more channel
sharing pilots in order to demonstrate the technical and legal arrangements necessary to
implement a successful channel sharing operation.
Both stations request broadcast operations at variance to their presently authorized
facilities to implement a Channel Sharing Pilot trial during which the KLCS facilities will host
the operations of KJLA. The stated purpose of the experiment is to demonstrate the necessary
technical and legal steps for a successful channel sharing operation and advance understanding
of channel sharing systems. Because KJLA’s signal will also remain on-air at its present
location and under its current operating parameters, the trial is not anticipated to have any
negative impact on viewers.
The Proposed Channel Sharing Pilot
Both licensees have entered into a Pilot Agreement under which KLCS and KJLA will
engage in testing up to and including shared use of the channel rights held by KLCS. This
testing will explore the feasibility and practicality of over-the-air channel sharing as follows:
Technical feasibility testing for multiplexing of signals on a single bitstream off-air
involving a variety of content combinations (for example, multiple HD streams as well as
HD and SD streams); transmission in the H.264 video compression format in addition to
the standard MPEG-2 format.
The development of reliable methodologies for modifying the Program and System
Information Protocol (“PSIP”) information to limit consumer disruption and ensure
reliable data during over-the-air testing.
Channel sharing using of a variety of configurations with replication during off-peak
hours. (For example, KJLA will provide content to KLCS and KLCS will transmit the
shared bitstream to determine the level of reception of the shared channel streams.)
During these tests, KLCS will continue to transmit its unaltered signal with all of its
broadcast streams pursuant to its licensed operating parameters.
In the final phase, implementation of full-time channel sharing, with KJLA remaining on-
air, while KLCS transmits a shared bitstream with content from both stations using
different virtual channels.
Both licensees state that, during each phase of the trial, the stations will monitor
performance of the pilot through a study of their actual video bitstreams, and will attempt a
variety of video feeds (for example, multiple HDTV streams, multiple HDTV streams plus
additional SDTV streams, etc.) to ascertain the feasibility of channel sharing between two
unaffiliated broadcast stations. Before proceeding to each successive phase of testing, the
stations will agree that any video degradation occurring will be within acceptable bounds.
The licensees represent that during the Channel Sharing Pilot they will utilize their
portion of the transport stream consistent with Commission rules, including subdividing their use
into multiple sub-channels. Further, the stations intend to experiment with implementation of
statistical multiplexing to improve the delivered picture quality of their multicast channels. They
propose to capture video and audio data during the testing that will allow analysis of the effects
of channel sharing on video and audio quality.
During the Channel Sharing Pilot, both stations note that they will retain their respective
licenses and continue to operate their channels to provide over-the-air service to their respective
viewing audiences. Each station pledges to continue to comply with the Commission’s rules and
policies for broadcast television stations.
The Spectrum Act1 authorizes channel sharing by television licensees as one possible
means of participation in the incentive auction of broadcast television spectrum. As the
applicants note, the Commission has stated that “participation in a channel sharing arrangement
has the potential to benefit broadcasters and the viewing public in addition to freeing spectrum
for new wireless services.”2 These public interest benefits include the potential reduction in
operating costs, additional income to broadcasters that can be directed into better programming
choices, and providing small, minority-owned, and other “niche” stations with an opportunity to
enhance or preserve their local program offerings.3
We find that the Channel Sharing Pilot is in the public interest, as it may help to
demonstrate the feasibility of successful channel sharing between two independently owned
stations. It also may serve as a model for other stations contemplating participation in the
incentive auction, using the channel sharing option, and provide information about the technical
implementation of channel sharing agreements. We do not anticipate enforcement issues that
would impede the accomplishment of the experiment.
Accordingly, the Request for Special Temporary Authority and Channel Sharing
Experimental Authorizations ARE GRANTED subject to the following conditions:
1. Pursuant to Section 5.207, a report will be filed with each application for renewal of this
authorization, containing the information required by that Section and any other relevant
information deemed appropriate by the licensees. In addition, should any unusual
problems or conditions arise during the authorization period, the licensees shall inform
the Commission of them at the time they occur.
Consistent with our rules pertaining to channel sharing in conjunction with the reverse auction,
we will consider Channel 41 to be separately licensed to KLCS and KJLA during the limited
duration of this experiment, and each will be separately subject to all of the Commission's
obligations, rules, and policies. 47 C.F.R. § 73.7300(a), (b)(4). Because KLCS will remain an
1 Pub. L. No. 112-96, §§ 6402, 6403, 125 Stat 156 (2012).
2 Innovation in the Broadcast Television Bands: Allocations, Channel Sharing and Improvements to VHF,
and Order, 27 FCC Rcd 4616, para. 12 (2012).
NCE licensee, it is prohibited from broadcasting advertisements on its portion of the shared
channel. 47 U.S.C. § 399b (b)(2). Any advertisements broadcast on a portion of the shared
channel during the course of this experiment must be limited to KJLA’s portion of the shared
3. The experiment may be terminated at any time, upon notification to the Commission.
During the Channel Sharing Pilot KJLA may operate on the KLCS digital streams to the
extent necessary to conduct the test.
4. A report of the research, experimentation, and results, showing both positive and/or
negative aspects of this experiment, shall be submitted to the Commission six months
from the date of this letter and at the conclusion of this experimental operation should
this authorization be renewed.
5. This experimental operation shall be conducted in compliance with Section 1.1307(b) of
the Commission’s radio frequency radiation rules.
6. This authority expires six months
from the date of this letter.
Barbara A. Kreisman
Chief, Video Division