Digital Station IDs

What is the proper way to identify HD channels? This question comes up for both television stations broadcasting multiple channels, and radio using iBiquity HD to broadcast multiple streams. The FCC rule governing station identification, Section 73.1201, is fairly clear for television digital multicast channels, but is less clear and a bit confusing as it applies to HD radio.

73.1201(b)(1) states that the official station identification must be comprised of the station's call letters immediately followed by the community or communities specified in its license. Digital TV stations or digital audio broadcast stations are permitted to include the station's channel number in the station identification, but if they do, they must use the station's major channel number and may distinguish multicast program streams. But where and how may they distinguish the multicast subchannel?

The radio portion of the rule requires only that a station operating in DAB hybrid mode or extended hybrid mode 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." It does not require identification of the subchannel, and it does not permit any other insertion between the station's call letters and the community of license.

So, how are you to identify properly the subchannel? The FCC staff has confirmed that the rule permits an identification of the specific digital stream, but only after first identifying the primary digital station and an alert to the audience that it is digital. An "appropriate" fashion would include, but does not require, identification of the specific multicast signal specific stream without anything else following the main channel ID. So for TV WWWW-TV DT2, YourCity would comply, and for radio, WWWW-FM HD2, YourCity would comply.

This column is provided for general information purposes only and should not be relied upon as legal advice pertaining to any specific factual situation. Legal decisions should be made only after proper consultation with a legal professional of your choosing.