April 3, 1997


                     Separate Statement of 
                                
                 Commissioner Rachelle B. Chong
                                
                                
Re:  Advanced Television Systems and Their Impact upon the Existing Television Broadcast
     Service, Sixth Report and Order (MM Docket No. 87-268)

     I am pleased to support this Report and Order in which we adopt a Table of
Allotments for digital television (DTV), rules for initial DTV allotments, procedures for
assigning DTV frequencies and plans for spectrum recovery.  This was a difficult task, but I
believe we have generally succeeded in ensuring that all eligible existing broadcasters are
accommodated, and that existing service areas are generally replicated.  

     This decision strikes a difficult balance between fiercely competing interests on the
issue of UHF power levels and the power differential between UHF and VHF stations.   We
have adopted a plan, based on an industry-proposed compromise, calling for a 50 kilowatt
minimum power level and a 1 megawatt maximum power level.  This plan provides for a high
degree of service replication.  At the same time, it ensures that all stations may provide DTV
service competitively in their markets.  I believe this is a fair, workable solution.  To the
extent that there is a need to make adjustments in individual cases to accommodate
interference problems, I am confident that the talented engineers both inside and outside this
agency will be able to find answers and that we will be able to resolve the issues on a case-by-
case basis.

     One of the most important aspects of this decision is that it establishes an allotment
table that provides all eligible broadcasters with a DTV channel, primarily in a "core" region
of the broadcast spectrum.  By using this core concept, we will facilitate the quick recovery of
approximately 60 MHz of spectrum at channels 60-69, and the eventual recovery of additional
spectrum.  I emphasize, however, that we have not made any decisions in this order to
reallocate any of this spectrum.  Moreover, we do not preclude the possibility that a future
Commission might decide that some of the recovered spectrum could be used for either full
power or low power broadcasting.  Those are decisions for another day.

     With regard to the 60 MHz of spectrum targeted for "early recovery," I believe that we
should explore the possibility of using part of the spectrum for public safety needs.  Many
parties to this proceeding made compelling arguments that spectrum in the channels 60-69
range would go a long way towards solving some of the pressing spectrum need of public
safety users.  This is a worthy goal and one that I believe we ought to pursue. 

     Finally, with regard to low power television service, this decision recognizes the
significant contributions that these services make to the public.  While there is not enough
spectrum during the transition period to accommodate every low power service, we have
taken steps to mitigate the impact of DTV implementation of LPTV.  For example, we are
changing some of the technical rules requested by the LPTV and TV translator industries,
which will provide additional flexibility to accommodate low power operations during and
after the transition to DTV.  Moreover, we will allow LPTV and TV translators to operate on
all existing TV channels, including channels 60-69, so long as such operations do not cause
harmful interference to any primary operations.  We hope this will preserve many existing
low power operations and open many new channels for those LPTV operations displaced by
DTV.