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I wasn't aware he was. Perhaps Tchaikovsky receives more negative criticism compared to some of the other "first rate" composers, but he still tends to rank extremely high (top 10-20) in the few polls I've seen ranking the greatest composers, so apparently he's attracted enough positive criticism as well. We could investigate the possible reasons behind why Tchaikovsky receives more negative criticism--many posters here have offered such reasons--but whether this criticism is robust enough to consign Tchaikovsky to "second rate" status would be hugely debatable.
I'm not the biggest Tchaikovsky fan for many of the reasons that have been listed: I often dislike his use of form and I frequently feel his emotional content as more bombastic and schmaltzy rather than epic and profound, but these are largely personal impressions. Tchaikovsky still has many works I love (1st Piano Concerto, Serenade for Strings, Eugene Onegin, etc.) where his melodies and lyricism overwhelms my criticisms, and I would still rank him in my own ~top 30, so probably not what I'd call second rate. Maybe a tad overrated in my estimation compared with those who put him top 10, but that's about it.
I'm not the biggest Tchaikovsky fan for many of the reasons that have been listed: I often dislike his use of form and I frequently feel his emotional content as more bombastic and schmaltzy rather than epic and profound, but these are largely personal impressions. Tchaikovsky still has many works I love (1st Piano Concerto, Serenade for Strings, Eugene Onegin, etc.) where his melodies and lyricism overwhelms my criticisms, and I would still rank him in my own ~top 30, so probably not what I'd call second rate. Maybe a tad overrated in my estimation compared with those who put him top 10, but that's about it.