Deborah D. McAdams /
12.02.2013 09:42 PM
NAB Challenges FCC’s ‘Reasonable Effort’
Use of proxy channels in repacking questioned
WASHINGTON — Estimating the coverage area for individual TV stations won’t do, a team from the broadcast lobby told regulators in a meeting at the Federal Communications Commission Nov. 25. The FCC is proposing the use of “proxy” channels in calculating the reach of TV stations relocated after next June’s spectrum incentive auction. The National Association of Broadcasters says doing so would violate the Congressional directive that “all reasonable effort” be made to preserve coverage.

The FCC’s repacking software “uses Ch. 3 as a proxy for all low VHF channels, Ch. 10 for all high VHF channels and Ch. 20 for all UHF channels,” the NAB said in an ex parte filing with the FCC. “Thus, a channel may be moved during repacking from 51 to 36, but the model assumes, for feasibility purposes, that the new channel is 20.”

The NAB ran models with TVStudy 1.2.8, the latest version of the FCC’s repacking software. It showed different results with the proxies versus actual channels in the NAB’s application—77 percent of the time for low VHF; 78 percent for high VHF; and 88 percent for UHF. Further, 43 percent of low VHFs, 35 percent of high VHFs and 49 percent of UHFs experienced a loss of service, while more than 500 stations experienced a loss of service greater than 0.5 percent. The 0.5 percent threshold is the proposed limit of new interference introduced by the repacking.

“NAB understands the FCC’s desire to simplify the computation burden to permit faster results for the auction, but… such speeds should not be a substitute for accurate results and preserving service to viewers,” the filing stated.

Two alternatives were offered. One involved calculating interference “for every possible channel that could be assigned during repacking.” While computationally demanding, it would only have to be done once, the NAB said. Another option would be to use proxy channels for feasibility, but to confirm between auction rounds that new interference would be held to 0.5 percent. NAB estimated that doing so would add roughly 15 minutes between rounds.

The NAB’s away team included Bruce Franca, Rick Kaplan and Victor Tawil, who was instrumental in the 2009 digital transition repacking. They also noted that TVStudy 1.2.8 treats all Class A low-power TV stations as digital, even though some continue to transmit an analog signal and a digital one on a second channel. This also could have a negative impact on the accuracy of interference calculations, they said. The team proposed using the analog channel in cases where that’s the only one licensed.

The methodology for calculating international interference is also skewed, they said. TVStudy 1.2.8 treats all border spectrum allotments as if they’re occupied at maximum power. The NAB proposed using actual interference data from Canadian and Mexican stations. In addition, the NAB urged the commission to nail down its international coordination agreements before the spectrum auction.

“Otherwise, TV stations will be stranded on spectrum identified for broadband or leave broadband use of recovered spectrum impaired indefinitely,” the filing stated.

The NAB refuted filings asserting that border coordination would be unnecessary with a variable band plan, or one that potentially frees a different amount of spectrum in each market. The FCC favors a variable band plan because it could raise more money from the sale of more spectrum. The NAB and Verizon oppose the idea. The NAB away team said most border stations could not be repacked without new agreements with Canada and Mexico. They also reiterated the NAB’s support for a contiguous band plan that doesn’t split the TV spectrum.

Also see…

August 22, 2013,
FCC Staff Demos TVStudy
he software developed to determine TV channel assignments following next year’s spectrum incentive auction can churn hundreds of millions of data sets requiring hours of processing. That would presumably comprise a final analysis of the entire United States.
August 20, 2013, TVStudy Update No. 3 Does Cross-Border Analysis
TVStudy Vers. 1.2.7 is said to be able to perform cross-border channel analysis of TV signal interference between stations in the United States and those in Canada and Mexico “on proxy channels.”

July 22, 2013: FCC Releases Channel Repack Analysis, Updated OET-69 Software
“One of the key advantages of the TVStudy Version 1.2 software is its ability to easily replicate multiple stations to generate various nationwide scenarios,” the commission said.

June 21, 2013, TV Band Proposals Diverge
No single solution is emerging for how the TV spectrum should be configured following next year’s incentive auction.

April 26, 2013, FCC Releases Updated OET-69 TVStudy Software
“This update addresses an issue with calculation cell indexing that can result in the population of some cells not being correctly considered, and which may cause the program to crash in unusual instances.”

February 6, 2013: NAB—OET-69 Update Injects Legal Uncertainty
Insiders say wagons are circling over the new methodology for predicting TV station coverage and interference.

February 5, 2013, “FCC Reveals Crucial Piece of TV Channel Repacking Model
The FCC has quietly revealed what amounts to its methodology for repacking TV channels in the post-incentive auction spectrum band. The agency released a new version OET-69 software that it intends to use for the repacking, and is seeking input on its efficacy.

January 24, 2013, “NAB, Wireless Providers, Agree on Contiguous Repack
Broadcast and wireless lobbies agree on one thing regarding how the TV band is repacked after the 2014 spectrum incentive auction: They don’t want to mix it up.



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Thursday 10:05 AM
NAB Requests Expedited Review of Spectrum Auction Lawsuit
“Broadcasters assigned to new channels following the auction could be forced to accept reductions in their coverage area and population served, with no practical remedy.” ~NAB

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