—AT&T is endorsing a regional repack and calling on regulators to get cracking on a plan.
“Execution of large-scale projects with complicated requirements like those contemplated by a robust broadcaster repacking plan contain inherent challenges and risks,” wrote AT&T’s Joan Marsh in a March 14 filing
with the Federal Communications Commission. “We’ve seen this play out time and again, including with the DTV transition—which took well over a decade to complete and merited three Congressional extensions of time—and with the 800 MHz rebanding effort, which commenced June 27, 2005 for a proposed 36-month timeframe but is still ongoing today.”
The 800 MHz rebanding involved a repack of public safety radio users in spectrum adjacent to cellular frequencies. AT&T, expected to be one of the biggest buyers in the upcoming TV spectrum incentive auction, wants to take possession of that spectrum as soon as reasonably possible.
Debate continues over how long it will take to repack the TV stations that remain after the auction into whatever amount of spectrum is left.
Current FCC rules lay out a 39-month window for several hundred TV stations to move to a new channel assignment. The National Association of Broadcasters has been saying for some time that 39 months is inadequate, and that fewer than half of the stations that will need to move could be accommodated in this timeframe. This primarily would be due to potential constraints in the necessary supply chains, including tower crews. T-Mobile, however, also expected to bid in the auction, disputes this.
Though Marsh, vice president of Federal Regulatory at AT&T, was decidedly stern about the timeframe, she neither advocated nor opposed the 39-month window.
“The 800 MHz rebanding effort began with the belief that the band could be fully re-organized within 36 months,” she wrote. “We now know, in hindsight, that the effort will in fact take more than a decade to complete.”
Marsh went on to outline AT&T’s proposal for a repack plan and suggested the FCC be ready to release one within three to six months after the auction closes. She suggested that the commission appoint a Transition Administrator to start collecting data now for a regional repack in order to avoid a “daisy-chain effect.”
“A schedule slip by a single station could impact the ability of other broadcasters or an entire region of broadcasters to complete their relocation,” she wrote.
It would be up to the Transition Administrator to define the regions where channel moves would take place first based on several variables, including population, weather concerns, international coordination and availability of tower crews. Marsh and others reason that a regional repack will allow tower crews to move from one market to the next versus bounce from job sites on one end of the country to another.
It also would fall to the Transition Admin to handle waivers, which Marsh said the FCC should anticipate—in some cases due to circumstances beyond anyone’s control. Hurricane Katrina compelled a modification of the 800 MHz rebanding plan, Marsh noted.
“The FCC must have resources in place that can review waiver filings as soon as they are completed and act quickly to resolve issues raised in such filings to keep the broader transition activities on track,” she said.
Marsh also emphasized the need for “extensive outreach” to affected broadcasters who will have to commission engineering studies, order equipment, modify facilities and obtain the necessary permits in coordination with neighboring broadcasters, cable operators, FM radio broadcasters, public safety agencies, wireless licensees and wireless microphone users.
She said the Transition Administrator should be maintained to track the repack, provide quarterly progress reports and identify any potential complications. She also said consumers need to know what’s going on.
“As regions are cleared, impacted broadcast stations will need to flash cut to their new channel assignments on a designated date and consumers in each region will need to be educated on the steps they will need to take to continue to receive over-the-air broadcast content from stations that have relocated,” she said.