broadcast team wants a do-over of the TV channel repack plan created by the
Federal Communications Commission for the post-TV spectrum incentive auction
signal shuffle. The National Association of Broadcasters filed for a Petition of Reconsideration on the
FCC’s repack plan, issued in a Jan. 27,
2017 Public Notice. The plan is for broadcasters get off their
pre-incentive auction channel assignment within 39 months, no ifs, ands or
buts. The NAB and others in the broadcasting community have long held this
39-month window is insufficient to move as many as 1,274 full-power and Class A
TV stations—notwithstanding as many as 3,150 low-power TV and
translator licensees—into the 16 remaining TV channels. The NAB
stayed the course in its March
17, 2017 petition:
“The commission has not previously resolved critical matters with respect to
how best to organize this complex transition, and the Public Notice, which is
predicated on perpetuating the fiction that compliance with the arbitrary 39-month deadline is
possible, reflects a commission policy that should be promptly revised.”
The FCCs’ post-incentive auction scenario is roughly as follows. The current
and final phase of the auction, where wireless bidders jockey
for specific frequencies, will close
March 30. In April, the
commission will issue an “Auction
Closing and Channel Reassignment Public Notice,” in which new channel
assignment are published. Stations, however, should already be apprised of
their own assignments via confidential letters that went out a few weeks ago.
The channel reassignment PN triggers a couple of things—a 90-day deadline to apply for construction
and/or modification permits. In
other words, engineers for thousands of TV stations will have to anticipate
both the signal and coverage characteristics of a new channel as well as every
last resource to make it work.
After the 90-day permit window closes,
a testing phase will begin when
broadcasters can test gear on new channel assignments. Then the repack will
commence regionally in 10 phases
according to various factors, most of which boil down to the limited number of
tower crews with the skill and equipment to tackle tall steel. (See sidebar, “The
Phase Scheduling Tool,” Oct. 5, 2016.)
Then 39 months in, ready or not, broadcasters
must stop transmitting on pre-auction channels. That’s when
the wireless carriers, who purchased nearly half of the remaining airwaves
designated for local U.S. TV operations for $19.6 billion, will begin taking
over UHF Channels 38-50.
In its petition, the NAB said the FCC’s repack
modeling relied on “imprecise
proxies and inputs,” and that the deadline is being put in place “months
before the FCC has any meaningful real-world information about the work that
will actually be required to move any individual station.” It also said the FCC
plan does not take into account delays
due to things like municipal zoning
or acts of nature, including harsh winter weather.
The NAB said the commission’s repack plan places the 39-month deadline above
all other considerations, and that viewers
and FM listeners will pay for any
repack faux pas by losing coverage of stations that can’t
make the move within the prescribed timeframe. Many FM radio operations share towers with TV broadcasters, which the
NAB said the FCC’s plan should take into consideration. The Corporation for
Public Broadcasting has said at least
191 public radio stations will be affected.
The NAB said the commission should instead grant “reasonable requests for extensions of time.” The digital TV
transition took 10 years, it noted. The 800 MHz reconfiguration was supposed to
be done in three years and continues eight years past that timeframe.
“There is no reason to assume the commission’s ability to bend reality to its
deadlines has improved over time,” the petition said.
The NAB further urged the commission to delay
assigning stations to moving phases
until structural and engineering studies are done.
“Assigning stations to repacking phases and assigning deadlines for those
phases before the stations themselves know what work will be required is the opposite of a process tailored to
stations’ individual circumstances,” the NAB said.
The NAB petition also called on the FCC to have its Media Bureau manage the
repack, and have personnel in the field gathering and sharing information
on the unforeseen complexities. Currently, the commission has authorized periodic
reporting from affected stations. The petition also said the wiggle
room left in the FCC plan for international coordination with Canada and Mexico
is “unacceptable” in that the FCC should have figured it out before assigning channels.
“Repacked stations along the border
deserve to know now whether or not
their channel assignments will require coordination,” the petition stated.
 “Transition Scheduling Plan Webinar,” Oct. 17, 2016, p. 34.
 Presentation to FCC commissioners and staff by LPTV Spectrum Rights
Coalition, Feb. 28, 2017.
For more TV Technology coverage,
see our spectrum
39 Months or Bust”
There’s no avoiding a deadline.
Jan 27, 2017
“NAB Asks for Repack Reporting Tweaks”
Yes or no does not always the question answer,
the National Association of Broadcasters told the folks at the Federal
Communications Commission regarding a proposed form for periodic
Jan. 10, 2017
“FCC Seeks Feedback on Repack Reporting Process”
Stations eligible for reimbursement comprise all
full-power and some Class A stations involuntarily assigned to a new channel.
The PN said a “small number of Class A stations are not protected during the
repacking process, and if displaced as a result of repacking will not be eligible
Oct. 5, 2016
Repack Plan: Key Points”