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
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
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
“Otherwise, TV stations will be stranded on spectrum identified for broadband
or leave broadband use of recovered spectrum impaired indefinitely,” the filing
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.
August 22, 2013, ” FCC
Staff Demos TVStudy
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.
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
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.
21, 2013, “ ” TV
Band Proposals Diverge
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