The commission is setting a deadline of summer 2014 to begin reassigning spectrum to wireless and mobile service providers by 2014. Although there has never been any question about who it prefers in these proceedings, the NPRM was blunt in its assessment of the current broadcast TV model. Nevertheless it also acknowledges the continued importance of broadcasters.

“Broadcast television stations provide free video programming that is often highly responsive to the needs and interests of the communities they serve,” the FCC said in its notice. “Among other things, broadcast television stations provide children’s educational programming, coverage of community news and events, reasonable access for federal political candidates, closed captioning and emergency information. A small but significant segment of the nation’s population relies solely on over the air broadcast television stations for video programming service.”

And yet the commission also wants to use Nielsen ratings to help determine how useful broadcast TV is to consumers.

“Although broadcast television continues to be a vital source of local news and information for most Americans, the other offerings in the video programming marketplace have diverted much of broadcast television’s over-the-air viewing audience over the years,” the commission said, adding that according to Nielsen, “only” 10.7 million television households, or approximately 10 percent of the total, rely solely on over-the-air broadcast television.

So there you have it. Even though it says that broadcasters are a “vital source” of information, apparently the FCC has decided to equate the popularity of “Mad Men” and the polarization of cable news networks with the value of free over-the-air broadcast news, emergency alerts and public service programming.

Whether certain broadcasters decide to cash in on the auctions is up to them, and granted, there are a lot more elements to this process than comparing the relevance of over-the-air TV with pay-TV in determining value. But as Commissioner Mignon L. Clyburn said in her comments at the NPRM’s release, “the word ‘voluntary’ is the most important word contained in all of the pages that comprise this document.” And before any broadcaster volunteers to enter into such an arrangement, it deserves to know more about the “unknowns” the FCC admitted to in its notice.

For this NPRM, the devil may be in the details, but some of those details are lacking, such as the commission’s acknowledgement that its Allotment Optimization Mode is a simplified formula for determining broadcast interference. The commission admitted in its notice that the repacking process will be a “complex engineering problem.” It’s up to broadcasters to not allow the commission to bypass or overlook basic physics and engineering principles in favor of expediency.