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FCC Releases Updated Widelity Report
3/27/2014

Last week the FCC released the second version of Widelity’s Report and Catalog of Potential Expenses and Estimated Costs that broadcasters are likely to incur as a result of repacking channels after the TV Incentive Auction. This second version addresses some issues raised with the earlier version with regard to tower work and the impact on other broadcasters and users on shared towers.
 
Addressing one of NAB’s concerns that costs for interim facilities are reasonable and should be eligible for reimbursement, the latest Widelity report includes costs for interim facilities in all of its examples and notes. As an example, it notes: "Stations at shared sites that are not changing channel[s] may require use of an interim facility in order to accommodate the modifications of a repacked station that is transitioning to its new channel."
 
Widelity surveyed broadcasters and manufacturers in creating its latest Report. Some of the findings indicate that there should be sufficient manufacturing capacity to meet requirements for antennas and transmitters provided the orders do not come in at the same time but the document cautions: "A 'bunching' of requests immediately after repacking results are released may cause delay in the initial portions of the process."
 
Finding people to do the relocation appeared to be a bigger problem. Interviewees told Widelity that there are currently only five to 10 crews with the skills capable needed for working on "complex" towers. (Complex towers are those higher than 1,000 feet or with candelabras or other special conditions. Widelity said that while training additional crews may be difficult, given the transition time frame, "such opportunities should still be explored." Other options include bringing in crews from other countries, or pairing experienced crews with workers who have moved onto cell tower work.
 
Finding field engineers to handle the channel changes will be just as difficult. Widelity's report notes: "Each new installation or major modification will need field installation, tuning, and calibration of transmitter equipment by a broadcast field engineer. Each installation typically takes three to five days to complete. In the DTV transition period there were over 100 qualified field engineers working in the industry. As with tower crews, the demand for this type of work has sharply fallen off since 2009. Many have retired or changed careers and there are now an estimated 30 such engineers for the U.S."
 
Finding sufficient RF engineering resources is also likely to be a problem. Widelity says, "There are a limited number of RF engineering resources. Among other things, RF engineers will have to review channel assignment(s), work with antenna manufacturers, structural engineers, transmitter manufacturers and suppliers of mask filters, transmission lines, and combiners to develop the final transmitter-antenna configuration."
 
The Report notes that a "handful of TV station groups" have their own RF engineering resources; however, "in most cases, stations do not have comprehensive internal resources and consulting RF engineers will be needed to meet the analytical, coordination, and FCC compliance needs of the station."
 
It further stated that "the number of experienced practitioners has fallen with the downsizing of established firms, career and job changes (some have gone to work for the FCC), and retirement."
 
Widelity estimated there are approximately 35 qualified RF consultants, only half of which are positioned to handle more than five or 10 stations at a time. Widelity did not propose a solution to this problem.
 
As was pointed out in comments on the first FCC catalog of expenses, many of the towers in use today do not meet Rev. G standards and will need to be upgraded if the equipment on the tower is changed.
 
Limited resources to conduct structural analyses are likely to be another problem. Widelity discussed the matter with key industry experts from major engineering firms and estimates that a maximum of 40 structural analyses can be done in one month in the United States, assuming all firms operate a peak capacity. Widelity concludes, "If all of the stations turn to the structural engineers at one time, the limited number of resources may be overwhelmed. Therefore, proper planning and sequencing of the post-repacking transition process will be of paramount importance."
 
Widelity also outlined options for modifying solid-state and tube-type transmitters. Harris (now GatesAir) and Rohde & Schwarz indicated they do not expect manufacturing capacity problems and are prepared to meet the needs of the industry. Comark said they are expanding, but have a limited production capacity.
 
Widelity concluded: "We do not anticipate that there will be problems acquiring new transmitters if the process of ordering equipment is orderly and broadcast stations order equipment as early as possible. If broadcasters wait until late in the process it will cause orders and manufacturing capacity to be 'bunched' and could cause delivery delays."
 
Based on conversations with manufacturers, Widelity found that obtaining mask filters is not expected to be an issue. Supply of transmission line also does not seem to be an issue, although Widelity noted: "To meet a high demand, transmission line manufacturers recommended that orders be consolidated or otherwise coordinated to avoid piecemeal jobs and to allow uniform production."
 
The Widelity Report devotes several pages to antennas. Not surprisingly, the timing of the orders is the critical piece:
 
"In our discussions with antenna suppliers, they all stressed the need to 'smooth out' the ordering process. If the process of ordering equipment and materials is orderly, manufacturers can effectively schedule production, delivery, and installation of antennas. If the orders are bunched where everyone is trying to acquire the same equipment at the same time, there will be delays and difficulty scheduling the work."
 
The Report noted that manufacturers were confident they could increase output to meet the demands of customers and clients.
 
Widelity addressed concerns that stations moving to lower UHF channels would need larger antennas, thus increasing the load on towers. This may turn out not be a concern, however, as stations moving to lower channels will have to reduce power to avoid an increase in coverage. The way the FCC uses the dipole factor to determine service contours, a station operating with 1,000 kW on Channel 50 would need only 545.8 kW on Channel 20 for the same coverage.
 
An example in the Report shows how a 1,000 kW station on Channel 50 with a 26-bay slot antenna that's 39.8 feet long and requiring 42.56 kW delivered to the antenna could be replaced with an 18-bay slot antenna that's two feet shorter and requires a transmitter power of only 34.12 kW to obtain a 545.8 kW ERP.
 
Of course, this issue will reappear if the station is allowed to expand beyond its allotted replication ERP, or if different procedures are used for determining post-repacking ERP. Stations moving to a higher number UHF channel might require more power to match coverage, although it doesn't seem likely the FCC will allow power to go beyond 1,000 kW.
 
The Widelity Report and Catalog lists estimated prices for transmitters, transmission line and antennas that seem to be good average numbers. However, I can see cases where the costs will be higher. One of the studies in the Report addresses the San Francisco Sutro Tower. If you refer to the Report for details on what stations would change channels and details on the modifications required, the cost is estimated to be $11,887,000 and the estimated time required, assuming no glitches, was 41 months (three years and five months).
 
It may be possible to stagger the transition to the new channels. This would help ease some of the issues with limited resources essential to a successful repacking, but would require identifying which stations or regions could move without impacting their neighbors. It could also complicate channel changes at MVPDs. If the repacking is not staggered, then some stations may be left operating with limited power and coverage while waiting for other stations to complete preparations for a channel change. This is a very complex problem. The latest Widelity Report and Catalog covers topics I haven't discussed here, among them costs for MPVDs, management of the reimbursements, and critical planning and project management. We'll see what they've missed when the comments start pouring in.
 
I've only covered a very small part of the 84-page Widelity Response to the Federal Communications Commission for the Broadcaster Transition Study Solicitation – FCC13R0003. For information on filing comments, see the FCC Public Notice Media Bureau Seeks Comment on Widelity Report and Catalog of Potential Expenses and Estimated Costs. Comments are due by April 21, 2014, with reply comments due by May 6, 2014.
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