As of this month, the clock for the 2GHz relocation project taken on by Nextel (which recently merged with Sprint) has been ticking for approximately 15 months, or about half of the time the FCC allotted for completion of the broadcast auxiliary services (BAS) transition process.
The questions on many minds:
To be fair, nothing like this has ever been attempted. The schedule was tight to begin with, and there were no handbooks with an easy-to-follow game plan.
To understand where the process stands, one must be familiar with, or at least review, the original FCC timeline requirement. FCC document 04-168 was released on Aug. 8, 2004, and published in the Federal Register on Nov. 22, 2004, which is the official start date.
The document is officially titled “Report and Order, Fifth Report and Order, Fourth Memorandum Opinion and Order, and Order.” The confusing title is because the rulemaking encompassed by 04-168 covers nearly 10 years of ground, as well as FCC decisions, including:
- WT Docket 02-55;
- ET Docket No. 00-258;
- RM-10024; and
- ET Docket No. 95-18.
Reduced to its most basic meaning, Sprint Nextel has been granted the right to operate on frequencies at the low end of the 2GHz BAS band. As a part of this authorization, the company is obliged to relocate all existing broadcast licensees to new frequencies within 30 months of its acceptance of the FCC rulemaking. Even under absolutely ideal circumstances, this is a tall order. (See Table 1)
Prior to the project's start, Nextel had identified 210 DMAs, which the company said would have to be relocated at a rate of two to three per week. This meant it could take anywhere from five to 15 months to complete each DMA.
The fundamental steps each BAS licensee is obliged to follow in the relocation process, including time estimates are shown in Table 2. The first round of kickoff meetings began in April 2005. And the first four steps went rather well. Unfortunately, step five — the placement of equipment orders — proved troublesome.
It is interesting that NAB2006 served as the backdrop to remind everyone that one full year had elapsed since the project started. Relocation talk dominated NAB2005, and here we were at another NAB discussing it again, but not necessarily the same issues. Over the course of the year, sticking points emerged between Nextel and the broadcasters.
The first point of resistance were Nextel nondisclosure agreements that all stations are obliged to sign prior to starting the process. The reasons for the objections were simple. While the management in any given television station may be in fierce competition with others in the same market, the engineering crews are generally on good terms. As a matter of necessity and survival, engineers must cooperate or chaos would result.
The worry was that it would be nearly impossible to keep all terms of an agreement quiet. Also, there were questions about the need for secrecy when everyone is theoretically offered the same deal. While Nextel was able to put initial fears aside quickly, unanticipated problems soon developed.
The Sprint factor
On Aug. 12, 2005, Sprint announced the completion of its merger with Nextel, a process that had started with the initial announcement on Dec. 12, 2004. Certainly everyone involved in the 2GHz relocation was well aware of the impending merger, but the finality of the agreement caused some worries among broadcasters and manufacturers. Would Sprint maintain the same commitment to the project?
In a small industry like broadcast, rumors travel at the speed of light — regardless of their accuracy. The Sprint Nextel merger created rumors that still circulate, with the most prevalent being that the combined company will not continue to support the relocation. Fortunately, the facts do not support this rumor.
According to the terms of the merger agreement, the new company must honor the obligations, rights and responsibilities Nextel originally agreed to, including clearing (the BAS licensees from) 1.9GHz in accordance with the FCC's rules.
Inventory, quote, quote, quote, verification and scrub!
Sprint Nextel's computerized inventory process does an adequate job, but firsthand experience with entering the data and reviewing the reports proved that it can take time to understand the system and get it right. In most cases, it is an iterative process. Once the final Enter button is pushed, the Sprint Nextel verification crew compares the submitted inventory with the actual physical inventory and makes any needed adjustments, and then a “scrubbed list” is generated.
Although the verification process has been fairly painless, the company initially encouraged BAS licensees to start the quote process prior to completing an inventory. And the manufacturers were anxious to respond, until they became bogged down with quote requests and revisions.
The key problem is: Any change in the final inventory and resultant scrubbed list requires a new quote, as Sprint Nextel can only accept a quote that is in total agreement with the final scrubbed list. Once the initial bottleneck was recognized, Sprint Nextel and the equipment vendors finally decided that quotes should be solicited only when the final scrubbed list is complete and accepted.
The FRA roadblock
One of the biggest issues has been the final contract, known as the Frequency Relocation Agreement (FRA) between Sprint Nextel and the BAS licensee. The Nextel legal team prepared the original agreements and viewed things a bit differently than the broadcast legal teams. Not surprisingly, the whole conversion process soon ground to a halt.
In addition to contract language disputes, the issue of tax payments was raised. Effectively, Sprint Nextel is giving new equipment to the broadcasters, which must be treated as a “gift” according to the tax laws. Broadcasters wanted the free equipment, but didn't want to pay the taxes on it.
The resulting slowdown started effecting the vendors. The equipment vendors had built up large inventories and even hired additional help in anticipation of new orders. However, the predicted orders were not materializing. Many wondered if the whole relocation project was in trouble.
One year later
By December 2005, 500 stations had completed their equipment inventories. Even so, only a handful of equipment orders were shipped. With the project running slower than planned, an FCC progress report due soon and NAB2006 in view, Sprint Nextel made a series of procedural changes to speed up the process. (See Table 3.)
With the help of MSTV, the company released a revised FRA on April 4, 2006. The changes included clarifying terminology and an improved change order process that provides a mechanism for approval of unanticipated costs after the relocation is underway.
A new, five-person team was formed within Sprint Nextel to focus on the preparation of the FRA and to speed up the equipment cost estimates and implementation schedules. Also, as part of the closing process, the company now provides a summary of all payments made to the broadcaster and reconciles them against final receipts and invoices.
Other procedural changes included:
the addition of spectrum monitoring equipment as eligible for “comparable” facilities;
replacement of milestone payments with a monthly reimbursement plan;
improvements in soft cost spreadsheet models; and
clarification of the timing of quotes.
Sprint Nextel was highly visible at this year's NAB show. It provided a series of public and invitation-only presentations for BAS licensees and manufacturers. The company also circulated personnel throughout the convention halls, including at the booths of major equipment vendors. Staff was also stationed at the Sprint Pavilion in the LVCC monorail station. Presentations covered progress made, information on the training sessions, digital equipment operation, the quote process and relocation weekends.
Perhaps the most interesting aspects of the report card addressed what has actually happened to date vs. the original plan and the current plan for completion. As noted earlier, the original estimate for completing the 210 DMAs was based on two or three DMAs per week. The FCC mandate requires completion in 30 months (or 130 weeks), which is September 2007. Some DMAs were combined, but looking at the math completion, projections were:
105 weeks with two DMAs converted per week;
70 weeks with three DMAs converted per week; and
84 weeks with 2.5 DMAs converted per week.
That gave Nextel a built-in margin of 25 to 46 weeks in its original estimates to get the program under way. The process should have been in full swing by the beginning of January 2006 to meet the deadline. According to its original schedule, Sprint Nextel should have relocated 58 markets by NAB2006, but it had not completed any as of May 25. Between that date and Sept. 7, 2007, there are approximately 46 available relocation weekends, which means that an average of 4.5 DMAs must be converted per week in order to make the deadline.
Sprint Nextel still maintains that meeting the deadline is possible and is pushing hard to make it happen. However, the largest concentration of relocation activity appears to be scheduled from December 2006 through March 2007, which is in the dead of winter in many areas of the country.
Although many of the major roadblocks appear to have been eliminated, there is still a good deal of apprehension relative to the actual relocation procedure. Because no DMAs have been relocated, there is no way to gauge how the procedure will work in practice.
The basic working assumptions are:
All equipment in a given DMA has been installed and tested.
New frequencies have been locally coordinated and agreed to.
Each radio will require approximately 30 to 90 minutes to retune and test.
Everyone must agree to the change two weeks in advance and reverify readiness three days in advance.
Tower crews may be needed to change filters, etc.
A sanity check/progress assessment will be made at the midpoint of the change process, i.e. Saturday.
The weekend scenario may seem like a good idea, but not everyone agrees. A fair proportion of major news events occur over the weekend, and TV stations are generally at a skeleton staff level during these times. Weather-related issues could be a major factor, particularly in view of the fact that much of the activity is planned in winter. Without a doubt, a lot will be learned in the first few cutovers.
But wait, there's more
As if the whole relocation is not enough to deal with, there are two interrelated issues brewing that threaten to have an effect on the conversion process. One is FCC RM-11308, and the other is Department of Defense uplinks being allowed in the 2GHz BAS band.
Rulemaking RM-11308 is the result of an SBE Petition for Rulemaking proposing to modify the FCC's Universal Licensing System and FCC Form 601 to allow TV pick-up licensees the option of entering the coordinates and antenna height of ENG central receive sites. This would allow any potential AWS licensee to quickly and anonymously do a point-radius search and thereby avoid selecting a new site that may cause harmful interference to an existing ENG central receiver.
The petition was well received by the broadcast community, by virtue of the supporting comments filed by NAB, CBS, Cox, Disney ABC and Tribune Broadcasting. Incredibly, Sprint Nextel filed comments against the petition and maintains that it imposes additional frequency coordination requirements. The petition includes no such language, and Sprint Nextel has not provided any further clarification of its position.
Although not specifically a part of the Sprint Nextel relocation, the FCC has created a situation that may cause an additional threat to 2GHz BAS licensees that Sprint can help to mitigate. In accordance with WT Docket 02-55, U.S. Department of Defense (DoD) tracking, telemetry and commanding (TT&C) satellite uplinks will be moved from the 1761MHz to 1842MHz federal government Space Ground Link System band to the new 2025MHz to 2110MHz TV BAS band. This move was triggered by the reallocation of the 1710MHz to 1755MHz federal government band to the commercial sector to support even more Advanced Wireless Services spectrum.
The DoD uplink transmitters have power outputs up to +70dBm (10kW) operating into 30m uplink antennas with a gain of around 45dBi. This results in an equivalent EIRP of around 115dBm. The side lobe suppression of these uplink antennas is roughly 60dB. The result will be horizontal RF radiation and potentially toward an ENG site on the order of +55dBm. A typical ENG truck might operate with an EIRP around +65dBm, meaning the DoD uplinks could be operated co-channel. If so, then these interfering signals will be seen at the broadcaster's central receiver just 10dB below the desired remote broadcast truck's signal. Even if the DoD agrees to make every effort to avoid interference, without RM-11308, it will face the difficult task of contacting every TV station that may be affected by its transmissions to identify the locations and technical data of each ENG receive site.
Another recent development: In a total reversal of their original position, and perhaps as a sign of the pressure for timely completion, Sprint Nextel released a memo to BAS licensees on June 15. It's intent was to convey that Sprint Nextel would no longer pay to upgrade Microwave Radio Communications (MRC) CodeRunner radios, but would pay for new CodeRunners.
Although the basic message was there, the wording led many to believe that it was MRC's idea, and that MRC was unwilling upgrade its radios. This process will offer Sprint Nextel substantial cost savings, and the company originally applauded the MRC upgrade plan. On June 20, Sprint Nextel circulated a second memo clarifying that it was its decision, not MRC's, and that it had no concern about MRC's equipment or performance. The second memo also admitted that time was the main issue.
As noted in the beginning of this article, nothing like this has ever been attempted. As relocation continues, additional issues will surface. Sprint Nextel, BAS licensees, the FCC and microwave manufacturers must work closely together if this conversion is to succeed.
George Maier is the founder of Orion Broadcast Solutions, a broadcast consulting firm.
Thanks to the SBE for providing advance information about its white papers on RM-11308 and WT Docket 20-55.
Sprint Nextel broadcast relocation: www.2ghzrelocation.com
The SBE: www.sbe.org
The FCC: www.fcc.gov