Repack-Ready? What to Expect

September 14, 2016

The FCC’s incentive auction is underway. Broadcasters have placed their bids to give up spectrum in the reverse auction and by the time you read this the forward auction should be under way. If the wireless carriers and others participating in the forward auction don’t bid enough to pay the broadcasters and cover the cost of the auction and repacking broadcasters, there will be additional rounds. There are different opinions on how many rounds will be needed, but at some point the auction will end.

In previous columns I focused on equipment selection for the repack. This month I’ll focus on the process, including the required FCC filings and opportunities for stations to maximize coverage.

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Repack timeline
Click on the Image to Enlarge

STARTING THE CLOCK
The post-auction transition period starts when the FCC announces the results of the incentive auction and repacking process in the “Channel Reassignment Public Notice” (CR-PN). The incentive auction determines if a channel can be found for a station using constraint files. This allows fast but not always optimum results. After the auction is over, the FCC will optimize the final channel plan before releasing the CR-PN to, among other things, minimize the number of stations that need to change channels; minimize the maximum aggregate new interference to any station; and avoid reassignment of stations with high anticipated relocation costs. That could take a few weeks.

Once the CR-PN is released, the clock starts for post-auction deadlines. Stations staying on the air that have to move to a new channel will have three months to file construction permits for any minor changes necessary to the facilities allocated by the FCC.

Form 2100 Schedule 399, a list of all repacking expenses eligible for reimbursement, also has to be submitted by the three-month deadline. The FCC will assign stations different construction deadlines, based on the circumstances of each station’s move. The deadline for all stations to move to their new channels is 39 months after release of the CR-PN.

The deadlines for stations giving up their spectrum will be based on when they receive their auction proceeds. Stations relinquishing their licenses and going off air will have three months to shut down and give up their spectrum. Stations giving up their spectrum, but keeping their license and sharing a channel with another station, will have six months to return their spectrum. These stations do not have to file a construction permit, but both stations have to file a Form 302 or Form 302-CA (if Class A) license application when the sharing starts and the spectrum has been returned.

The three-month window for filing the Relocation Fund Reimbursement Schedule 399 and the application for modified construction permit is short, considering that a station won’t know what channel it is being moved to, if it is being moved at all, until the CR-PN is released.

FILINGS: RELOCATION COST REIMBURSEMENT
You can get started on Schedule 399 now by downloading a copy at https://apps.fcc.gov/edocs_public/attachmatch/DA-15-1238A2.pdf. Since it may be difficult to get accurate costs in such a short period of time, the Widelity Report (www.fcc.gov/sites/default/files/Widelity%20Report.pdf) provides a good starting point. I copied the values into a spreadsheet and added some columns to speed cost-estimating.

The FCC will only reimburse “like-for-like,” so if you are making some of the improvements I talked about last month—such as adding elliptical polarization and increasing transmitter power—reimbursement will only cover the “like” part of the construction. Technology has changed since in the seven to 16 years since most full-power DTV stations were built and in the three years since the Widelity Report was created.

Exactly how much of the cost of replacing an out-of-date IOT transmitter with a solid-state transmitter isn’t clear. Nor is it clear to what extent the cost of a station building out a full-power new facility on their new channel—so they can continue broadcasting full power on their old channel until the channel change—will be covered. What if that facility, which starts as an “interim” facility, becomes the main facility? If your plans involve any of these situations and the FCC does not clarify how they should be handled on Schedule 399, once you have created a repacking plan, work with your FCC attorney to see how the estimated costs should be reported.

After the Schedule 399s have been filed, subject for fund availability constraints, the FCC will issue non-commercial broadcasters up to 90 percent of their estimated costs eligible for reimbursement and other eligible broadcasters, and MVPDs up to 80 percent of their eligible estimated costs. A final allocation based on actual costs, if appropriate, will be issued sometime prior to the end of the three year period.

FILINGS: INITIAL, FINAL AND TEMPORARY
During the three months after release of the CR-PN, broadcasters changing channels will have to file an initial minor change construction permit for the new channel. The FCC channel table will list facility parameters, including antenna height, location, pattern, ERP, etc. For stations with non-directional antennas that intend to replace their existing main antenna with one for the new channel, they can simply accept the FCC’s allotted parameters. In other cases, the modifications may be small—a minor change in antenna height if the new antenna is larger or smaller, a slight shift in location to specify a different tower, or modifying the polarity of the antenna from horizontal only to elliptical or circular.

For other stations, especially those with unusual directional patterns or with mechanical beam tilt, matching the FCC’s allotted facilities may be difficult, or even impossible. The FCC will allow a maximum one percent increase in coverage contour in any direction. The new facility must not reduce the population served by more than five percent. Stations moving from UHF to VHF or high-VHF to low-VHF are not subject to the one percent limit, but must not cause new interference other than a rounding tolerance of 0.5 percent to any other station.

After the FCC substantially finishes processing the initial minor change applications, stations assigned a new channel will have an opportunity to request a different channel in the same band and/or file for expanded facilities (> one percent contour extension). The FCC will give priority to those stations I mentioned above that can demonstrate it is impossible for them to construct the facilities with the technical parameters specified in the CR-PN.

The Media Bureau also has authority “to define other categories of stations that may be eligible for a filing priority due to extraordinary circumstances beyond a station’s control.” These may include, for example, stations using shared broadband antennas that cannot match the CR-PN specified pattern. Applications for new channels will be considered major change applications, applications for expanded facilities on the channel assigned in the CR-PN are limited to minor changes.

I suspect many stations with directional antennas will have to file in this second phase to maintain coverage if they can’t find an antenna they can install that can replicate the FCC allotted pattern with no more than one percent contour extension in any direction or if their original antenna was designed to protect stations that will no longer exist after the auction.

At some point after stations being assigned new channels in the repacking have had a chance to file applications, the FCC will lift the filing freezes now in place and allow stations—even those staying on their existing channel—an opportunity to file for modified facilities. In many areas, this may be the last opportunity for stations to optimize coverage! It is also an opportunity for stations in a market for file for a single frequency network (SFN). To summarize:

• Stations changing channels file initial minor change applications closely matching their FCC-allotted facilities;
• Stations changing channels can file for maximized coverage or new channels, with certain stations having priority, and
• Freeze lifted, any station can file an application to modify/maximize.

BUILDING IT
The applications I’ve referred to are for final facilities, but many stations will have to build temporary facilities either on their old channel or their new channel, to stay on the air while the main antenna is being changed out. These temporary facilities are likely to have less coverage and will require filing an application and getting a grant of special temporary authority.

Some of the options for broadcasters to consider include: Leaving the old facility intact and building out a new full coverage facility on the new channel; switching to an auxiliary broadcast facility on the old channel until the main antenna and transmitter can be replaced and the new channel switched on; or building a temporary (perhaps future auxiliary) facility on the new channel and waiting until the old channel is shut off before constructing the new main facility.

Which path to choose will depend on equipment and tower crew availability, when the transition to the new channel will take place, and perhaps what costs the FCC will reimburse. Unfortunately, I don’t see clear answers to any of those yet! Note that any construction done more than 39 months after the CR-PN is released won’t be eligible for reimbursement.

Next month, I’ll look at the impact of repacking on LPTV and translators, the timeline LPTV and translator operators’ FCC filings, and show an example of how TVStudy could be used to help select an antenna to squeeze an LPTV or translator into post repack crowded spectrum.

Doug Lung is vice president of Broadcast Technology, NBC/Telemundo stations. He welcomes your comments and questions. Email him at [email protected].

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