At the FCC’s TV Broadcaster Relocation Fund Workshop this week, it was obvious there were a lot of questions and very few, if any, answers to how the repacking of TV channels after the spectrum auctions will play out. One thing was clear—if a large number of stations have to relocate to another channel, there most likely won't be the resources available to accomplish this in the three years allowed by Congress.
The FCC staff that organized the workshop deserve credit for selecting panelists with expertise on what the relocation will likely entail. The panelists included Jay Adrick, vice president of Broadcast Technology for Harris who came well prepared with the data to highlight the challenges stations will face in changing channels; Patricia Tikkala, vice president of Spectrum for Sprint Nextel, who had firsthand knowledge of the complications and delays involving tower work, new equipment and reimbursements for the 2 GHz BAS relocation; and Jane Mago, executive vice president and general counsel for NAB who didn't hesitate to jump in to emphasize the issues broadcasters were facing and the protections afforded them by Congress. Rebecca Hanson, Senior Advisor and Special Counsel at the Media Bureau moderated the panel and William Lake, Media Bureau Chief, opened the forum. Brett Haan, principal at Deloitte Consulting, LLP provided valuable information based on reallocations for other services but, in my opinion, didn't appear to grasp all the difficulties broadcasters will face in changing channels.
Rather than go into detail on the entire workshop, I will focus on some of the data Jay Adrick provided. A key point is that there are only 14 crews qualified to work on tall towers and remove and replace antennas on them. Adrick estimated this typically takes 5 to 6 weeks. Based on my experience, that's probably best case, as missing parts, weather, and crew and equipment getting stuck on other jobs can cause this time to double. Even if we accept six weeks as the average, with a crew working 48 weeks (you have to allow for time around the holidays and for travel), this means each crew can do eight jobs per year, or a total of 24 jobs in the three years allowed by Congress. With 14 crews, that means a total of 288 stations could change out antennas on tall towers in three years, assuming they are able to start the day that three-year period begins. That's unlikely as engineers won't be able to design antenna systems, order equipment, and schedule until the new channel plan is known.
Based on the chart in my March 28, 2012 TV Technology article How Will Spectrum Auctions Impact Broadcasters, if the FCC takes away 48 MHz of spectrum and requires all stations above Channel 43 to move, fewer than 300 stations would need to change channels. However, to make room for those stations, other stations below Channel 43 may have to move. Some stations may decide to give up their spectrum and share with another channel, allowing more spectrum, but based on this one example it appears the amount of TV spectrum the FCC could expect to reclaim and have broadcasters make the transition in three years would be 48 MHz at most. Even that would require the FCC to allow for some time after the new channel plan is adopted for stations to design antenna systems and schedule crews before starting the three-year clock.
The other question, of course, is whether or not antenna manufacturers could build enough antennas in a three-year time frame. Since the completion of the DTV transition and with the uncertainty over the spectrum auctions, manufacturers have reduced staff. There are not that many companies able to build high-power TV transmitting antennas. Adrick also pointed out that many towers do not meet the current ANSI/TIA 222-G specifications and if any work is done on them, the tower may require modification or replacement before it can be permitted or insured. That would certainly add to that six-week timeframe as well as the cost of the relocation.
Adrick, Haan, Tikkala and other members of the panel kept emphasizing the need for planning and scheduling all of this work, but as Adrick pointed out several times, we can't start the planning until the auctions are over and stations know what channel they will be moving to. I would add that it would even be difficult to get manufacturers to staff up to handle additional work without knowing how many stations are likely to be affected.
I would expect that even if few stations offer up their spectrum for auction, the FCC will attempt to find additional spectrum by displacing LPTV stations to open up channels and remove inefficiencies created during the DTV transition so that it isn't inconceivable that more than 300 stations will need to be relocated. This will likely be impossible with the time and money allowed by Congress. When this issue was raised, Hanson suggested Jane Mago and broadcasters could go to Congress and get more time and more money. You can view the webcast to hear all of the problems with reimbursement, a primary one being that many Public TV (PTV) stations are not allowed to order equipment without funding in place.
The question and answer period also provided some interesting insight. Greg Herman and an associate at Spectrum Evolution raised some interesting questions. His suggestion that LPTV stations could help during the reallocation was largely dismissed, as it was pointed out the over-the-air audience was important and broadcasters were unlikely to give up the coverage. It wasn't mentioned that many LPTV stations themselves are likely to be displaced and those lucky enough to find another channel will probably end up on unwanted low-VHF Channels 2-6. LPTV stations that change channels will not be reimbursed.
There was a question concerning the “flexible use” part of the Spectrum Act, which allows flexible use of the spectrum to broadcasters in lieu of reimbursement. The FCC panel members apparently hadn't considered this could be interpreted to mean using a different modulation method.
Before the end of the year the FCC will issue Notices of Proposed Rulemaking and take other actions to set the procedures for the incentive auctions of broadcast TV spectrum. This week's forum indicates the process will be more difficult than many imagined. The good news is that events like this week's forum highlight the issues and provide an opportunity for everyone to work together to minimize the problems. It was very clear from all the participants that stations will have to make every effort possible to complete the reallocation and there will be little if any tolerance for stations that attempt to delay it.