WASHINGTON—The FCC is inclined to allow KGW-TV Portland, Ore., to change from a VHF to a UHF, but is seeking input on that inclination.

It has given commenters until 25 days after publication of Wednesday's (Oct. 14) petition for rulemaking in the Federal Register, which usually takes a couple of weeks.

There has been a freeze on such changes for almost a decade, dating from when the FCC first started to prepare for the 2016 broadcast incentive auction.

KGW-TV is seeking a waiver of that freeze so it can move from channel 8 to channel 26 and thus from VHF to UHF and better serve its viewers given that UHF is the stronger signal in digital, as VHF was in analog.

KGW-TV licensee Sander Operating Co. said that ever since the 2009 digital switch, it has gotten "a steady stream of complaints from viewers unable to receive the station’s over-the-air signal, despite being able to receive signals from other local stations.”

Sander said it has determined that its move to a UHF channel, including the equipment vendors involved, will not impede any repack-related efforts by other stations in its market.

In response to the request, the FCC said: "We believe that a waiver of the channel substitution freeze would serve the public interest." One thing arguing in favor of the waiver, the FCC suggested, would be that relatively few viewers would be adversely impacted. "[T]he Commission has found that population loss of less than 500 persons is de minimis,18 and the predicted population loss is only 417 persons who would not otherwise be well-served," it said.

WASHINGTON—The fiscal year 2019 came to a close at the end of September, but there is still discussions on the FCC’s process of collecting regulatory fees for that year. And according to the NAB, some revisions are needed, specifically regarding the fees of VHF stations.

Commenting on a Further Notice of Proposed Rulemaking, the NAB requests that the FCC revise proposed regulatory fees for VHF stations so that they “more accurately reflect their actual population served,” the comments read.

The way regulatory fees were determined was changed in 2018, switching from Nielsen Designated Market Area groupings to population covered; FY2019 was the first year implementing this measurement tactic. The NAB does agree with this approach, but believes that it has a flaw that “unjustly” impacts VHF stations.

Using a station’s noise limited service contour (NLSC) as a basis for regulatory fees negatively impacts VHF stations operating at power levels above their normal maximum level to overcome environmental noise in a digital world, wrote the NAB. This in turn can extend the reach of many VHF stations, however the quality of the signal is weak because of different hindrances, NAB continues.

As a result, the NAB contends that “the new regulatory fees for some VHF stations are artificially high because they are based on viewer population figures that include viewers who are not able to receive a viewable signal.”

In addition, due to the broadcast spectrum repack, some TV stations have moved from UHF to VHF or to a lower frequency VHF channel and have not been able to officially determine their population served, which in turn does not allow them to gauge the effects of the new regulatory fees on their operating budgets.

“NAB believes that a more reasonable approach would be to calculate fees for such VHF stations based on a station’s contour under the commission’s original assignment of technical parameters during the DTV transition,” the organization wrote, calling it a more accurate reflection of a VHF’s station actual coverage and population reach.

To read NAB’s full comments, or other related comments filed, visit the FCC’s ECFS.

WASHINGTON—With its official publication in the Federal Register on Oct. 23, the clock is now ticking for interested parties to submit comments regarding the regulatory fees of VHF stations to the FCC, specifically whether they should be lowered or not.

The FCC officially adopted this Notice of Proposed Rulemaking back on Aug. 15, but now appearing in the Federal Register gives a 30-day window to submit comments and a 60-day window for reply comments. The exact deadlines are Nov. 22 for comments and Dec. 23 for reply comments, though it is possible the FCC may extend due to the Christmas holiday.

VHF broadcasters have been arguing that the predicted contour distance used by the FCC to determine a station's reach, for which their regulatory fees are based, is not the most accurate representation of a station’s actual reach. Some examples of elements that could be impacting these numbers includes terrain blockage.

If such is the case, broadcasters argue that regulatory fees should be adjusted to more accurately represent their reach.

The FCC is seeking comment on if this is the case and how they should then go about addressing such concerns.

WASHINGTON—The FCC has released its status report on the post-broadcast incentive auction TV station repack, which involves most of 1,000 full powers and 2,000 low powers in a 10-phase plan, and as FCC Chairman Ajit Pai signaled last week, the commission is ahead of schedule. It is also freeing up more money for the TV station transition.

"We are pleased to report that the transition is off to a very strong start on all counts, and that the Transition Scheduling Plan and the Commission’s rules, procedures, and systems are operating as designed and anticipated," the Incentive Auction Task Force and Media Bureau said. "[T]he transition is ahead of schedule both in terms of the number of stations that have already vacated their pre-auction channels and the amount of 600 MHz spectrum that has been cleared and therefore made available for use by wireless auction winners.

The FCC said that among the wireless carriers, T-Mobile, the auction's biggest winner, said it has already launched service using its broadcast spectrum in more than 1,500 cities in 37 states and Puerto Rico.

The auction closed April 13, 2017, with 84 MHz of spectrum raising almost $20 billion, including $7 billion for deficit reduction. The stations being repacked into new channels so the 84 MHz can be used by wireless carriers have until July 3, 2020, to make the move.

Only 175 stations agreed to give up spectrum, but another 987 stations had to be reassigned to new channels to free up that 84 MHz spectrum.

Those 175 stations have already been paid over $10 billion, the FCC said.

Of the 175, only 41 went off the air, with 30 changing from UHF to VHF licenses and the other 104 striking deals to share channels with another station.

Phase one of the 10-phase transition ended Nov. 30, 2018, with all stations meeting their deadline, except those granted extensions or moves to other phases. Even so, some other stations in other phases moved early, so that 172 stations have made the move, or 17% of the total 987 repacked stations vacating their pre-auction channel.

The FCC announced that it would be allocating an additional $68.1 million to 316 full power and Class A stations from the incentive auction repack fund created by Congress, boosting the total allocated so far to $1,808,722,301.

For all the latest news and insight on the repack, visit our repack silo.

SOUTHWICK, MA—WGBH Educational Foundation has ordered two new VHF Parallax liquid cooled DTV transmitters from Hitachi Kokusai Electric Comark LLC for its WGBH Boston PBS station and the WGBY PBS station in Springfield, Mass. Both stations are in the process of a post-spectrum auction channel repack.

At WGBH, Comark will supply a multicabinet Parallax VHF band 1 liquid cooled transmitter on channel D5. The transmitter is designed for initial operation at 7.5kW TPO but allows for future power upgrades up to as high as 55kW should the station decide to maximize their ERP in the future. The transmitter cabinets will be pre-wired to facilitate a quick upgrade with additional power amplifiers and PA combiners.

In addition, Comark will supply another Parallax VHF band 3 transmitter on D13 for WGBY. The WGBY transmitter will be configured for 1+1 redundancy with a main/standby configuration. Each half of the transmitter can fully supply the required 13kW TPO with custom RF switching between transmitter cabinets. Both cabinets will be pre-wired to accommodate future power upgrades.

Comark will manage all aspects of both transmitter installations including program management, equipment delivery, on-site installation, and proof-of-performance testing. Both transmitters are fully upgradeable from ATSC 1.0 to ATSC 3.0 due in part the EXACT-V2 exciter technology.

[Read: Maryland Public TV Chooses Comark Parallax UHF TX]

“We expanded our Parallax product line from UHF to VHF band 3 and most recently to cover VHF Band 1” says Dick Fiore, President and CEO of Hitachi Kokusai Electric Comark, LLC. “WGBH/WGBY has been a long standing customer of Comark for many years, having previously purchased their original UHF DTV rigs from the transition from analog to digital. We are very pleased to be working again with WGBH Educational Foundation on this exciting project.”

“WGBH is looking forward to continuing our long relationship with Hitachi-Comark” says Emeric Feldmar, Director of Engineering at WGBH. “We have received excellent products, and support throughout the years. We purchased these Parallax VHF band 1 and band 3 transmitter systems for our WGBH and WGBY facilities that are being upgraded as a result of the spectrum auction/repack with capability to upgrade to ATSC 3.0.”

For more information on the repack, visit TV Technology's repack silo.

NILES, ILL.—Shure’s ULX-D digital wireless system and related accessories are getting a new component to its make-up, as the company announced they are now available in the VHF frequency band; Shure’s QLX-D digital wireless system will follow suit early next year. The VHF option will provide users with 42 MHz of tuning bandwidth in the spectrum.

ULX-D

The new VHF band ULX-D and QLX-D systems offer alternatives to the increasingly crowded UHF TV Band, which includes systems capable of operating in the 900 MHz band (ULX-D, QLX-D and PGX-D), DECT (Microflex Wireless), and 2.4 GHz (GLX-D digital wireless).

Features offered from the ULX-D and QLX-D system include spectrum efficiency, recharging accessories, networking options and rugged construction. Individually, ULX-D offers efficient RF performance, network control, Dante digital audio and AES-256 encryption for professional sound reinforcement. The QLX-D will deliver streamlined performance with transparent 24-bit digital audio, as well as wireless functionality for live sound events and installations.

New, VHF-ready accessories will be available with the VHF versions of ULX-D and QLX-D. These include the UA844+V antenna distribution system, UA834V in-line amplifier, UA874V active directional antenna, and UA860V passive, ground-referenced omni-directional antenna. The UA845UWB antenna distribution system is also available, as it is switchable for UHF/VHF.

JOHNSTON, IOWA--I recently fielded some questions from a colleague regarding the upcoming spectrum auction. The colleague observed that it appeared that the FCC was clearing the way for UHF stations that wanted to participate in the auction but still stay on the air to move to low-band VHF. He wanted to know what my feelings were on moving to low-band VHF and wondered if stations would really move there.

The decision on low-band VHF is really a business decision. I am a huge fan of over-the-air broadcasting and have that capability in my home. I travel with a USB tuner stick that lets me look at DTV services when I am on the road. But even I recognize that the majority of people that watch OTA broadcasts do it via a subscription-based service; thus they are not receiving the over-the-air services but a redistribution of which, in many instances, is provided via a direct feed from the stations' studio rather than receiving the over-the-air signal.

In my opinion, low-band VHF is what I would call a "technological cul-de-sac." It was a great technology in the early days of broadcasting when making power was an expensive proposition and generating RF at frequencies above 100 MHz was a challenge to do and keep stable, and receive antennas were mounted on the outside of homes high above the roof. Low-band VHF offered great “bang for the buck” for economical operation and the signals traveled considerable distances, even over the horizon. There were few television stations and few man-made noise sources to disrupt the service and when problems happened they were pretty easy to diagnose and correct. When I worked for WSAZ (channel 3) in Huntington, W.A., I frequently found power poles with dirty insulators using just my Sony Watchman as a locator and calling the power company to report down to the pole number the insulators that needed to be cleaned in a rural area.

NOISIER ENVIRONMENTS

Now the entire environment has changed. The number of stations increased to the point where the ability of low VHF strength to travel great distances has become its weakness because of interference, resulting in power levels being reduced to the point of absurdity. The man-made noise environment has swelled to the point where the issues for reception may not be a just a power pole in the area but with the hundreds, if not thousands of other man-made noise generators that raise the noise floor while the interference protection requirement lowers the signal level. Antennas are no longer on roofs but at best in an attic, but more frequently sitting on a table inside the house near the television creating the necessity for the diminished low VHF signal to overcome the increased noise level as well as endure the added loss of building penetration and complex echo environment within the home. In my opinion, the time for low-band VHF technology for television broadcast has passed and if the decision were to be based on technical criteria only, it is an easy decision to make.

But as I said before, it is a business decision. If the majority of the viewers are relying on a subscription-based delivery mechanism, there are compelling reasons to consider low-band VHF; cost of operation certainly being one. I recently did some computer modeling for a UHF station that is considering moving to low-band VHF as one possible scenario. Using their existing tower location, antenna elevation and the FCC's methods for replicating coverage, their effective radiated power went from 85,000 watts down to 360 watts. Assuming they use a reasonable VHF transmitting antenna with a gain of 4 and allowing for losses through the passive RF system, their transmitter is in the neighborhood of 100 watts of DTV power; so the transmitter would consume less energy than most microwave ovens.

Couple that with all of the specialized HVAC and associated requirements at a traditional transmitter site that is no longer required and the cost of operation would become inconsequential compared to the UHF costs. So for the cost of operation of a few household appliances this UHF station would be able to replicate its coverage and maintain its carriage rights within the same service area. Add to that the FCC—through the spectrum auction—may compensate stations for a significant percentage of the value associated with the UHF spectrum they are vacating in favor of the less desirable low-band VHF and from the business perspective, this could be quite attractive.

BUT THEN THERE’S 3.0…

Now of course what the station is sacrificing is reliable OTA indoor reception and future reception on portable devices which is one of the key benefits that the ATSC 3.0 proponents are working towards. I am also a big fan of ATSC 3.0 and the capabilities that it promises but until it is deployed, all of its benefits are theoretical in the eyes of the marketplace. And if it isn't widely adopted by broadcasters and consumers, it is a great idea whose time did not come. So going back to my original business decision, if I believe that my business is to provide a few real-time streaming services—as is the traditional digital broadcast model—then moving to low-band VHF lets me stay in the business that I am already in, significantly reduce my costs of operation, and may provide a significant infusion of cash to help sustain the business from auction proceeds. 

On the other hand, if I believe my business has to change and adapt to the new audience behavior patterns, I have to recognize that the audience is mobile and wants the capacity for various levels of interactivity and additional capabilities over and above streaming. In that case, the business decision would be to stay with the UHF spectrum and plan for the adoption of ATSC 3.0. I would not make decisions that would preclude the business from succeeding with the changing audiences or limit my availability based on the already well-known and well-understood limitation of low-band VHF.

Bill Hayes is the director of engineering for Iowa Public TV.