Broadcasters Seek FCC’s Spectrum Repacking Model

WASHINGTON: A coalition of TV stations and their supporters are calling on federal regulators to reveal their predictive model for auctioning off TV airwaves and repacking stations in whatever remains. The Advanced Television Broadcasting Alliance is asking the Federal Communications Commission for the “immediate release” of its Allotment Optimization Model. The AOM will be used to project an outcome depending on how many and which TV stations do or don’t give up spectrum. The AOM is necessary because relinquishment is voluntary. There’s no way to anticipate precisely how much TV spectrum will be freed up for the commission’s National Broadband Plan.

The FCC first presented a conceptual AOM in June of 2010. Broadcasters are still waiting to see a working model. The Alliance, made up of members of the Coalition for Free TV and Broadband, noted that FCC Chairman Julius Genachowski said the AOM would be released when Congress granted auction authority to the commission. The commission needed Congressional authority to split auction proceeds with broadcasters, providing the incentive for them to give up spectrum. That authority was granted in February with the passage of the “Middle Class Tax Relief and Job Creation Act.”

“With the complexity, the unknowns, the severe impact of the repacking on local television, the Alliance strongly suggests it is time to release the AOM,” the group said in a statement released today.

The group’s request follows on an exchange between Rep. John Dingell (D-Mich.) and FCC Chairman Julius Genachowski several months ago. Dingell first asked for the AOM last June.

“I understand that the commission has developed an Allotment Optimization Model that has been used to investigate various scenarios for incentive auctions, including spectrum reclamation and repacking. I recognize that these are investigative scenarios and may vary from results in reality,” Dingell wrote in a letter to Genachowski. “Nevertheless, this analysis would be as helpful...”

Dingell went on to request the analysis of certain scenarios, and asked when the AOM would become available to the public. He requested a response by the end of June. Genachowski did not respond until early August, telling Dingell the AOM was still “a work in progress.”

“...and I am deeply concerned that disclosure of predecisional information would potentially damage the commission's deliberative processes, as well as result in needless public confusion about the status of the commission’s work on the voluntary incentive auction concept,” Genachowski wrote.

“Should Congress grant the commission the ability to conduct voluntary incentive auctions, I commit to you that we will put the then-current—and further refined—version of the AOM out for public comment before setting the rules for the auction,” he continued. “The result will be a full, fair and open process that will allow for a complete review of the methodology, data and assumptions the commission will ultimately use to implement that authority.”

Dingell flamed Genachowski over his refusal, inferring that it would affect the vote on spectrum auction authority, but that didn’t come to pass. Congress ultimately used auction authority as a pay-for to extend unemployment benefits.

Genachowski had told Dingell at the time that Technical Paper No.3, “remains the touchstone of the commission’s work and is available for all public parties to use to conduct hypothetical modeling.”

Technical Paper No.3 presents the conceptual version of the AOM. Radio frequency and transmission expert Doug Lung called the paper “biased, incomplete and, in some ways, inaccurate.” Lung, a long-time contributor toTV Technology, said,“Critical information is missing and conclusions are presented as fact when data doesn’t support them.” (See “FCC Spectrum Analysis Doesn’t Add Up.”)

Lung said that model would yield only a fraction of the 120 MHz of TV spectrum the commission seeks to reclaim, if all existing full-power TV stations remained operational. In a separate analysis, Bruce Franca of the National Association of Broadcasters said reclaiming 120 MHz—
-40 percent of the spectrum dedicated to TV broadcasting—would knock about 210 full-power stations off the air.

Since receiving auction authority in February, the commission formed a task force to manage the auction process, but no further AOM has been released.

~ Deborah D. McAdams
February 23, 2012:“Obama Signs Spectrum Auction Authority Bill”
TV spectrum can officially go on the auction block.

June 20, 2011:“Congressman Asks FCC To Explain Its Spectrum Analysis Model”
John Dingell wants to know how many people would lose over-the-air TV if broadcasters lose 40 percent of their spectrum.