FCC Repack Plan: Key Points

TV Technology gleaned some key points from the phased-in repack plan proposed by the Federal Communications Commission last Friday
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WASHINGTONTV Technology gleaned some key points from the phased-in repack plan proposed by the Federal Communications Commission last Friday. (See, “FCC Proposes DMA-Level Phased Repack,” Sept. 30.) Comments on this plan, described in the Transition Scheduling Plan Public Notice, are due Oct. 31. Replies are due Nov. 17.

The quiet period prohibiting auction participants from communicating about bidding continues to apply during this comment-reply period, but is not meant to “discourage stations from proposing transition solutions that would reduce reimbursement costs or implement a marketwide transition plan that broadcasters may independently develop,” such as American Tower Corp.’s broadband antenna proposal for large markets, the TSPPN states.

(TV Technology will present a Q&A with ATC’s vice president of Broadcast, Peter Starke, on the company's Broadband Antenna Initiative, next week.)

KEY POINTS:

  • The commission ran repack scenarios for both a 114 MHz and an 84 MHz clearing target. (The current clearing target is 114 MHz. If the auction does not close at this target, it will drop, most likely to 84 MHz.) 
  • At 114 MHz, 1,393 stations have to move.
  • At 84 MHz, 1,274 stations have to move.
  • FCC will finalize repack during the forward auction clock phase once the final stage rule is met. 
  • At that point, each station eligible to remain on the air will receive a confidential letter with channel assignment, technical parameters and assigned transition phase. 
  • Once the forward auction closes, the FCC will release an “Auction Closing and Channel Reassignment Public Notice” listing all post-auction channel assignments, technical parameters and repack deadlines.
  • These deadlines comprise 10 transition phases, each with sequential testing periods and phase completion dates.(The commission seeks feedback on whether or not it should consider completion date waivers in some cases.) 
  • All stations within a Designated Market Area will be assigned to no more than two transition phases.
  • Transition phases will all begin at the same time, but have sequentially phased completion dates
  • Stations moving to new channels will have three months from the release of the “Auction Closing and Channel Reassignment PN” to apply for construction permits for facilities modifications. 
  • The construction permit deadline will be the phase completion date for that station.
  • With the exception of the first transition phase, the testing phase will begin the day after the phase completion date. Equipment tests on post-auction channels will be confined to a station’s specified test phase. 
  • Stations that may experience or create interference at new channels will have to coordinate equipment testing as part of a “linked-station set” in a daisy chain, illustrated above right.
  • At 114 MHz, 799 stations are linked to others.
  • At 84 MHz, 710 stations are linked.
  • This coordination may involve operating at a lower power or accepting more interference during testing. 
  • Stations that are not part of a linked-station set may commence testing without coordinating it with their spectrum neighbors. 
  • The commission is proposing to allow a 2 percent increase in temporary pairwise interference during the transition, and no more than 0.5 percent afterward. 
  • The FCC’s Media Bureau will use two software programs to establish the repack process:

— The Phase Assignment Tool will assign TV stations to a specific transition phase based on constraints designed to minimize interference as channels are assigned in the auction process. These constraints include:

  1.  Causing no more than 2 percent new interference to another station during the transition.
  2.  No Canadian stations will be assigned before the third transition phase, and none will be assigned temporary channels.
  3.  No more than 10 transition phases.
  4.  No temporary channels will be assigned, with the possible exception of stations in complicated interference dependencies and those close to their post-auction channel assignment. (Discussed further below.)
  5.  At least one, but no more than two transition phases per station.
  6.  No phase can have more than 125 linked stations.
  7.  No station in a “complicated” interference-interdependency will be assigned to the first phase.
  8.  A difference of no more than 30 stations between the largest and smallest transition phases.

— The Phase Scheduling Tool will be used to establish phase completion dates.

  1.  This tool will divide the station transition into a pre-constructionstage and a constructionstage, with the goal of managing resource availability.
  2.  It will incorporate specific estimates regarding the availability of tower crews.
  3. Tower crews will be divided into three categories—U.S. crews qualified for more difficult jobs, such as top-mounted antennas on towers exceeding 300 feet; U.S. crews qualified to do less difficult jobs; and Canadian crews.
  4. The software discounts the time allotted to multiple jobs on a single tower.
  5. It assumes that 75 percent of stations will need an auxiliary antenna. 
  6. Testing periods for stations that complete the transition in four weeks will be "scaled up" to allow four weeks of testing.
    • The commission would prefer to make notemporary channel assignments, but seeks comment on them nonetheless: 
    • Should the commission decides to use temporary channel assignments, they would be limited to stations with complex interdependencies. 
    • These temporary channel assignments would be close to the station’s final channel assignment, and limited to “relatively low-power stations.” 
    • If stations are assigned a temporary channel, they must apply for a Special Temporary Authority to broadcast on it within 90 days of the release date of the “Auction Closing and Channel Reassignment PN.” 
    • Must-carry would apply to temporary channel assignments. 
    • Inter service interference protection would apply to temporary channel assignees. 
    • “Reasonably incurred costs of equipment needed to move to temporary channels are eligible for reimbursement,” for both broadcasters and multichannel TV distributors. 
    • Construction deadline extension requests will be evaluated case by case. 
    • Proposals for expanded facilities or alternate channels also will be evaluated, case by case, according to their overall impact on the repack.

    TV Technology strongly encourages readers to consult the FCC Media Bureau’s Transition Scheduling Plan Public Notice, Appendix A, which starts on p. 19 and lays out more technical details of the commission’s proposed repack plan. As always, TV Technology will continue to provide coverage on the auction and the repack. As our esteemed contributor Charles Rhodes says, “stay tuned.”

    See more TV Technology coverage at our spectrum auction silo.