WASHINGTON—The areal reach of most TV stations in the United States will be diminished in the post-incentive auction repack by the government’s current technology. That’s the conclusion of the National Association of Broadcasters, which ran its own comparative analysis on TVStudy, the software created by the Federal Communications Commission for the repack.
“The issue is… not an abstract legal or technical question, but one that has real-world consequences,” the NAB said in comments filed with the FCC this week. “Changes in coverage area and population served produced by the use of TVStudy will impose substantial burdens both on broadcast licensees that participate in the auction, and those that are subject to channel changes through the commission’s subsequent repacking process.”
TVStudy is based on OET-69, the FCC’s predictive methodology for TV signal reach and interference. TVStudy uses updated data compared to OET-69 as it was when Congress passed the Spectrum Act in February of 2012. The NAB says Congress intended the repack to be done with the version of OET-69 established at the time of the law’s passage.
However, the NAB says that even plugging in OET-69 parameters into TVStudy leaves 88 percent of U.S. full-power and Class A TV stations—1,978 out of 2,232—with less coverage. Of those, 84 percent or 1,668 would lose between one-half and five percent of their coverage area, while 8 percent or 151 would lose more than 5 percent.
NAB’s analysis also indicated that 45 percent or 1,009 of the TV stations in the sample would lose viewers using TVStudy with OET-69 values plugged in. Of those, 45 percent or 448 stations would lose between 0.5 and five percent of their audience. About 11 percent, or 110 stations, would love more than 5 percent.
In a side-by-side comparison, using the same data in TVStudy and the February 2012 version of OET-69, TVStudy knocked down the coverage area for more than half of the sample. Since the commission has not identified the parameters and switch settings it will use for the spectrum auction, the NAB set theoretical ones. E.g., population data, beam-tilt, grid size, terrain profile resolution and so forth—more than 100 in all.
In the side-by-side comparison, 249 stations lost more than 5 percent of their coverage area with TVStudy versus OET-69.
“Certain results are particularly egregious,” the NAB filing said. “For example, full-power station WKPC-TV in Louisville, Ky., is calculated to cover 15,207 square kilometers using the current OET-69 methodology, but only 12,984 square kilometers—a 13.8 percent loss of area—using the TVStudy software.”
More than half of stations also lost eyeballs, with 116 losing more than 5 percent of their audience. WLTV-TV in Allentown, Pa., for example, lost around 10 percent of its audience—471,332 of its 4,838,490 viewers. WFXQ-DC in Springfield, Mass., lost 16.6 percent. KKFX-CA in San Luis Obispo, Calif., lost 48 percent.
The NAB’s filing suggested a legal strategy should the commission pass an incentive auction order adopting the software as it is.
“If the commission adopts TVStudy as it currently stands, and in express contravention of unambiguous Congressional intent, the commission will be acting in a manner that is arbitrary, capricious and contrary to law,” the filing said.
February 5, 2013, “FCC Reveals Crucial Piece of TV Channel Repacking Method”
The FCC has quietly revealed what amounts to its methodology for repacking TV channels in the post-incentive auction spectrum band.
February 6, 2013, “NAB: OET-69 Update Injects ‘Legal Uncertainty’”
Insiders say wagons are circling over the new methodology for predicting TV station coverage and interference.
March 21, 2013, “NAB Says OET-69 Changes ‘Unlawful’ and ‘Flawed’”
Proposed changes in how a TV station’s reach is calculated are “fundamentally flawed in their execution” if not entirely “unlawful,” the NAB said today in a filing with the FCC.
August 20, 2013, “TVStudy Update No. 3 Does Cross-Border Analysis”
TVStudy Vers. 1.2.7 is said to be able to perform cross-border channel analysis of TV signal interference between stations in the United States and those in Canada and Mexico “on proxy channels.”
September 9, 2012, “FCC TVStudy Update No. 4 Tweaks Beam-Tilt”
The update includes new source code and executable files for both the Mac and Linux platforms, an updated instruction manual, change log, and upgrade guide.
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