TV Spectrum Sellers Say TVStudy Shortchanges LPTVs

WASHINGTON—The coalition representing TV stations interested in selling spectrum on the incentive auction are objecting to the signal-coverage methodology associated with the auction.

“The Expanding Opportunities for Broadcasters Coalition hereby submits these informal comments… [identifying] an outdated input used in the FCC’s TVStudy software that appears to undervalue the coverage area of many Class A television stations.”

The comments were submitted by Preston Padden, executive director of the coalition, following the blogged revelation by Federal Communications Commission’s Incentive Auction Task Force chief, Gary Epstein, that the auction would be postponed from mid-2015 to “early” 2016.

Epstein cited lawsuits brought by the National Association of Broadcasters and Sinclair Broadcast Group as the reason for the delay.

“We are confident we will prevail in court, but given the reality of that schedule, the complexity of designing and implementing the auction, and the need for all auction participants to have certainty well in advance of the auction, we now anticipate accepting applications for the auction in the fall of 2015 and starting the auction in early 2016,” Epstein wrote.

The coalition’s informal objection reflects the NAB’s lawsuit in that it focuses on specifics in TVStudy. The NAB contends TVStudy’s choice of updated population data reduces the signal coverage area for many stations, and that doing so violates the Spectrum Act, which directs the FCC to preserve signal coverage as it was measured Feb. 22, 2012.

The EOBC is honing in transmitting antenna patterns.

“By failing to double the vertical antenna patterns for Class A stations, TVStudy undervalues the service and interference potential of some Class A TV stations,” Padden’s comment states.

E.g., the omission predicts a population loss of nearly 96 percent for KSKT-CA in San Marcos, Calif., he said; one that is mitigated entirely by using vertical antenna pattern data values set forth in the commission’s July, 2011, Digital LPTV Order. This, with all other parameters reflecting those set out by the NAB in the organization’s comments on TVStudy. The resulting population coverage results also exactly reflect those ofTVStudy’s precursor, OET-69, Padden said.

“The continued use of input values in TVStudy that the FCC has deemed ‘not appropriate’ will have a tremendous negative impact on certain Class A TV stations both in the auction and the subsequent repack,” Padden said. “First, it will unfairly reduce compensation for affected stations considering auction participation.Second, it will result in a failure to identify many unacceptable repacking scenarios—leading to real world interference after the auction that will, in some cases, greatly exceed the predictions in TVStudy.

“We urge the commission to act promptly to revise the vertical antenna pattern inputs in TVStudy to reflect the same values that the agency has used for years to determine a Class A TV station’s coverage and interference. “

Also see…
September 27, 2014,
Lawsuits Drive FCC Incentive Auction Delay
The FCC quietly announced it would delay the spectrum incentive auction to early 2016. The revelation came, not from an official announcement from the agency, but in a blog post by Incentive Auction Task Force Chairman Gary Epstein on Friday.

August 18, 2014,NAB Sues FCC Over Incentive Auction Rules
The broadcast lobby has asked a federal court to enjoin the FCC’s post-incentive auction TV station repacking methodology. The commission modified the data used for 2009 repack in a way that many say changes signal reach.

August 12, 2014, TVStudyOptions Show Impact on Coverage
I’ve been playing around with some Python programs that parse data in the tvstudy.cel file and convert it into a color-scaled image that can be displayed on a map. Looking at the results I realized I had the perfect way to show how the use of the different antenna pattern options available in TVStudy impact the predicted signal strength inside a station’s coverage area.

May 27, 2014,FCC Updates TVStudy
The FCC Office of Engineering and Technology has released a new version of TVStudy, v1.31. Most of the changes are bug fixes and performance improvements.

May 9, 2014,NAB: 1,978 Stations Lose Coverage With FCCRepack Software
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 NAB.