There’s a Notice of Proposed Rulemaking (NPRM) for implementing an incentive auction of TV broadcast spectrum on the agenda for this Friday's Open Commission meeting, and broadcasters with no intention of selling spectrum will be analyzing the NPRM to see how the post-auction repacking could impact off-air audience service.
Legislators will also be watching. Judy Chu, Chair of the Congressional Asian Pacific American Caucus; Emanuel Cleaver, II, Chair of the Congressional Black Caucus; and Charles A. Gonzalez, Chair of the Hispanic Congressional Caucus, sent a letter to FCC Chairman Julius Genachowski expressing concern over the repacking.
The letter states: “Given the dependence that our communities place on broadcast television, including Class A and LPTV, maintaining a robust free and local broadcasting system must remain a priority for the FCC. As the FCC drafts rules to implement the incentive auctions and develops the technical plans for the repacking process, we implore the Commission to work with all interested parties to ensure a successful auction. To that end, a fully transparent process that allows interested businesses and consumer groups the opportunity to review and comment on all of the Commission's plans, before any irreversible decision has been made, is critically important.”
As I have explained in recent articles, there are inaccuracies in the way the FCC calculates coverage and interference using FCC Bulletin OET-65 procedures. This could result in lost real world coverage due to interference that's greater than what calculations predict. One of the reasons the DTV transition was so successful was that broadcasters and engineers had an opportunity to tweak the FCC's original Table of Allotments to improve coverage and to negotiate interference agreements with other broadcasters. A successful repacking will require more than giving broadcasters a new channel and forcing them to use new antenna patterns and coverage areas based on calculations with known errors that are not easily corrected. Broadcasters must have time to analyze the FCC's repacking plan and suggest changes.