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FCC Seeks Input on TV Station Repacking Expenses

Doug Lung

As part of the channel repacking after the completion of the incentive auction of UHF TV spectrum, many stations will have to move to another channel. The Spectrum Act established a $1.75 billion TV Broadcaster Relocation fund to reimburse broadcasters for eligible costs incurred in relocating to a new channel. Whether or not this will be enough will depend on how many stations have to change channels and how much time they will have to do it.

This week the FCC released a Notice (DA 13-1954) requesting comment on a catalog of eligible expenses and other issues related to reimbursement of expenses incurred in relocating broadcasters and modifying MVPD equipment used to receive TV stations. The Notice also asked for comment on different ways to mitigate relocation costs, including encouraging manufacturers and service providers (such as engineering consultants) to establish built-in discounts to reflect the volume of business generated by the repacking. Another suggestion was to limit reimbursement for items that are already part of a General Services Administration (GSA) schedule, such as HVAC systems, to the prices manufacturers offer to the Federal Government.

The Notice asks if requiring stations to obtain multiple bids for equipment and services above a certain threshold is feasible for all stations.

The FCC requested comment on whether it should encourage broadcasters seeking reimbursement from the fund to pursue tower or antenna sharing arrangements and if so, how? The Notice recognizes stations will need interim facilities during the move and asks how that equipment could be used as part of the final, permanent facility. The Notice asked for other suggestions to reduce expenses and facilitate broadcasters' move to new channel.

The Notice does not address a issue that has been raised before in connection with the repacking--that there may not be enough engineering consultants, tower companies and equipment manufacturing capability to relocate a large number of stations in a short period of time. Manufacturers would have to add significant manufacturing capability to deliver transmitters, towers and antennas during the relocation, but after the relocation the number of orders would drop dramatically. The new manufacturing capabilities would have to be written off in three to five years instead of 15 to 30 years and that could raise the price of transmitters and antennas.

The catalog attached to the Notice is very comprehensive, with costs broken down by transmitter type and power level. In the section on transmission line it even includes a table showing which channels won't work with specific rigid line length sections. Different channels require different section lengths to avoid having reflections from the rigid line flanges adding at certain wavelengths. I noticed one oddity in the section breaking out minor, major and serious tower modifications. Tension diagonal and horizontal (struts) reinforcing at less than 12 bays and levels (respectively) is considered minor. Tension diagonal and horizontal (struts) reinforcing at more than 15 bays and levels (respectively) is considered major. Cases requiring reinforcing between 12 bays/levels and 15 bays/levels are not defined in any of the categories.

Overall, I was impressed with the level of detail in the catalog, not only for the equipment required but for services, including structural studies and local permitting. No prices or even a range of prices was suggested.

The catalog notes that in some cases retuning a transmitter could exceed the cost of replacing it. One problem for broadcasters is that by the time the channel change takes place, many of their DTV transmitters will have been in service for 15 years or more and ready for replacement. It wouldn't make sense to invest money in retuning them, although that old transmitter may work okay as an interim facility.

When replacing antennas, stations may want to add elliptical or circular polarization, increasing antenna cost and likely requiring more transmitter power. In short, for many stations defining the cost of moving to a different channel and the amount eligible for reimbursement won't be easy.

One of the challenges broadcasters will face in responding to the Notice (with comments due Oct. 31, 2013) is how to define the costs. Transmitter cost, excluding shipping and installation, should be roughly the same across the country, but there are many different transmitter options even within the defined categories depending on the degree of redundancy and energy efficiency (MSDC IOT vs. conventional IOT, Doherty solid-state vs. conventional solid-state). The catalog recognizes the extra costs associated with Ch. 14 due to extra filtering required to protect adjacent land-mobile allocations; however, calculating the cost of different system configurations involving trade-offs between transmitter size, antenna size, and tower loading as well as the impact of relocating other stations that may share the tower are impossible to determine until after the final channel plan is established.

More information on the FCC's plans for reimbursing broadcasters for repacking channels changes may be revealed at the FCC Workshop on TV Broadcast Relocation Fund Reimbursement and Related Issues on Sept. 30.