NAB, and many broadcast equipment suppliers and engineers, say the FCC’s 39-month schedule for the television repack is too aggressive. The proposed schedule doesn’t fully take into account logistical and technical challenges broadcasters and suppliers will face, says NAB in comments to the agency; the trade lobby urges the Commission to re-think the deadline.
On top of all this, wireless companies are inflating how urgently they need new spectrum and are dragging out the auction, according to NAB.
Many of the Commission’s proposals for the television repack “are reasonable steps towards planning an efficient transition,” notes NAB. However a software-driven approach to categorize and assign stations to different phases is “unlikely” to produce a workable and efficient plan in practice, according to the broadcast trade lobby.
NAB and other commenters, like American Tower and T-Mobile, urge the Commission to adopt a flexible transition plan that can be changed based on particular circumstances — and unforeseen circumstances. Block Communications, for example, told the FCC at least two stations are “located at sites that may require significant tower improvements” — including potentially the need to replace the towers or find new sites, according to NAB.
Block also emphasizes the importance of getting additional information from broadcasters regarding their construction projects, some of which cannot possibly be known until after broadcasters receive their final channel assignments. For example, if a station is assigned a lower channel, it may require a larger and heavier antenna that could exceed the load limitation on the station’s existing tower.
NAB continues: “Significant tower construction work itself could easily require the full 39-month transition period to accomplish. In the event that the Commission assigns a station that requires such work to an early repacking phase, the station will have been put in a no-win situation where, through no fault of its own, the station cannot possibly meet its repacking deadline. Assigning deadlines that are unachievable at the outset is not a reasonable approach to a complex project.”
The FCC should reject the notion of false urgency, according to NAB, which says CTIA must have stepped into a time machine and recycles threats of a “spectrum crunch” and “staggering growth” in customer data use, in its comments to the agency. “This is a remarkable claim given the state of the incentive auction,” states NAB, which adds some CTIA members have left spectrum on the table through their unwillingness to bid “at a sufficiently high level” to allow the auction to end at an earlier stage.
Similarly, CCA claims the 39-month deadline shouldn’t be adjusted because broadcasters have had seven years to prepare for the repack. By the same logic, CCA members have had four years to prepare their bids, “but that has not resulted in robust bidding,” according to the broadcast trade lobby.
“Further,” says NAB, “although the broadcast industry has been aware for years that the incentive auction would occur, it remains to this day uncertain whether any individual broadcaster will be repacked, let alone to what channel that broadcaster may be repacked, which can have enormous impact on the scope and type of planning necessary. It is wholly unreasonable to assert that broadcasters should have spent the past four years preparing for a repack about which they knew so little.”
November 17, 2016