If you intend to apply for reimbursement from the FCC for expenses related to the channel repack, start gathering documentation, including tower-related expenses, now. Don’t wait for the October 15 deadline.
That’s the advice of Hillary DeNigro, Deputy Chair of the FCC’s Incentive Auction Task Force.
The repack reimbursement program has been operating for two-plus years for full-power TV stations, DeNigro said during a webinar on Wednesday. Now, Low-Power TV stations, TV translators, FMs and FM translators get a chance to get their repack expenses covered.
The first thing a station owner or engineer needs to do is fill out FCC Form 2100, Schedule 399 (Reimbursement Form), online. It has multiple parts and purposes. It’s used to establish a station’s eligibility for reimbursement and to estimate expenses. Tower owners should be prepared to provide their station tenants with supporting documents for tower-related repack expenses.
DeNigro says time is an issue. “You should not wait to submit the forms to see if you are eligible.” Stations can use the provided reimbursement forms to submit actual costs. “After the allocations are ready [we] will disperse funds. Assuming they’re reasonable and eligible, then we’ll pay those invoices,” she said.
However, DeNigro explained, invoices can’t be paid until after the October 15 deadline and, once all cost estimates are in. “Stations may receive requests for more information from us. Please respond to them promptly,” added DeNigro. “We will pay on a rolling process. It usually takes a couple of weeks.”
The Incentive Auction Task Force and the Media Bureau have specific criteria to determine which stations are eligible for reimbursement. Tower rental or leasing agreements are one way to prove a station is eligible. So too, are documents such as master control logs or operating logs.
Power upgrades by themselves are not eligible; the funds need to be repack-related. If a station installs a higher-power transmitter or larger antenna after the channel move, the station would be reimbursed up to the pre-repack power level and the station is responsible for the balance.
FMs that share a tower with a full-power TV station must prove their expenses are caused by the full-power TV station conducting repack work on that tower. That includes expenses related to building an Aux site if the FM needs to be off that tower for a period of time. If the repack work is being done around the October deadline, the FM can rely on estimates from the Cost Catalog. However, “If you use a cost estimate not from the catalog, you need a document from the vendor. It has to be based in reality,” DeNigro emphasized.
Overall, the agency realizes cost estimates may change. Stations can modify those estimates “at any time,” she said.
By Leslie Stimson, Inside Towers Washington Bureau Chief
August 29, 2019