In the December 2012 issue of Broadcast Engineering, I presented an article focused on the eventual television band repack and how stations should prepare for this event. At the time the article was written, the FCC had just released its Notice of Proposed Rule Making (NPRM) (Docket No. 12-268). My plan is to present periodic updates on the process that will look at the FCC’s actions, industry reactions and the thoughts of some industry leaders.
We now have many comments and reply comments that have been filed in response to the FCC’s NPRM. The FCC has also released several proposals and actions, such as the revision to OET-69 and comments on possible ways that initial valuations might be made on television spectrum. At least one group has surfaced, announcing it has properties that it plans to put into the reverse auction process.
The NAB and others have reacted to the OET-69 revision. Spectrum issues were a hot topic at the recent NAB convention; the FCC recently conducted a workshop on issues surrounding the proposed 600MHz band plan; and the FCC implemented a freeze on television facility changes. It has been a busy six months.
If this wasn’t enough, the FCC also announced that it is beginning proceedings on the T-band segment (TV Channels 14–20), where the television service has shared, in some markets, this spectrum with public safety users.
Hundreds of companies and organizations filed comments on the TV Spectrum NPRM. Both the broadcast and wireless communities were aligned on one major point: No one liked the FCC’s proposal for a split-band plan. (See Figure 1.) Most support the idea that the reclaimed spectrum should come off of the top of the TV band. Another issue that had less cross-industry support, but was unanimous among broadcasters, was that the band plan must be uniform across the nation. The FCC has pushed the idea that the lower limits of the reclaimed spectrum can vary on a market-by-market basis, while broadcasters reminded the commission that co-channel interference will result from such a plan.
A joint letter submitted to the FCC by NAB, Verizon, AT&T, T-Mobile, Qualcomm and Intel rejected the FCC’s proposed split-band plan and advocated for the following principles:
- Adopt a contiguous “down from TV 51” approach with uplink at the top.
- Maximize the amount of paired spectrum above TV 37. (Rely on supplemental downlink configurations where spectrum is cleared but pairing options are not viable.)
- Rely upon 5MHz spectrum blocks as building blocks for the wireless band plan.
- Incorporate a “duplex gap” or spacing between uplink (mobile transmit) and downlink (base transmit) of a minimum of 10MHz, but no larger than technically necessary.
- Avoid broadcast television stations in the duplex gap.
- Preclude any operations in the duplex gap or guard bands that would result in harmful interference to adjacent licensed services.
Many broadcasters supported loosening the proposed reverse auction eligibility requirements to allow more licensees and permittees to participate. They argued that one or more of the following should be eligible to participate in the auction: full-power or Class A licensees appealing the expired, cancelled or revoked status of their license; permittees of new, unconstructed full-power stations with construction permit applications granted as of Feb. 22, 2012; licensees with applications to convert stations from low power to Class A status pending as of Feb. 22, 2012; low-power stations able to demonstrate compliance with Class A eligibility requirements; and entities faced with “exceptional and unique circumstances” that prevented them from licensing their facilities by Feb. 22, 2012.
Most broadcast commenters supported expanded bid options for licensees, such as moving from a UHF channel to a VHF channel, agreeing to accept additional interference, and agreeing to accept a smaller service area or reduced population coverage.
Many broadcast commenters, including NAB, argued that the Spectrum Act requires international coordination with Canada and Mexico as a prerequisite to conducting the incentive auction. Various state broadcaster associations noted that border coordination affects about one-third of broadcast television stations. Putting off international coordination, therefore, would complicate the repacking process and delay reimbursement beyond statutory time limits. Wireless carriers, including CTIA, also urged prompt attention to international coordination measures, but not at the expense of an auction delay.