The devil is in the details, so the saying goes. That adage seems apt as the federal government considers how to establish a “catalog” of relocation costs for users of C-Band spectrum, including radio and TV stations, who will have to migrate.
The National Association of Broadcasters has filed comments with the commission that give some idea of the complexity of the discussion. The commission’s Wireless Telecommunications Bureau had asked for industry feedback on its preliminary schedule of costs associated with relocating services out of the 3.7 to 4.0 GHz band.
It’s a detailed filing, but in general NAB is asking the bureau to take more input, revise the current estimates and not finalize anything until satellite operators submit their own ultimate plans — and also until rising costs from pandemic-related disruptions of supply chains are known.
NAB pointed to a number of places in the preliminary schedule where it thinks costs need to be adjusted or clarified. It asked for more flexibility in certain line item filings. And it asked the FCC to clarify that the catalog’s description of technology upgrades does not suggest that specific technology selections are solely at the discretion of satellite operators.
Download the NAB filing here.
An example from the filing: NAB points to a potentially large “cost error” in calculations for Integrated Receiver/Decoders. “For the downlink portion of costs associated with compression upgrades, the Catalog lists a range of $5,000 to $35,000 ‘per transponder.’ While that cost range is likely appropriate for each individual IRD, thousands of broadcast stations and cable headends across the country may receive content from a single transponder. As a result, in many cases there will be thousands of IRDs required for each transponder.” (NAB suspects the FCC’s “per transponder” description may be an error and that the intent was to address costs “per IRD.”)
Another example from the discussion of costs for earth stations: “In Table III-A-1, the Cost Catalog sets for passband filter installation costs of $300 to $1100 per earth station. At least one NAB member has already expended significant effort in estimating installation costs associated with filter installation, and has determined that actual costs will be $1350 per station. Accordingly, we urge the Bureau to revise the upper end of the range of costs for passband filter installation to at least $1350.”
The proceeding, for those who wish to dig into the comments, is “Wireless Telecommunications Bureau Seeks Comment on Preliminary Cost Category Schedule for 3.7 to 4.2 GHz Relocation Expenses,” Public Notice, GN Docket No. 18-122, DA 20-457.