The National Association of Broadcasters says again that the FCC should take “a more flexible, fact-based approach” to the TV spectrum repack process, which also has implications for some FM stations.
NAB earlier had asked the commission to reconsider its plan to develop a repack transition schedule. Wireless companies T-Mobile USA, Competitive Carriers Association and CTIA then opposed that request.
NAB argues that the oppositions were largely procedural. Further, it said, opponents “essentially insist that the current commission should continue the previous commission’s practice of favoring the wireless industry over broadcast viewers and listeners. We urge the commission to reverse this course, and at least provide the Media Bureau with the flexibility to adjust its schedule to reflect the facts as they unfold.”
It argued that if the commission ignores available information, the result would be to “deprive viewers and listeners of broadcast television and radio service for the benefit of a single nationwide wireless carrier that already has substantial spectrum holdings in other bands.”
Among specific requests in its original petition, NAB asked that the FCC Media Bureau and Task Force revise its scheduling plan so as to minimize disruption to FM stations and other “non-repacked” broadcasters.
“In response, CCA and CTIA state that the Media Bureau and Task Force had already revised the plan to accommodate concerns regarding broadcasters that share facilities with repacked television stations,” NAB wrote. “In particular, the Public Notice announced that the Media Bureau and Task Force had reduced the ‘same tower discount’ applicable in developing the transition schedule. While we appreciate this effort by the Media Bureau and Task Force, CCA and CTIA miss the point.”
NAB argues that the “same tower discount” reduces the amount of time the scheduling plan estimates to complete work on a tower if more than one TV station on a stick is transitioning in the same phase. “The discount thus does not take into account the presence of non-repacked broadcasters on a tower.”
NAB said it’s customary to schedule tower work at off-peak hours to avoid disruption to other broadcasters on a tower. “To accommodate this industry standard approach, the commission would need to allow more time for repacked broadcasters on towers with other broadcast stations, regardless of whether there are other repacked television stations on those towers. Reducing the same tower discount does not address this problem.”
The full filing including NAB’s responses on other points is here (PDF).