REPACK RANT


7554 LPTV AND TV TRANSLATOR LICENSES AND PERMITS MAPPED BY CHANNEL NUMBER ON TO 210 TV DMA 

IS A REPACK 
SUMMIT NEEDED?
THERE IS CHAOS AHEAD IN THE REPACK UNLESS WE ACT NOW TO FIX THE PROCESS FOR ALL USERS, INCLUDING BROADCASTERS, WINNING BIDDERS, WIRELESS MIC'S, UNLICENSED, AND TV WHITE SPACE.  

LPTV AND TV TRANSLATORS, WITH THEIR "RIGHT OF DISPLACEMENT",  
HAVE ENOUGH LICENSED AND PERMITTED SPECTRUM FOR ALL USES, 
WITH CONDITIONS, AND FOR A PRICE BASED ON MARKET RATES.


COALITION COMMENTARY
With the NAB report this week detailing that the repacking process could last much longer than 39 months, our own analysis showing that more than 5000 LPTV and TV translators are facing displacement and new channel moves during the same 39 months, we are very concerned about the process.  When you consider that the unlicensed users, from wireless mic's, MicroGoo, and others, are not going to get what they really want, three contiguous nationwide channels (18 MHz), and that for the FCC to attempt to give it to them will stop the auction in its tracks for months. And then add in that the TV white space industry, which are the wireless internet providers, they also want 18-24 MHz.  

So rather than all of these interest groups battling over the same spectrum pool, ours, in which we have substantial rights, maybe what we should be doing is having a meeting to see what can be done within the rules, or which rules need to be changed.  We think it could work for all parties, and make the repack and transition run smoothly, albeit longer, as NAB research shows.

While LPTV and translators are not to be a factor for the FCC incentive auction rulemaking, we are THE factor when it comes to post auction spectrum for unlicensed and TV white space users.  So let this email be an invitation to all interested parties, we are ready to discuss how we all can get our aspirations and business needs met.  


FCC INCENTIVE AUCTION ALERT



ALERT - THE FCC HAS CHANGED SOME POP COUNTS AND OPENING BID PRICING - SO CHECK OUT:


TV Newscheck sums up what has changed... READ
TV Technology dives deep into what is new...  READ

"The commission said that in order to provide broadcasters with at least 60 days after the release of the recalculated prices to evaluate whether to apply to voluntarily participate in the reverse auction in light of such prices, it announced a revised filing window for FCC Form 177, the reverse auction application form. It will now be from noon ET on Dec. 8 and close at 6 p.m. ET on Jan. 12, 2016.

Given the revised reverse auction filing window, the commission also revised the filing window for Form 175, the forward auction application form. That window will open at noon ET on Jan. 26, 2016, and close at 6 p.m. ET on Feb. 9, 2016."


SO IS THE STARTING DATE OF THE AUCTION 
NOW ALSO PUSHED BACK?

RELATED UPDATE @ 2:51 PM:

[AFCCE-CDBS] Release of Updated Constraint Files and Opening Prices
Mark.Colombo@fcc.gov

Good afternoon,
Because the FCC has announced the release of updated constraint files and opening prices today, the updated datasets that were used to reproduce those constraint files have also been made available at:

The new constraint files are here:

The public notice is here:

The new baseline is here:

The new opening prices are here:

Note that with this new release comes a delay in the reverse auction window for filing to participate in the Incentive Auction.  This window will now be open for broadcasters December 8, 2015 through January 12, 2016.

Please let us know if you have any questions.

Mark J. Colombo
Electronics Engineer
Federal Communications Commission
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HOUSE ENERGY & COMMERCE COMMITTEE

ALERT

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FCC RULEMAKING PROCESS

FAB FILES MOTION 
TO REOPEN 3RD LPTV NPRM




COALITION COMMENTARY
As we have since the beginning of this rulemaking, we can show that the impacts to LPTV and TV translators will be real, cost us money, time, and we all run the risk of losing the coverage populations we now serve, and have public interest obligations with. However, as a secondary service we do give way to the whichever primary status licensees the objective FCC interference guidelines require of us. And our Right of Displacement, which each licensee and permittee has, empowers you, if displaced, to go find another channel, first within, then overlapping from, to your current contour.  DMA's have nothing to do with finding a new channel.

While we of course agree with the FAB request for any studies the FCC has conducted or commissioned about the impacts within each band plan to LPTV and TV translators, none has been provided by the FCC so far.  The rubber meets the road when the band plan is announced in late January, although we do not know if that date is now also pushed back.

We do not support slowing down the rulemaking process at all at this time.  The faster we get the Report and Order of the 3rd LPTV NPRM, the better it is for almost everyone in the business.  Again, the announcement of the band plan will give us about 85% of the impacts, with channel shares, and moves to the VHF, filling in the rest when the auction is done.

FAB (and Word of God Fellowship) is already in court, and that process has its' own timeline.  The auction timeline needs to keep chugging along in order to meet the 2016 goal, unless, and until, FAB and its' supporters stop it in the court.  Reopening the record is not needed right now, seeing the Report and Order is.  


EVERYONE WANTS FREE SPECTRUM





LOCAL MARKET AUCTION NEWS

 



INDUSTRY NEWS



INDUSTRY PROPOSALS TO BE AFRAID OF...






COALITION COMMENTARY
Back in 2014 we suggested just such a plan, but then got worried about what it could mean.  If a regionalized repacking happened, it would have two dramatic impacts on LPTV and TV translators:

1)  Quickly repacking an entire DMA, without first including LPTV and TV translator rebuilds at the same time, would mean forcing off the air those stations which currently occupy spectrum which the winning bidder bought.  So no 39 months at all.  This could mean vacating, and then no tower crews would be around until all of the 210 DMA are done.  

2)  Unless LPTV and TV translators are included in this regionalized approach, they will be off the air and lose their licenses and permits. By restricting the private marketplace for tower installation services to just primary users, well that is outright unAmerican!  

ATSC 3.0 

3.0 ECONOMIC BOOM?



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If you would like to be part of our collective effort to make sure LPTV and TV translators are treated fairly in the Incentive Auction and channel repacking, process, and that our spectrum usage rights are protected, then  JOIN US today!

Want to help fund the legal defense of LPTV?  GO HERE


Mike Gravino
Director
LPTV Spectrum Rights Coalition
(202) 604-0747
lptvcoalition@gmail.com
http://www.lptvcoalition.com