We have been alerted that there are emails being sent around to LPTV (LPTV and TV translator) licenses predicting doom and gloom for their license unless they provide reply comments into the LPTV NPRM process.  And that the only hope for the future is for LPTV to be in the Incentive Auction. Nothing could be further from the truth!  Don't buy into this faulty logic!  

While in 2013 and 2014, the Coalition had been the most vocal advocate for LPTV participation in the auction, and still has an active Petition for Reconsideration working its way through the formal FCC process which is demanding an economic analysis of LPTV as auction eligible, this is a new year, and as such, we have a new focus...LPTV license and permit survival post-auction.  

Why?  Simply put, with the new realization from the FCC that an 84-MHz clearing (channels 51-38) is the most probable clearing target and the most profitable to be auctioned (it will be unimpaired), the Coalition now wants to make sure that all LPTV licenses and new permits have a 6-MHz channel to displace to in the DMA they are already in, and if not, then an adjacent DMA.  

We want to dispel any fear licensees (6,500) and those with permits (3,500) have that their investment, current operations, and planned new businesses will be able to have spectrum to use post-auction.  Since the LPTV "Right of Displacement" is the cornerstone of LPTV spectrum rights in the auction process,  we are all protected, albeit with having to pay for our own displacement moves.  But Congress is investigating that issue with their requested GAO study of auction impacts on LPTV, and later this year when it is completed Congress can again be engaged.

While we are still in the middle of the fight still to get LPTV auction eligible, the odds of that happening are low unless we can get the Congress to agree - which is not likely at this time.  Even though the FCC has said they have the authority to do so, and even though they refuse by saying LPTV would not provide any value to achieve the goals of the auction, and even though 90% of the spectrum from 51-38 is spectrum LPTV now has licensed and permitted to build...without the internal political will at the FCC, it just will not happen. And we can not wait around for any potential court activity while we help to craft solutions to the rest of the real issues confronting LPTV.  You fight the battles you are in, not the ones which are months away.

The current comments and reply comments process for the 3rd LPTV NPRM is not the vehicle to wage the battle for LPTV in the auction.  It is the place to comment on dozens of affiliated and associated issues which real LPTV operators and permit holders have.  So don't get freaked out by the Merchants of Fear - they are pushing a singular issue with no consideration of all of the other issues.

The Coalition actually now here in early 2015 believes that a much better alternative to LPTV in the auction, is an LPTV buy-out by the Federal government after the auction.  And those which then want to stay in business could.  But the best alternative of all may be an LPTV private market auction which cuts out the Federal government and FCC oversight of it.  Now that is a real possibility and more on this as it develops.