COALITION SPONSOR - 2014/2015/2016


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CONTENT PROGRAMMING RANT

 
22,733 WORDS ARE SPOKEN
IN MONTHLY FCC MEETING
BUT LPTV IS NOT ONE OF THEM!
THE FCC ISSUES  A "NOTICE OF INQUIRY" ABOUT THE PROGRAMMING DIVERSITY AND PRINCIPAL OBSTACLES THAT INDEPENDENT PROGRAMMERS FACE IN OBTAINING CARRIAGE ON VIDEO DISTRIBUTION PLATFORMS





COALITION COMMENTARY
The FCC today decided that the diverse network programmers which air on LPTV and translators, and also air on pay tv platforms, well, they don't count or have problems.  The Commissioners and staff spoke over 22k words yesterday, and not one of them was about LPTV programming. When we did a quick study back in 2013, we found over 200 programming networks air on over 2500 LPTV digital subchannels. A look today at rabbitears.info shows more than 297 networks airing on over 9000 subcahnnels, including those shown on the primary and NCE stations. Whichever the current correct numbers, it is a fact that there are a heck of a lot of independent programming creating content for free over the air broadcasting.  


 
ARE THE VIEWERS OF LPTV NETWORKS 
ANY LESS IMPORTANT THAN THE PRIMARY  OR NCE STATIONS?  

Isn't the intent of the spectrum auction act to NOT disrupt the programming of networks which is carried on LPTV?   No? Just because it is not in the spectrum auction act, that the FCC was not suppose to deal with those impacts? 
There has not been any study done on the potential impacts to LPTV networks, no mention of it at all in all those FCC documents and rule makings.  So what gives?  Does our secondary for interference status make our viewers secondary?  Since many LPTV now air multiple channels of digital content, are we not also multi-channel distributors? And what about those 200+ government agencies which are LPTV and translators licensees, does their "civic content" qualify for study?  The FCC is concerned about the PEG content, but what about the civic content aired for free over the air, and not part of a pay system?

Now I am getting upset...remember, the FCC decided that LPTV would be the only industry interest sector not invited to participate in the numerous LEARN sessions as part of the original NPRM for the auction.  This is what they are being sued about in the Court of Appeals case now.  They never studied the impacts on us in the auction rulemaking, and now in this NOI, they do not include to study our network programming partners, and how the auction will affect them. Not even a basic question or two.

And, during the failed Time Warner & Comcast merger process, our Coalition on numerous occasions requested  discovery of the merger partners regarding their "leased access" contracts with LPTV.  
We did this knowing about the legal case another LPTV had against the FCC related to preferential treatment given to specific niche networks, such as zero cost contracts, vs. another local LPTV asked to pay a very high price.  But the FCC denied that request for information.  

So how the frak are we suppose to  get information about how the networks we air will be impacted by the auction, and this new NOI?


THIS WAS SOME OF THE FIRST RESEARCH WE DID IN 2013

And this is what  rabbitears.info says today...note that there are now, when you include the primary and Class-A stations, some 9263 sub-channels. 

It is now 4 years since the spectrum auction act was passed in 2012 without any UMRA (unfunded mandates) point of order challenges about a now estimated $1 billion impact on the 10,000 LPTV and translator licenses, permits, and accepted applications. 
 


Never mind the stranded investment loss involved with 2000+ rural construction permits from 2009, which was well before the 2012 legislation. These construction permits, along with the 1500 remaining analog to digital conversions, are indefinitely suspended from a deadline to build until many years post auction.
 
These permits were obtained in most cases to build rural wireless internet using licensed spectrum and approved flexible use.  Ever since the 1999 digital data services act, the LPTV industry was researching and organizing to accomplish this new approved flexible use. 



As many as six related investment groups filed almost 3000 applications.  Of which, more than 2300 were approved and are now not built permits, which have to compete for new channels in an open filing window after the licensed LPTV and translator displacement window six months after the auction ends.  The remaining accepted applications continue to be approved or rejected by the FCC.

That's ok, don't study the impacts to the LPTV licensees, translator systems, the networks which they carry, impacts to civic and educate broadcasting, and our viewers.  LONG LIVE THE ROD! 
COALITION SPONSOR - 2015/2016




Low Power/Television Translators
Proposed Construction Permits Report No.: PGL16-1 
Released: February 18, 2016 

Notice is hereby given that the television translator and low power television applications on the attached list have been accepted for filing. These applications are not mutually exclusive with other LPTV and TV translator. Petitions to deny the applications may be filed with the Commission within 30 days of the release of this Public Notice.



This is what we were telling you about, there are still 100's of "accepted applications" from the 2009 filing window, plus many many others.
COALITION SPONSOR - 2013/14/15/16
COALITION MEMBER UPDATE







COALITION SPONSOR - 2015/2016
LPTV AFFILIATES WANTED NATIONWIDE
CLEARED IN SF, LA, CHICAGO, HOUSTON, DALLAS, FRESNO...
GET YOUR 
INNER GEEK ON
AND READ THE ATSC STANDARD





COALITION SPONSOR - 2014/2015/2016



ATTENTION
EAS TEST ALERT




AND A SHORT MESSAGE FROM DAVE MALLOF, 
MANAGING DIRECTOR, FREE ACCESS AND TELEMEDIA (FAB) 
WHO IS ONE OF THE GROUPS SUING THE FCC IN THE US COURT OF APPEALS


"FAB Requests Sunshine on Low Power TV's  Fate in the Spectrum Auction
In a November 16, 2015 letter to Representative Renee Ellmers (R-NC), FCC Chairman Tom Wheeler stated that "...we have not systematically analyzed the potential displacement impact on those [LPTV] stations."

However, in a December 16, 2015 meeting with Colin B. Andrews, counsel to Free Access & Broadcast Telemedia LLC (FAB) and FAB Managing Director David Mallof, high-ranking Wheeler executive Edward Smith stated that he had indeed seen analysis of the expected market-by-market impacts of the auction on LPTV and said the analysis confirmed "...that LPTV could survive in many markets."

And even earlier, back in April 2015, Howard Symons, vice chair of the FCC's Incentive Auction Task Force, also told a WAMU-FM Washington, DC radio audience during an on-air roundtable that the FCC knew well that not all LPTVs would survive. "We did look at the impact on LPTVs," he stated.  They can't all be right.

The contradictory statements of Chairman Wheeler and top-most FCC officials make the Freedom of Information Act requests for such documentation filed by FAB of critical importance. FAB's initial filing took place September 21, 2015; a new filing was submitted today specifically requesting the analysis Mr. Smith cited in December.

The FCC has acknowledged that there will not be a home for all licensed LPTV stations post-auction; and Mr. Smith's remarks chillingly imply that if LPTVs could survive in many markets, then in many more they will not.

"We have always believed that the FCC has a very good handle on what the displacement and relocation score will be in every single market under various spectrum-clearing scenarios," stated FAB spokesperson Dave Seyler. "In a proceeding of this importance and complexity, how could it not?"

There is a finite amount of spectrum available for the repack, and a finite number of full- and low-power television stations in each and every DMA. The FCC must have a firm grasp of how many station relocations can be accommodated and how many cannot in order to promote with great precision for 210 TV markets that spectrum can be cleared and resold in specific quantities and prices.

"The Commission has already arbitrarily decided to exclude LPTV from both voluntary auction participation while denying LPTV relocation homes during the repack," observed Seyler. "The very least it can do is put some real numbers out there on market-by-market survival odds so these small businesses can make informed and critical decisions about their future."

A lawsuit to fight for the interests of low power television licensees, FAB v. FCC, is currently pending before the US Court of Appeals for the District of Columbia Circuit. It challenges the legality of the auction as structured, even calling into question the auction's compliance with the takings clause in the Fifth Amendment of the US Constitution."


COALITION SPONSOR - 2013/14/15/16


Communications Law Attorneys representing clients before the FCC, the federal courts, and other regulatory, and governmental agencies on communications matters.

Chip Grange & Wray Fitch
(703) 873-7349 - www.gg-law.com




BRUCE FRANCA
NAB Senior Vice President, Spectrum Policy 
 February 17, 2016

"Broadcasters have no desire to delay the post-auction transition. It will be painful and expensive for stations, as well as disruptive for their viewers. But we do not have the luxury of assuming away the problem (or shopping a paper for a hefty price with no consequences if we are completely wrong).  The FCC's policy decisions on this matter should be driven by facts and serious analysis - not by crossing our fingers."



COALITION COMMENTARY
Franca makes all good points, but none about LPTV.  So take what Franca says and then multiply it times 400% and maybe you start to get the impacts and damages to LPTV and translators.

COALITION SPONSOR - 2015/16








COALITION COMMENTARY
This study, whenever it is formally released, could be a "game-changer" for LPTV and translators.  Why?  In those 410 pages of engineering research, no matter how biased it could be, will be a literal roadmap for LPTV and translators in how the post auction repack could work.  And that means when you get kicked off of your current spectrum assignment.  We will come back to this study once we get it.
NEW COALITION MEMBER WELCOME!




COALITION SPONSOR - 2016


 

STAND-UP AND 
BE HEARD!

Start off the NAB Show in Las Vegas on Sunday night with the 
2016 Save LPTV Rally and industry gathering, and all around informative and good time. 
 
Last year's event drew a crowd over 300 licensees, and many product and service providers.  


2016 SPONSORS (AS OF 2/15/16)
       

     

                   

   

     

     


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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 JOIN US today!


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