Widelity Generates Range Of Repack Opinions

The FCC has received and made public an additional dozen comments on the Widelity report on the scope and cost of work necessary to repack TV spectrum that support some its findings, disagree with others and offer specific suggestions on how to make the repack of TV spectrum a success.

The comments from American Tower Corp., Block Communications Inc., Cohen, Dippell and Everist, Dielectric, DirecTV and Dish Network, Google, the National Association of Tower Erectors, the National Cable and Telecommunications Association, Sinclair Broadcast Group, Stainless, Transmit Consultancy and an anonymous collection of broadcast licensees, join those of GatesAir and NAB made public earlier.

Concerns varied among broadcasters. Sinclair noted the Widelity report says that under the best-case scenario repacking a station will require nearly four years, but to achieve the best case will take “thorough planning by all parties.”

“Yet broadcasters cannot do any advance planning without a clear and complete understanding of the repacking and transition scenarios the FCC intends to impose,” Sinclair said in its comments.

The broadcaster also noted the report “does not sufficiently account” for contraction in the RF equipment manufacturing capacity nor “the impact of a sudden and dramatic increase in demand for products and services that simply are not being produced and provided in the ordinary course today” resulting from the FCC freeze on construction permits that began a year ago.

Sinclair also said it is concerned the $1.75 billion in funds available to reimburse broadcasters for their move will be insufficient and renewed its call for the FCC “to define ‘standard’ flexible use waivers” and grant them liberally prior to the auction. “This is perhaps the single most significant step the FCC can take to relieve some of the burden on the repacking fund and improve the likelihood of a successful auction,” Sinclair said.

Comments filed by Colby M. May, representing an unspecified number of non-network affiliate broadcast licensees in the top 75 markets, praised the Widelity report for providing “important and needed information” on many issues, but pointed out it did not properly account for “the inevitable delay” in manufacturing and supply of essential RF components needed for the repack, such as antennas, waveguide and transmitters.

“The Widelity Report should be expanded to address in detail how the paucity of manufacturers will surely negatively impact the repacking process and time-line,” the comments said.

Block Communications said in its comments that it is “keenly interested in ensuring that the FCC respects Congress’s mandates that existing TV service is fully protected by the FCC’s repack scheme and that broadcasters are fully reimbursed for all reasonable costs if they are required to modify their facilities to accommodate the repack.”

Failure to do so will be tantamount to “a government-enforced transfer of assets from broadcasters to wireless operators,” Block said. The cost to viewers would be TV reception quality that is inferior to what is available today, it added.

Block said it questions whether the Widelity report’s list of expected repack expenses and estimated costs “will have any practical value once stations actually begin making the changes necessitated by the repack.” Each station participating in the repack will face unique challenges “that cannot be quantified by a prefabricated government schedule of acceptable expenses,” it said.

Block suggested the Widelity report should be used to help the FCC to begin figuring out the maximum number of TV stations the agency will be permitted to repack given the $1.75 billion budget set aside by Congress for broadcaster relocation.

Cohen, Dippell & Everist, a Washington-based professional consulting engineering services firm focused on the communications industry, said in its comments that it questions the usefulness of the Widelity report in light of the 39-month repack completion deadline under consideration by the FCC.

“This abbreviated buildout timetable is a prescription that drives a nail through the heart of the estimates for any of the cataloged equipment, services or the planning provided by the Widelity report,” the comments said.

“It is obvious that the FCC in its trial balloon [the 39-month deadline for completing the repack] does not appreciate the myriad of items that fully go into an overhaul of a major UHF transmission facility,” the Cohen comments said.

The tower and antenna community also submitted comments. Dielectric said the Widelity report “grossly underestimates the magnitude of the potential bottlenecks associated with certain elements of the transition … namely, pre-planning, radiofrequency (RF) engineering, structural engineering and tower work.”

Completing a repack of 500 stations within three years is beyond the current capacity of the tower structural and rigging industry as well as antenna manufacturing industry, Dielectric said. To achieve the 500 mark in three years will require reversing the unwinding of RF manufacturing resulting from the FCC construction permit freeze.

“From a practical perspective, Dielectric believes that the respective demand for RF and structural engineering services by transitioning stations, occurring at the same time is likely to create a tremendous bottleneck in obtaining access to those engineering services,” it added.

Comments from Stainless reflected concern over the toll taken by the construction permit freeze, which has “reduced the size of support industries to broadcasters and has created limited industry capacity to facilitate the repacking transition.”

“Stainless is concerned that the FCC may prioritize rapid implementation of the auction and its revenues over safety issues,” the comments said.

The National Association of Tower Erectors expressed concern in its comments that establishing a three-year deadline for completing the repack will likely “promote a scenario in which undertrained and unqualified individuals and contractors will seek to reap the rewards of over a billion dollars of channel relocation” funds, which “will undoubtedly lead to an increase in accidents and fatalities ….”

In its comments, American Tower, an independent owner, operator and developer of wireless and broadcast communications real estate, including towers, said “clear ‘rules of the road’ are imperative’ in an environment where multiple entities can own infrastructure in use by a single broadcaster.”

Two scenarios exist in which repack repercussions will ripple out beyond a TV broadcast licensee, said American Tower. The first involves multiple TV broadcasters sharing a master antenna system in which not all of the broadcasters will be repacked, but all may incur costs. The other scenario involves towers where non-TV licensees may have costs to accommodate repack changes.
The company also urged the commission to authorize reimbursement for six eligible expenses incurred prior to the repack that are identified in the Widelity report catalog of eligible expenses, including structural analysis of towers to current building codes with existing towers and RF engineering studies for single frequency or broadband antenna designs.

DirecTV and Dish Network jointly filed comments expressing general satisfaction with the Widelity report and catalog of MVPD expenses and offered only “modest” changes to reflect the true cost of receivers and other items.
Google recommended in its comments that the FCC continue its existing policy of reserving TV channels for wireless mic use and that those channels should be opened for use by unlicensed consumer devices when wireless mics are not in use.

The National Cable and Telecommunications Association said in its comments that most of the costs detailed in the Widelity report “track fairly closely” to figures it has provided the commission, but identified Widelity’s costs of receiver equipment and tower rigging as being too low.
Transmit Consultancy, which helped to manage two spectrum repacks in the United Kingdom, said in its comments that the FCC should establish “a single-purpose organization operating within a framework established by the regulator” that would “facilitate consolidated, central management for repacking” and would be “coordinated by the Industry itself.”