This week, the FCC conducted a webinar to explain the spectrum repack plan laid out in its Sept. 30 public notice. Leading voices in the broadcast industry gave the plan a less-than-enthusiastic response, citing a variety of specific shortcomings. But the underlying reason for the halfhearted reaction may have more to do with what is seen as the near impossibility of completing the repack in 39 months.
Repack Plan Draws Tepid Industry Reaction
The FCC’s TV spectrum repack plan — which it laid out in a Sept. 30 public notice and was the subject of a three-hour webinar from FCC headquarters Oct. 17 — is receiving a lukewarm response from industry players.
“The concept is good. The problem I see with the PN [public notice] is they have made assumptions that perhaps won’t hold up in the real world,” says Jay Adrick, retired Harris Broadcast VP and now an industry consultant who has remained deeply involved in the TV spectrum repack issue.
“The PN makes everything fit their schedule without factoring the real-world conditions that will cause the schedule to slip.”
The FCC webinar and public notice laid out the agency’s proposed plan for how broadcasters, vendors, tower crews, consulting engineers and others will move more than 1,000 full-power and Class A stations to new channel assignments.
The proposal breaks up the spectrum repack into 10 phases in an effort to make tackling the thorny issue of relocating TV stations in daisy chains with interlocking frequency dependencies easier.
It addresses how to stage various steps in the repack, manage limited resources, protect stations from interference in excess of 2% during the repack and minimize the number of viewer TV channel rescans needed — all within the 39 months allotted for the repack.
The overall goal of the notice was to “find a way to make an orderly and efficient transition” for stations affected by the repack, says Sasha Javid, chief data office, incentive auction task force at the FCC.
While the agency should be recognized for its effort, the procedures laid out in the notice and discussed during the webinar fall short of what will be needed, says Rebecca Hanson, SVP, strategy and policy, at Sinclair Broadcast Group.
“The FCC has clearly put a great deal of effort into this plan, and we hope it goes smoothly,” she says. “But the plan depends so heavily on factors outside of its control that it is hard to see how it will stay on track.”
The notice is out for public comment until Oct. 30, and, based on the interviews for this article, those “factors” will be at the heart of many of the comments filed.
Among the concerns are the lengthy process of obtaining FAA permission to modify tower height; time needed to acquire land-use permission, building permits, zoning waivers and other local permissions to modify towers; resource availability; weather delays; and TV viewer education about the consequences of the repack.
“There are only about 12 to 15 people at the FAA who process obstruction evaluations,” says Dennis Wallace, managing partner of engineering consultancy Meintel, Sgrignoli & Wallace.
With TV broadcasters moving to lower frequencies as part of the repack, the new antennas they will use will be taller than existing ones, he says.
Coupled with the fact that most antennas in the United States are top-mounted, the increase in tower height could mean that 800 requests may be filed for relatively time-consuming FAA obstruction evaluations.
“That is something the FCC needs to coordinate with the FAA,” Wallace says.
Wallace raised that issue during a repack seminar on Oct 19 at Washington law firm Wiley Rein. An FCC representative at the event acknowledged the issue, as well as similar requests for the commission to assist the industry with other government agencies when necessary, but added that ultimately issues like obstruction evaluations will be up to the agency involved.
Consulting engineer Merrill Weiss, owner of Merrill Weiss Group, questions how the plan regards tower reinforcement — specifically the limited tower crew resource needed to do the reinforcement.
“The reinforcement of towers [in the notice] is included in the general construction process as opposed to requiring a tower crew,” Weiss says.
But that is unrealistic, in effect underestimating the demands that actually will be placed upon limited tower crew resources, he says.
The way auxiliary antennas are regarded in the notice — as cookie cutter placeholders that simply keep stations on air while main antennas are being custom-designed and built — must also be reevaluated, says Weiss.
“I did not see any recognition that a substantial percentage of stations will be putting as much effort into their aux antennas as they do their main antennas,” he adds.
Consultant Adrick also questions assumptions about antennas in the notice. “They assume each antenna manufacturer starts the [repack] process with 20 antennas on the shelf,” he says.
While acknowledging some broadband standby antennas may be in stock, primary antennas are not, he says.
“The fact is many of these [primary] antennas are not something you can pre-build because at this point the channel a station will be on is unknown and the dimensions and criteria for mounting antennas on towers are unknowns because no two towers are identical,” Adrick says.
The plan also fails to make adequate accommodations for weather delays, he says. During the FCC webinar this week, someone in the online audience raised the same concern about weather.
In reply, a commission spokesperson pointed to conversations the agency has had with tower crews, saying “even tower crews in Canada” have said “they work 12 months a year.”
The biggest weather condition that would prevent them from working is wind, the spokesperson said, adding that not doing “any tower work in the months of December through February is probably too conservative.”
However, tower crews are concerned about more than wind, Adrick says. “Wind, rain, lightning, ice — those are all factors. People aren’t going to want to be working on a tower when it is covered with ice. Let’s get real.”
While the FCC still has the opportunity to address these and other concerns that might be raised by commenters, Sinclair’s Hanson says the plan suffers from a fundamental flaw — trying to pull off such an ambitious repack in 39 months.
“At the end of the day, the more honest expectation is what industry has been telling the FCC for many years … that the transition can’t be completed in the unrealistic timeframe that the FCC is perpetuating,” she says.