T-Mobile: 39 Mos., $1.75B Plenty For Repack

In a direct challenge to broadcasters, T-Mobile, which is expected to bid for TV spectrum in the FCC’s incentive auction, says that the government is giving broadcasters plenty of time (39 months) and money ($1.75 billion) to move to new channels in the post-auction repacking to the TV band.

The wireless carrier backed its claim with a 410-page study from the RF engineering firms of Broadcast Tower Technologies and Hammett & Edison.

The findings sharply contradict an NAB-commissioned study by Digital Tech Consulting (DTC), which concluded that the repack could take between eight years (if the FCC reallocates 120 MHz of the spectrum through the auction and has to move 800 stations in the repack) and 11 years (if the FCC reallocates 84 MHz and has to move up 1,200 stations).

The NAB has been using the DTV study in an attempt to get more time and money from the Congress and the FCC.

“The DTC Report is flawed because it overstated demand and understated supply,” the T-Mobile study says. “For example, DTC incorrectly assumed that every broadcaster will need to replace its antenna during repacking.

“DTC also assumed that there will be only 16 qualified tower and antenna installation crews available during the transition. These assumptions and others contained in DTC’s analysis are incorrect.”

Among the study’s other findings:

Not All Stations Will Need New Antennas. Broadcasters will not need new antennas in many circumstances because they often share antennas, and some antennas can be used on multiple channels. Almost 12% of UHF stations eligible to participate in the reverse auction reported to the FCC that they use antennas capable of operating across the full range of the UHF band, and nearly 20% reported using antennas that are capable of operating on six or more channels.

Not All Towers Will Require Modifications. Using the FCC’s conservative 2014 repacking simulations, we found that, on average, only 845 unique antenna structures will be involved in the repacking process. This estimate is lower than DTC’s finding because it takes into account the number of antennas that will not  need to be replaced. In addition, many remaining stations will be located on the same tower which promises additional efficiencies.

Many of these towers are also fully upgraded and will not require any additional modifications other than removing an old antenna and installing a new one.

Television Antenna Supply Will Be Sufficient. Contrary to DTC’s assertions, more than two manufacturers are capable of providing and, in fact, do provide antennas to broadcast stations. The nation’s current and potential manufacturing capacity is more than capable of meeting broadcasters’ demand for antennas during the repack, even more so once the potential for antenna sharing and broadband antenna reuse is considered.

Ample RF Consulting Engineers Are Available. The study identified 18 additional RF consulting engineers than DTC included in its analysis. An accurate tally of RF consulting engineers demonstrates sufficient capacity to assist with between 370 and 475 construction permit applications per month. The availability of RF consulting engineers should not pose a problem in meeting the initial three-month construction permit application deadline.

More Than Enough Tower Structural Engineers Are Available to Meet Anticipated Demand. The study identified 19 structural engineering firms capable of conducting work on tall towers, which we define as towers more than 1,000 feet tall (305 meters). The combination of fewer towers needing modification and greater availability of structural engineers means that tower structural engineering services will not delay the repacking process.

At Least 41 Tower Crews Are Available Today to Work on Tall Towers. The study identified 41 tower crews operating today that are capable of working on 1,000 feet tall towers. The firms employing these crews enjoy strong reputations for professionalism and service in the industry. DTC excluded several firms when it claimed that there were only 16 qualified tower crews in the United States, and discounted the possibility that any of these firms could meaningfully expand capacity.

Existing tower climbing firms are preparing for the repacking process and expect to increase the number of available crews. Even if one were to accept DTC’s assumption that one crew can complete only eight or nine antenna change projects per year and its assumption that these projects could not begin until six months into the repacking process, today’s workforce could complete at least 900 station relocations during the remaining 33 months of the transition.

The Repacking Process Will Likely Cost Less than $1.75 Billion. Based on the estimated number of stations that will likely need to be repacked as well as the number of stations that currently operate using solid-state transmitters and can use their current antennas on their new channel assignment, DTC’s  estimate that the cost of the repack could exceed $2.9 billion is overstated. Simply using a realistic number of stations that require repacking and identifying cost estimates based on broadcasters’ actual equipment would yield cost savings of as much as $1 billion or more. Additional savings are possible and provide us with confidence that the congressionally mandated budget of $1.75 billion is realistic, if not generous, for the actual task at hand.