Surviving the Incentive Auction and the FCC
Bruce Franca, NABMay 4, 2013
Want to thank Byron and NTAfor inviting me to speak
ME!
Change is Inevitable - except from a Vending Machine
Robert C. Gallagher
Outline
• Quick Review of Incentive Auction • FCC Proposed Band Plans • Repacking • TV Translator Issues
Incentive Auction
Reverse Auction
(Broadcaster bids)
Broadcasters Wireless
(Wireless bids)
Forward Auction
Repacking
FCC
Auction Reimbursement and Payments
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Treasury
Payments to Broadcasters who
Sell or Share(Fixed payout)
Broadcasters
Additional Revenue to
Treasury
(Amount will vary based on auction
proceeds) Reimbursement for
Repacking (Amount will vary based on repacking – up to $1.75B)
Incentive Auction
• “Voluntary” Participation, “Repacking” and “Eligibility for Reimbursement” Applies Only to Full Power and Class A stations– Does NOT INCLUDE LPTV and TV
Translators • FCC Band Plan and Goal to Maximize
Spectrum Recovered for Broadband – Could Have Major Impact on TV Translators
FCC Proposed Band Plan
• Plan “Split” with Uplink from TV Ch. 51 down and Downlink from Ch. 36 down (TV remains in the middle)
• Downlink Nationwide but Uplink “Variable”
• 6 MHz Guard Bands for Unlicensed
• Wireless 5 MHz Blocks Licensed by Economic Areas (EAs)
FCC Proposed Band Plan
• NAB Identified Several Major Problems with FCC’s “Split” and “Variable” Band Plan for BothWireless Carriers and Broadcasters
Some Split Band Problems
• Intermodulation Products/ Harmonics fall in Wireless bands and create interference
• Interaction of Uplink and TV will cause interference to Downlink
• Large separation in frequency between uplink and downlink – Inefficient or larger handset
antennas– MIMO not practical
• NAB Preferred Overall Plan
• Wireless carriers agree with “split” problems but still supported “variable” spectrum approach to maximize spectrum for broadband
NAB Band Plan
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FCC Variable Band Plan
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FCC Variable Band Plan
FCC Variable Band Plan
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• Different spectrum amounts in different markets requires the development of co- and adjacent-channel separation distances between television and broadband services to avoid interference
• Mismatch in channel bandwidths (5 and 6 MHz) and service areas (TV Service Contours vs. EAs) adds further complications
NAB “Variable” Band Plan Assessment
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Illustration of Band Plan Misalignment
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6 MHz TV Channels in 1 MHz increment
Wireless 5 MHz blocks in 1 MHz increment
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Interference from TV to Wireless
• TV operation on ch. 49 is co-channel to both C and D blocks and adjacent to both E and B blocks
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TV operation on channel 49
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Interference from Wireless to TV
• C block operation co-channel to TV chs. 49 & 50
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Transmission of C block
Base Station Downlink
Handset Uplink
Interference Cases• Interference to DTV Reception
Interference Cases• Calculated Interference Mitigation Distances
based on:– FCC Testing of DTV Receivers– Existing TV White Space Rules– Part 27 Requirements (upper 700 MHz)
Comparison of Wideband and Narrowband Interfering Signals
Interference Cases• Interference From DTV to Wireless
Interference to Base Station Receiveron Uplink Frequencies
Interference to Wireless Handset on Downlink Frequencies
Interference from DTV transmission • Required Separation from TV Transmitter to
Base Station Receiver Based on:– TV station transmit parameters:
• Transmitter Height Above Average Terrain (HAAT) 305 meters• Transmitter Effective Radiated Power (ERP) 1 MW
– Base station receive parameters :• Receiver height above ground 9.1 meters
– Two assumption were made about the signal level required to “desense” base station receiver:
• Assumption 1: TV field strength value that does not exceeds 17 dBµ at the base station receive site
• Assumption 2: TV field strength value that does not exceeds 40 dBµ at the base station receive site
Wireless Band
Interference Separation Distance Required to Mitigate Interference
From To Co-channel Adjacent Channel
Uplink Handsettransmission
TV receiver DTV contour + 5 km DTV contour
TV transmission
Base station receiver
225 to 375 km 100 to 130 km
Downlink Base station transmission
TV receiver 150 to 225 km 90 to 130 km
TVtransmission
Handset receiver
130 to 150 km 90 to 130 km
*Note that the downlink separation distances will depend on power and height ofbase station and sensitivity and out-of band rejection characteristics of the handheld device
Uplink Separation Distances
225 km(7 EAs)
375 km(15 EAs)Washington-Baltimore EA
TV Channels 47, 48 and 49
Overlay of EAs on TV channels (47 to 51) coverage
Variable Band Plan Bottom Line• Inefficient Repurposing of Spectrum• Complicates Auction and Repacking Process • Makes it More Difficult for Manufacturers to
Build TVs and Handsets• Unnecessarily Disrupts Broadcasters and
Viewers, Particularly in Rural Areas where Additional Wireless Spectrum is Not Needed
REPACKING
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Broadcasters Repacking Nightmare!
From This
To This
NAB Repacking Studies
• Large Number of Repacking Studies Completed over Past 3 Years
• Recent Work on OET-69 Changes • Number of Studies Looked at Impact on
LPTV/TV Translators • Maximizing Spectrum Recovery Will
Impact TV Translators in Western States
Early Studies on Impact of National Broadband Plan
to Reclaim 120 MHz
Station Type Total Number of Stations
Number of Stations above TV
Channel 30Full Power 1,755 672Class A 502 209LPTV/Translators 6,434 3,214Total 8,671 4,095
MarketNumber of Broadcast Stations (Full power, Class A, LPTV) Required to Be Relocated to Lower Channels* 120 MHz 90 MHz 84 MHz 60 MHz 30 MHz
New York 42 stations 32 stations 30 stations 23 stations 12 stationsLos Angeles 66 51 48 33 23Chicago 21 19 18 12 6Philadelphia 26 20 18 12 5Boston 21 12 12 6 2San Francisco 33 27 25 18 9Dallas/Ft. Worth 25 19 18 13 7Washington, DC 35 27 26 17 8Atlanta 22 17 17 12 8Detroit 10 9 9 6 3Minneapolis/St. Paul 64 46 46 37 24Phoenix 96 75 70 50 24Portland, OR 55 45 40 28 12Bend, OR 9 6 6 3 2Eugene, OR 44 33 31 22 13Medford‐Klamath, OR 50 39 36 25 17Denver, CO 141 110 102 72 36Salt Lake City, UT 580 422 390 277 14134
Broadcast Stations to be Relocated to Lower Channels
Amount of Spectrum Reclaimed
Station Type TotalNumber of TV Stations
Number of TV StationsAffected
Total number of TV Stations
Affected120 MHz Full Power 1,735 672 4,095
Class A 502 209Low Power 6,434 3,214
84 MHz Full Power 1,735 450 2,826
Class A 502 143
Low Power 6,434 2,233
60 MHz Full Power 1,735 320 2,072
Class A 502 101
Low Power 6,434 1,651
30 MHz Full Power 1,735 148 1,078
Class A 502 50
Low Power 6,434 88035
NAB Repacking Studies
DMAs Affected if 120 MHz Reclaimed
DMA Industry Study Results
Amount of UHF Spectrum
Reclaimed
Station Type
Minimum Numberof Volunteers
Needed
Number of DMAsAffected
120 MHz Full Power + Class A
391 86
84 MHz Full Power + Class A
215 53
60 MHz Full Power + Class A
151 33
Channel Shortfall (Full Power, Class A, Border Protection)
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DMA Rank(2010-2011)
Market Number of TV Stations
TV Stations With No Channel
1 New York 27 16
2 Los Angeles 29 14
3 Chicago 22 6
4 Philadelphia 24 14
5 Dallas-Ft. Worth 20 2
6 San Francisco-Oakland-San Jose 28 14
7 Boston 23 9
8 Atlanta 18 2
9 Washington, DC 22 9
10 Houston 19 4
11 Detroit 14 14
12 Phoenix 25 2
13 Seattle 18 10
14 Tampa 19 4
15 Minneapolis-St. Paul 20 0
Areas Most Seriously Affected by Repacking
Station Shortfall vs. Spectrum
30 MHz 60 MHz 84 MHz 120 MHzFP+ClassA+LP 1095 1417 1776 2530FP+Class A 102 151 215 391Full Power 54 79 108 210
0500
100015002000250030003500
Stat
ion
Shor
tfall
Previous Studies
Findings/Lessons Learned • Limited number of DMAs are critical to the
recovery of any amount of spectrum• Not all “critical” DMAs are located in the top 30
markets– Relative location of DMAs to each other more
important than their size– For example Salisbury, MD (DMA 143) and Scranton,
PA (DMA 54) affect the repacking and recovery of spectrum in the Boston/Washington corridor
Findings/Lessons Learned • Key to reclaiming any significant amount of
spectrum (in Major Markets) depends on the collective decisions of ALL stations in critical DMAs
• Maximizing spectrum by repacking harms TV Translators and Rural TV service
• International coordination (especially along US/Canadian border) will have a great impact on amount of spectrum being reclaimed
International Coordination
• Letter from entire Michigan Senate and Congressional Delegation
Simple Coordination Example • In July 2011, FCC
establishes 12/31/2011 as date when all TV translators on Chs. 52-59 must cease operation
• Lake of Woods files for replacement channels in March 2010
• 17 months later (8/1/2011), Lake of Woods notified that Canada objects and applications dismissed
Translator Implications
NAB Reply Comments Highlighted Potential Impact on TV
Translators
NAB Replies• Spectrum reallocation should be limited to
spectrum recovered from voluntary incentive auction and used to create nationwide blocks for broadband
• Repacking is about organizing spectrum not reclaiming more spectrum
• Reallocating more spectrum beyond the auction – Disproportionally hurts Western states by wiping
out low power stations and TV translators– Undercuts ability to diversify industry and
broadcasters ability to innovate– Eliminates unlicensed use of TV white spaces `
NAB Replies• Spectrum Act did not “alter the spectrum usage
rights of low-power television stations” does not mean FCC should treat TV translators and LPTV stations as if they don’t exist
• A significant number of the existing 1,984 LPTVs and 4,171 television translator stations will be forced off-the-air– Displaced by wireless broadband, class A or Full
Power TV and no replacement channel or– Displaced and lack of funds to rebuild
• FCC should protect LPTV and TV Translators whenever possible
NAB Replies• For more than 30 years, FCC has lauded role
of LPTV and TV translators – Providing diverse programming and ownership
opportunities for minorities and women– Lifeline to rural Americans, where TV translators
provide the only means for them to obtain free over-the-air television
– Impact in Arizona, California, Oregon, New Mexico, Nevada, Colorado, Utah, Wyoming, Montana and Idaho would be particularly severe
Colorado TV Translators, LPTV and Class A Stations
• 554 TV Translators, LPTV and Class A stations (5 Class A) in State of Colorado
• 221 on TV Channels 30 and above
• Minimum of 124 without a channel if 120 MHz reclaimed
Colorado Translator and LPTV Station Coverage Today
NAB Replies• Spectrum Act requires FCC to “make all reasonable efforts to
preserve” the “coverage area and population served of each (full power and class A) broadcast television licensee”– Congress’s clear intent is to protect viewers’ service– Contrary to statute to fail to make all reasonable efforts to
preserve the populations served via translators• FCC has consistently found that translators serve the public
interest by providing valued and varied television service, particularly to isolated areas and smaller communities that would not otherwise enjoy such free service– Viewers’ service today - news, weather, emergency information,
sports and entertainment programming - depends on stations’ use of translators.
Translator Examples• ABC affiliate, KOAT-TV, relies on a state-wide system of 31
translators to serve the Albuquerque-Santa Fe DMA– Translators cover approximately 47 percent of DMA and serve
about 285,000 television households, or approximately 39 percent of all television households in the market
– Five of the station’s translators provide coverage to over 23,500 Native Americans on tribal lands
• KATU(TV), another ABC affiliate, uses 8 translators to serve the Portland, Oregon DMA. – KATU’s translators provide service to more than 590,000 people,
reaching more than 20 percent of its television households
Translator Examples• KNPB in Reno, Nevada uses 28 translators to reach 423,000
of its 845,000 viewers, including 27 tribal communities• WGEN-TV, Key West, Florida has a network of 5 translators
that provide Spanish-language programming throughout Keys• KNPB in Reno, Nevada uses 28 translators to reach 423,000
of its 845,000 viewers, including 27 tribal communities • 50% of New Mexico public television viewers (including
members of the Navajo Nation) are reached by translators• Translators provide service to 69 percent of public television’s
coverage in Wyoming
NAB Needs Your Help• Need to inform Washington and FCC
about the importance of TV Translators• Need additional real-world examples
– Serving public safety needs – Serving native American, foreign language
audiences• Need translator community to contact
local, state and federal representatives to get the message to the FCC
Importance of TV Translators • Congressional
Letters from California and Colorado
• Recent Letter from New Mexico Congressional Representatives
– 600,000 New Mexicans rely on over-the-air TV
– Served by over 200 TV Translators
THANK YOU
• My contact information:
Bruce FrancaE-mail: Bfranca@ nab.orgTelephone: (202) 429 - 4188
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