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

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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