Broadcasters Want Aggregate Interference Cap
The FCC should cap the total interference that TV stations will experience as a result of the TV incentive auction repacking, said NAB, affiliates of Block Communications and consulting engineering firm Cohen Dippell in comments on a public notice (CD June 4 p17) on how much interference broadcasters are likely to see as a result of the repack. Though the incentive auction order proposed that stations’ new interference reception would be limited to 0.5 percent per station repacked, commenters all proposed solutions that would limit the total new interference any station could receive, rather than the total per repacked station.
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"The FCC appears to be content to seek to ‘minimize’ new interference rather than carry out its statutory duty to make all reasonable efforts to ensure that there is no new interference,” said TV stations owned by Block Communications. The FCC’s standard of interference “is untenable and threatens to deprive many, many TV viewers of relied-upon service,” said the Block comments (http://bit.ly/1sovb4S). No commenters filed in support of the FCC standard in docket 12-268, which had a comment deadline of last Thursday.
Wireless companies and the FCC prefer to limit interference per station repacked because it allows more flexibility in repacking stations, and could lead to more spectrum being made available for wireless uses, said broadcast attorneys in interviews Monday. An FCC analysis found that about 1 percent of reassigned stations would receive new aggregate interference above 1 percent, and the majority would be below 0.5 percent, the notice said (http://bit.ly/1uywlKI). The projections were made by running numerous repacking simulations, the PN said.
Data from those simulations were released last month, and examination of the data has found possible errors in the simulations, NAB said (http://bit.ly/1n8E1DD). The association found “anomalous” results in the data, though it said it can’t be sure of the cause without more information. The FCC analysis results “are based on an interference paired file containing possible errors that could affect the generation of these repacking scenarios and ultimately the aggregate interference results,” NAB said. The FCC should identify the source of the anomalies and do more studies, NAB said. The FCC Incentive Auction Task Force did not comment.
The FCC needs a cap on the aggregate amount of interference because the current 0.5 percent interference per station standard won’t protect repacked stations that face multiple sources of interference, NAB said. “As repacking scenarios become tighter, it is possible that aggregate interference just over the threshold from multiple stations could increase.” The commission’s projections were also “optimistic” on the amount of stations participating in the auction, NAB said. If fewer broadcasters participate, there will be more interference to contend with, NAB said.
NAB and the Block stations want the FCC to institute a 1 percent cap on aggregate additional interference from the repacking. “That’s the only way that makes sense from a station owner’s standpoint,” said broadcast attorney Jack Goodman, a former general counsel at NAB. Doing otherwise would be tantamount to allowing stations to face an unlimited amount of new interference, said another broadcast attorney. “Absent a cap, each station potentially would be subject to several times the 0.5 percent interference limit,” said the Block filing. “This easily could translate into millions of viewers losing over-the-air TV service they have depended upon for decades."
The commission could instead adopt a compromise method, suggested Cohen Dippell (http://bit.ly/1mBV4yN). Aggregate interference could be capped at 0.5 percent if 100 or fewer stations participate in the auction, but rise to 1 percent if more than 100 participate, said the engineering firm.
The FCC should continue to analyze the repacking, but perform tests using actual channels rather than the proxy ones used for the previous scenarios, NAB said. “The use of actual channels in the analysis of interference to population served represents a significant improvement and will provide more accurate repacking solutions.”