NAB wacked away at what it says are inaccuracies presented to commission officials by T-Mobile about the Digital Tech Consulting repack report.
T-Mobile officials recently told the agency not to delay the auction and that budget set aside and timeline for television owners to move is doable; it urged the agency to release the spectrum that broadcasters give up ASAP.
The DTC report estimated more money and more time will be needed for broadcasters to make the channels moves during the repack. T-Mobile said the report overestimated the scope of the repack and underestimated the resources to achieve it. T-Mobile asserts tower work is less taxing than claimed and more tower crews are available than the report suggests.
In a meeting with representatives from Commissioners Jessica Rocenworcel, Ajit Pai and Michael O’Rielly, NAB representatives pointed out broadcaster have every incentive an expeditious transition. “However, we also understand the incredible complexity such a transition is likely to involve and, based on every past transition and the likely size and scope of the project required by the auction, there is little or no chance every station will transition within 39 months,” NAB EVP/General Counsel Rick Kaplan writes in an ex parte notice describing the meeting.
NAB and other broadcasters have asked the agency “to reconsider the death penalty its rules currently require should a broadcaster not be able to relocate to its newly assigned frequency within 39 months following the auction.”
NAB says in T-Mobile’s count of 40+ available tower crews, T-Mobile included crews that NAB members have never heard of and some that no longer perform tower work. NAB tells the FCC that just because someone climbs a tower does not mean that person can work on an antenna.
“These are not experienced, trusted partners, and broadcasters will not put their most valuable asset in the hands of unproven vendors identified by a company that operates in a completely different network environment,” says NAB.
T-Mobile also failed to take into account winter weather in its timeline, says NAB.
Antenna manufacturers have told the broadcast trade lobby some 1/3 of broadband antennas will need to be removed and remade to operate on a new channel. That’s because while broadband antennas are technically capable of working over multiple frequencies, when they are used on a different channel, in most cases the antenna pattern and/or gain will change. This bears out in RBR+TVBR’s recent series by GatesAir and Dielectric on the repack.
“Beyond its technical inaccuracy, T-Mobile’s suggestion that the FCC should consider frequency agility of broadcast antennas in its optimization process is disingenuous. The FCC has made plain that it will not conduct optimization during the auction itself. The only optimization the FCC will conduct in assigning stations to new channels will be at the very end of the auction, at which point it will be too late to assign most stations to particular channels or optimize so that only stations with broadband antennas are repacked. In short, even if T-Mobile’s suggestion that any broadcaster using a broadband antenna will not need to replace its antenna to repack were accurate, which it is not, there would be no meaningful way to take that into account during optimization,” wrote NAB.
Further “T-Mobile’s report dangerously oversimplifies the repacking challenge by focusing exclusively on tower height. The relevant question is not how many tower crews may be qualified to perform work on tall towers. Rather, the relevant question is, how many tower crews have the experience, training and equipment necessary to perform broadcast work and antenna installations. The fact that a given tower crew may be qualified to climb a tower to replace a beacon or perform maintenance is irrelevant to determining whether that same crew can safely and correctly install a multi-ton antenna,” NAB tells the agency.
The broadcast trade lobby says it remains interested in working with other stakeholders to address the repacking challenge. However, T-Mobile has concentrated on commissioning an outcome-driven, oversimplified and misleading analysis, and developing a repacking plan in isolation, according to NAB. “Disappointingly, commission staff meanwhile appears to be focused only on auction expediency and is imploring broadcasters to be optimistic and simply trust that the optimization process will work as yet unforeseen miracles.”