In a letter to Media Bureau Chief William Lake, NAB’s Rick Kaplan noted that the FCC never really explained why it froze television CPs, noted that it works at cross-purposes with the goal of maintaining a healthy television service and may in fact be having harmful effects.
Kaplan said, “The notice establishing the freeze failed to provide a convincing rationale for bringing the broadcast business to a standstill, and, to date, it still remains uncertain to whom exactly the freeze applies.
There clearly has not yet been an adequate examination of the true costs and benefits of such a freeze, including its impact on related industries beyond broadcasters and their viewers. The Bureau accordingly should immediately lift its imposition of this freeze.”
At the very least, the NAB wants the freeze lifted for stations that properly filed applications beforehand, saying they were acting to improve service to their viewers, have in many cases invested a great deal of time and money into the effort and are now seeing all of that money and effort go to waste.
Further, it appears that a side-effect of the freeze has been hastening the departure of Dielectric from the antenna marketplace, an event that could put broadcaster’s ability to timely comply with repacking moves in jeopardy.
Kaplan concluded, “For these reasons, we request the Media Bureau to lift its freeze until it is able to examine, evaluate and explain the freeze’s impact on all pending and impending station modification applications and on viewers and the television industry more broadly. The Public Notice neglected to do this, and as outgoing Chairman Julius Genachowski has made clear repeatedly, each Commission action should be subject to a rigorous cost-benefit analysis to determine whether it is in the public interest. NAB is eager to work with the Media Bureau to help determine the scope and potential consequences of a freeze of modification applications to ensure that any such freeze, if it should occur, will be beneficial for the impending auction and the broadcast industry.”