In comments submitted to the FCC, the NAB strongly made the case that every television channel forced to move due to channel repacking should be fully compensated for all related costs, and further demonstrates that the opportunities for “cookie cutter” solutions are all but non-existent.
For starters, NAB noted that the current list of expenses eligible for compensation is incomplete, and argues that all related expenses, including those for interim facilities, should be eligible.
FCC explorations into the possibility of savings using techniques such as bulk purchasing, competitive bidding and equipment sharing are impractical, largely because the circumstances of almost every television station are different, stating, “The universe of television transmission facilities is populated by customized, unique transmission architecture featuring a wide range of station-specific features that are a function of channel number, geography, tower site location and design, tower load limitations, weather and climate, number of tower users, tower crew availability, spectrum congestion, location of population centers within a market, and other factors.”
Time will be of the essence to pull off any repacking plan, and NAB strongly recommends keeping the forward auction open until the last possible moment, and issuing channel reassignments at the earliest possible moment thereafter.
An obvious goal for the FCC is to relocate as few stations as possible to make sure the $1.75B allocated to the fund is enough to go around.
To prevent fraud and abuse, NAB suggests that a 3rd-party administrator should administer the reimbursement program and that a set of principles be devised to assess the reasonableness of expenses.
NAB further recommends putting the onus on broadcasters to certify all of their relocation costs on penalty of losing their license.
The bottom line is that there is still a great deal of work to do in this critical component of the incentive auction program.