Stakeholders prod FCC for “down from 51” plan


GavelIt should tell you something that the industries that are expected to sell and buy spectrum when the incentive auctions take place agree on the way television channels should be repacked, and it should tell you a lot more that they are dismayed the FCC has decided to consider other methodologies.

The companies that will be providing equipment for the project also agree with broadcaster (the potential sellers) and wireless companies (the potential buyers).

AT&T, the National Association of Broadcasters and Verizon collaborated on a blog in which they stated their jointly-held views.

The key is the mitigation of interference issues. Without that, values will be driven down and the ultimate success of the auctions compromised.

Experts from all three industries have studied the issue backwares and forwards, they stated. “The result is growing consensus for adoption of a “down from 51” framework that seeks to maximize paired allocations and build guard bands only to meet engineering necessity. This approach reflects the best collective engineering judgment of the companies most affected by the auction, including those that will spend billions of dollars to purchase 600 MHz licenses at auction and billions more to develop and deploy the spectrum in U.S. wireless networks.”

The FCC is now considering two other approaches, which these stakeholders oppose. One, which they note features a “time division duplex,” has no support whatsoever in the record, and the second flies in the face of the consensus approach favored by the stakeholders.

They believe the FCC is angling for market-by-market flexibility, but argue that all the proposals will do is draw attention away from other still-pending issues.

They concluded, “Each of us of course will respond to the notice, but we don’t anticipate any fundamental shift in positions we’ve already taken in the record. In the meantime, we are concerned about the apparent disconnect between the FCC and the various industries that will be critically affected by this auction. Nothing about this auction will be easy, and, if we are to succeed, we must all work together to find solutions best designed to respond to broadcast industry concerns while meeting wireless industry requirements.”


  1. There are dramatic differences between the various band plans, with how much spectrum they each would require. This is especially important for the LPTV service, many which are now licensed in the upper UHF band. For example: In the 120-MHz plan (clearing 51-38), while there are 658 full power and 91 Class A stations which will need to relocate, there are over 1,896 LPTV stations which will have to find a new place in the new core, and that is after those full power and class a’s have first shot at a frequency. To make matters worse there are already over 2,405 LPTV stations in what would be the new core. There simply will not be enough room for them all. However, in the 84-MHz plan, that is, 51-38, about 1,401 LPTV stations would have to move, but that is off-set by 2,900 LPTV stations currently in that new core. But those two less stations per DMA just might be the difference.

    We have estimated that between $250-$400 million will need to be spent by the LPTV stations to move around in the repack. This is a huge unfunded mandate by the federal government for these small businesses and it is not right!

  2. Correction to our above comments:
    120 MHz band plan (51-38, 36-32) = 1,896 LPTV stations to move
    84 MHz band plan (51-38) = 1,401 LPTV stations to move
    60 MHz band plan (51-42) = 991 LPTV stations

    120 MHz band plan (2-31) = 2,405 LPTV stations
    84 MHz band plan (2-36) = 2,900 LPTV stations
    60 MHz band plan (2-36, 37-41) = 3,310 LPTV stations

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