The FCC Friday issued a public notice outlining its plan for the "order and schedule" for repacking broadcasters into smaller spectrum space after the broadcast incentive auction. The FCC will try to move stations repacked into the wireless band as early as possible so wireless operators can get access to that spectrum expeditiously but also give stations with complicated moves more time. But in either even, the order will be determined primarily by how much spectrum, and where, is reclaimed in the auction.
The FCC will be playing an important game of "phase 10," and it wants broadcasters to know the rules.
It will be a phased approach with the goal being that the move of chains of stations whose repacks will be linked are the least disruptive to viewers and the most efficient in terms of limiting interference and utilizing limited tower crews.
Media Bureau chief Bill Lake said Friday the goal is an "efficient and orderly" transition.
While there were early talks of a regional approach to the repack, Lake says it turned out to be more about physics than geography.
The temporary interference between stations during the repack will be limited to 2%, which is in line with the DTV transition, but the FCC is proposing not to allow for use of temporary channels during the transition, but is seeking input.
There will be 10 repack phases, with each station put into one of those phases and with staggered completion dates "to ease coordination issues and enable the Commission to track progress." Phasing is also meant to prevent undue interference to broadcasters as they make their moves.
The repack will not be regional per se—though geography is a factor—but instead according to the chains of stations whose moves are linked—like dominoes falling. But the FCC will make sure that no more than two phases will apply to stations in each market so viewers will only have to rescan for new channels, at most, twice.
The FCC describes the challenge of moving those chains of stations this way: "With hundreds of stations nationwide needing to move to new channels, there is the potential for a 'traffic jam' in which a station can’t move to its new channel until a second station moves, and that station in turn must wait for a third station to move, and so on. Stations whose moves are dependent on another’s move are called 'linked stations,' and these links can span dozens of stations across a large geographic area. Linked stations can switch to their new channels simultaneously to break up these congestion points, but doing so requires careful coordination."
Why 10 phases? The FCC says that strikes a balance between limiting the size of those chains of linked stations and "other goals." Those would include the geographic element of trying to transition stations within the same DMA at the same time (the limit of only two phases for each market). The FCC also says it will "let stations, tower crews, and equipment manufacturers know when the FCC expects specific stations to complete their transition and so that they can plan accordingly. It also ensures that the majority of stations will be able to test on their post-auction channel during a specified testing period without having to coordinate with neighboring stations – or those stations’ neighbors."
Once phases are assigned, the FCC will determine when those stations move using a "phase scheduling tool" that estimates the total time for each station's transition, which will help the FCC determine an end date. The tool "assigns minimum completion times for each station based on certain characteristics;" allows the FCC to assess the impact of unknowns such as the order in which stations receive required resources; and "gives the FCC the ability to gauge the impact of resource availability and adjust accordingly."
Exactly how the repack will be structured depends on what and how many stations give up that spectrum, so what group of stations will be going first has yet to be determined. The proposal essentially outlines how, once the FCC knows that final band plan, it will assign stations in those 10 phases and on what staggered timetable.
But the FCC is putting a priority on repacking the stations in the wireless band, so forward auction bidders can start using that spectrum as soon as possible.
"Assigning U.S. stations whose pre-auction channels are in the 600 MHz Band to earlier phases would help open it up to licensees to offer new innovative services," the FCC says.
The FCC will also try to put more complicated repacks later in the process.
Stakeholders will be able to comment on the plan. In fact, Lake emphasized it was a proposal and he welcomed input on making it better.
Lake also said there would be a webinar on the repack proposal Oct. 13.
Look for CTIA to put its two cents in on the proposal.
“A smooth and speedy transition will be key to meeting consumers’ demand for mobile broadband services," said CTIA VP Scott Bergmann. "We are glad that the FCC is working actively to prepare for the transition and welcome the opportunity for input.”
The National Association of Broadcasters had no immediate comment, but noncommercial broadcasters used the announcement to highlight ongoing issues with the repack timetable.
"America's Public Television Stations appreciate the FCC's timely release of a draft plan for post-auction repacking. We look forward to reviewing the draft plan in detail and providing constructive comments to the Commission," said America's Public Television Stations president Patrick Butler. "We remain concerned that a 39-month deadline for completion of the repacking process is quite challenging, given the limited number of engineers, tower companies and other expert personnel required to make this transition, but we commend bureau chief Bill Lake and his colleagues for their thoughtful approach to a difficult set of issues."
Low power TV operators will be vetting the plans for what they see as a forced march with an uncertain destination.
"With the [request] for comments about the FCC's post-incentive auction transition scheduling plan, the LPTV industry can now further refine the potential $1.5 billion in negative auction impacts on it," said LPTV Spectrum Rights Coalition director Mike Gravino. "This is all about timing. If you are in a PEA which is cleared quickly, did we ever really have 39 months to relocate?"
The item does not address broadcasters' request that the repack be coordinated with a regional rollout of ATSC 3.0, but it also doesn't address costs and equipment issues.
The spectrum auction is currently in its second stage at a 114 MHz clearing target, having failed to generate enough bids in the forward auction to pay the $88 billion the FCC had to pay broadcasters to clear off 126 MHz.
The auction could last until early 2017 but could also end before the end of the year, so the FCC is not waiting around to outline how it will handle the transition.
The FCC has set a 39-month transition window for TV station repacking, though with a waiver process for extenuating circumstances.
Wheeler has told Congress that there is flexibility in that timeline if the FCC finds that it is not doable. Some legislators have their doubts about the timeline.
Among the primary concerns are the sheer number of variables in the two-sided auction and spectrum repack, something the FCC has never tried before and has been described as a Rubik's cube of complexity.
Among the variables are the availability of construction equipment, the impact of weather (tall tower work is tough in any weather, more so in the wind and snow), local regulations and availability of personnel.
Then there is the possibility of equipment short-falls—transmitters, antennas—that could inflate the costs and delay the moves.