The National Association of Broadcasters has taken issue, make that issues, with the FCC's recent simulations of various scenarios for setting clearing targets for spectrum in the incentive auction.
In a filing with the FCC Thursday (June 4), NAB said the FCC's public notice on the simulations raises more questions than it answers, particularly by basing the simulation on a different standard for how much allowable interference there would be to stations and wireless carriers when stations are repacked after the auction.
Two weeks ago, the FCC released some data from incentive auction simulations — based on three separate spectrum clearing targets — of how it would "optimize" its reclamation and divvying up of the 600 MHz spectrum band between wireless carriers and broadcasters in the incentive auction. Optimizing means getting the most spectrum while creating the least post-auction interference (impairment) in the repacked spectrum bands.
The scenarios it ran were for freeing up 85 MHz of broadcast spectrum (if 40%-50% of broadcasters participated), 114 MHz (50%-60% participation), and 126 MHz (60%-70%) participation—Fox, Ion, Univision and Tribune have told the FCC it should shoot for 126 MHZ. “Participation” doesn’t mean that is what percentage of stations need to give up spectrum. That is the percentage who participate in the auction, win or lose.
The FCC has not set any of those target scenarios as policy, but simply set up the parameters and ran the numbers. It gave the public and stakeholder two weeks to comment on the data, and NAB had plenty to say.
NAB said it was troubled with the FCC's use of a new standard for limiting market variability—the difference in the amount of spectrum cleared in different markets—and was not sure how that would be applied. NAB called it a "step backwards" from the "shared goal" of a successful auction.
NAB is still pushing for a cap of 3% impairment in each market, rather than the 20% the FCC has contemplated, or the 10% it ran the simulations on. The less spectrum is impaired (subject to interference), the more valuable it is.
The association is also concerned that the simulations were run without taking into account the impact of impairment from Mexican stations. The FCC said that data was not yet available, but NAB pointed out AT&T had estimated such impairments, suggesting that if AT&T could do it, so could the FCC.