The National Association of Broadcasters says it is OK with the FCC's phased approach to transitioning TV stations to new channels after the incentive auction, calling it a reasonable approach to spreading out the work required and trying to avoid bottlenecks in the supply chain for a daisy chain of station moves.
NAB called the FCC's post-spectrum auction repack proposal a "productive and critical step." It also said it agreed that there should be no more than 10 different phases, saying more than that would be overly complex.
But it also had a couple of suggestions for avoiding missteps.
The first was to prioritize minimizing viewer disruptions. The second was to remain flexible about which phase stations were placed in—saying they should be considered "tentative" assignments—based on "facts on the ground....Weather conditions, delayed zoning approvals, supply chain issues, and unanticipated engineering complexity for some stations can and will create delays that will have cascading effects for other stations."
Those came in comments filed after the FCC said it wanted input on the plan and was willing to adjust it according to that input.
NAB put a sharper point on its number two suggestion. "Unfortunately, while there is much promise in the proposed scheduling plan, the Commission’s continued insistence that the transition can be completed in 39 months has painted the Commission into a succession of unnecessary corners that ultimately threaten the transition’s viability," NAB said.
For one thing, NAB says that timetable drove the FCC to give stations only three months after the close of the auction to file construction permits and cost estimates—the FCC has $1.75 billion to reimburse moving costs.
NAB says that will lead to rushed applications that will likely need to be amended. NAB says the FCC needs to have a clear waiver standard for that 39-month deadline, which it called an "arbitrary and unattainable deadline."
NAB also has issues with the FCC's tool for estimating how long the transition will take, saying it makes "unreasonably optimistic" assumptions about the pace of change—failing to take weather and ratings periods into account and leaves little or no margin for error.
The FCC should better consider the fate of low-power stations in the transition, NAB said, and how the commission can minimize service losses from displaced LPTV and translator stations.
In fact, NAB points out, "the Public Notice makes no mention whatsoever of displaced low power television or television translator stations and how they will transition to new channels, if available, following the close of the auction. While NAB understands that many LPTV and translator stations may be displaced by repacked full power stations, failing to address how LPTV and translator stations will operate during the transition will result in significant service losses for viewers who rely on these stations."
LPTVs except for Class As were not allowed to participate in the auction—they have "secondary" status to full-powers—and can be knocked off the air if there is no room for them in the repack.