Broadcasters, CEA, CTIA Clash Over TVStudy Software
Broadcasters and their consulting engineers clashed with the consumer electronics and wireless industries over the merits and legality of updating the FCC’s DTV interference software for the purposes of calculating interference between stations after the planned spectrum incentive auction. The commission released an updated version of its interference prediction software described in the FCC’s Office of Engineering and Technology Bulletin 69 (OET-69) called TVStudy last month and asked for feedback on it (CD Feb 6 p10). CEA and CTIA each urged the agency to use the proposed changes, which they say will make the software more accurate.
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But in joint comments, NAB, Fox, CBS, NBCUniversal, ABC, and the affiliates associations of the four major networks raised a host of concerns with the new software and the way the commission plans to update it (http://bit.ly/Y4hlYR). They said the new software changes the methodology of OET-69 and violate the law that authorized the incentive spectrum auction and that the new software will substantially reduce the predicted coverage areas of “a significant number of television stations.” Some stations in California and Washington would lose more than a third of their predicted viewers as a result of the changes, they said.
They also claimed procedural flaws with the public notice announcing the proposed changes. Any changes to OET-69 should be made at the commission level, not the staff level, they said. “Meaningful evaluation of the TVStudy software requires a formal comment period that provides commenters with sufficient time to assess and troubleshoot the software’s features,” they said. Others working in the broadcast industry also complained about the timeline. The Merrill Weiss Group, a consultancy, said it did not have enough time to evaluate potential concerns about how the new software handles stations with distributed transmission system (DTS) authorizations (http://bit.ly/14hOKD1). “Six weeks has not been sufficient time to get the software environment installed, operating, tested, given the necessity to continue providing services to clients who depend on us,” it said.
Sinclair Broadcast Group opposed the software’s use on statutory grounds. “It does not comply with the Spectrum Act and therefore it must not be implemented” (http://bit.ly/WJM24t). Like NAB, Sinclair said the kinds of changes proposed in the software require a formal notice and comment rulemaking proceeding. “The FCC released the software, with no advance notice, for an operating system that is not widely used in broadcasting engineering,” it said. “Sinclair is concerned that the FCC has released what appears to be beta software and stated that it intends to use that software for repacking, rather than asking” whether it complies with Spectrum Act and is suitable to be used, Sinclair said.
CEA said the new software is far more accurate than what has been used in the past to calculate DTV interference. It uses newer census data, a more detailed mapping system, more accurate information about each station’s antennas culled from the Consolidated Database System, and flexible treatment of cells flagged as “dubious or unreliable” by the Longley-Rice analysis, among other improvements, CEA said (http://bit.ly/Y4qwbH). “More accurate coverage and interference calculations made possible by the TVStudy software are essential” to meeting Congress’s requirement that the agency take all reasonable efforts to preserve TV stations’ coverage area and population served, it said.
CTIA also said it supported the new software. Updating the operating system it’s built on, including more up-to-date census data and using more granular terrain as the new software does will give a more accurate implementation of the Longley-Rice methodology, CTIA said (http://bit.ly/WJMRKP). That could mean the software shows lower expected population served under the new analysis, according to figures in CTIA’s comments. In looking at WGBH-TV’s signal in Boston, “the overall effect is a loss of 1,913 square kilometers in coverage area (a reduction of 5.6%) and a reduction in population served of 117,949 people (or a reduction of 1.5%).” In other markets, where it looked -- Chicago and Washington, D.C. -- the drop was not as sharp.
In any case, the TVStudy software is only a one piece of the repacking puzzle, CTIA said. “CTIA urges the Commission to complete its repacking algorithm and provide it to the public for review,” it said. “This will enable all affected stakeholders the opportunity to understand the methodology used by the Commission while ensuring that the algorithm itself is the most effective and efficient model,” it said.