IATF Seeks Comment on Repacking Plan That Won't Interfere With Move to ATSC 3.0

Stations with a more complicated repacking -- such as those located in a geographically challenging area -- would be in later phases, giving them more time to complete the process, Kiddoo said. Stations that are located in the 600 MHz wireless band would be in early phases, to clear the path for the new wireless owners of the spectrum “as soon as possible,” the IATF said in a fact sheet. The item proposed not allowing broadcasters to use temporary channels.

Broadcasters and their attorneys told us they were still reviewing the proposal and gauging its impacts. It's difficult to know the effect of the repacking plan with the auction still ongoing, since the number of broadcasters repacked will shrink with each stage, broadcast attorney Jack Goodman said. Carriers had some concerns, too. NAB declined to comment.

In a technical appendix released with the PN, an IATF model estimates around 1,300 broadcasters being repacked at the current clearing target of 114 MHz, and just over 1,200 at the next lowest clearing target of 84 MHz. America's Public Television Stations CEO Patrick Butler praised the commission's work but said he continues to be concerned about the availability of resources during the repacking. “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,” Butler said.

The plan won't interfere with efforts​ to coordinate the ATSC 3.0 transition with the repacking, since broadcasters will be able to replace outdated equipment with ATSC 3.0 equipment if it's available, Lake said.

Since each phase has different deadlines for the stations involved to be off their pre-auction channels, the phased system should prevent the limited numbers of tower crews and antennae manufacturers from being stretched too thin, Lake and Kiddoo said. There will be no more than two phases to a designated market area, and the IATF will try to limit the number of stations in a phase that have “linked” transitions -- meaning one station can't move until another does because of interference or other concerns, the IATF said. To assign stations to phases and consider criteria such as minimizing viewer rescans and preventing interference, the IATF will use “a mathematical tool” called the “phase assignment tool,” the IATF said. A similar “phase scheduling tool” will be used to set the deadlines for each phase, Lake and Kiddoo said.

The phase assignment tool uses FCC calculations of the time and resources the repacking will take to assign each phase a deadline, Lake said. “Putting stations into different phases with a detailed schedule 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,” said the IATF.

Each phase would also have assigned testing periods, to allow the stations involved to test their equipment on their new channels, with minimal interference to others, the IATF said. The proposed plan also would allow temporary increases in the amount of allowed interference up to 2 percent, the IATF said. “Allowing temporary limited increases in interference between two stations is in accord with past transitions,” said the fact sheet.

Wireless Reaction

Wireless carriers and their lawyers expressed some skepticism based on the FCC release and comments. Carriers have faced long, complicated transition processes, for example, clearing government incumbents from spectrum after the AWS-1 auction and dealing with the interference issues that followed the 700 MHz auction, industry officials said.

“I think wireless carriers will be pleased with the general principles being adopted here, in that it will force broadcasters not to delay,” said Davina Sashkin, who represents broadcaster and wireless clients at Fletcher Heald. “On the other hand, it relies heavily on broadcaster coordination with one another, which is difficult to enforce and manage.”

“At first blush, the basic framework seems reasonable, but with something like the post-auction transition, the details matter,” said a lawyer who represents carriers. A carrier executive said the FCC is mostly trying to show progress.

"While we are still reviewing the plan, it’s clear that the FCC understands the importance of access to low-band spectrum for carriers, consumers and the economy alike,” Competitive Carriers Association President Steve Berry told us. “I am glad to see the FCC will complete the transition within the statutorily derived 39-month time frame. CCA will work with carriers, broadcasters, tower crews and the FCC to ensure a rapid and safe transition to meet this goal.”

Carriers and consumers throughout the U.S. need access to the 600 MHz spectrum as soon as possible, Berry said. “We know that in many rural areas of the country, such as Wyoming and surrounding states, there are few impediments to deploying the 600 MHz spectrum and allowing consumers quickly to reap the benefits,” he said. “We are hopeful that the FCC takes this into account when geographically prioritizing what stations to clear and when.”

T-Mobile, expected to emerge as a big player in the auction, welcomed the plan. “We are pleased the FCC is moving forward with a detailed plan providing the foundation for a rapid and orderly post-auction transition so we can put the spectrum to use for our customers as quickly as possible,” emailed Steve Sharkey, vice president-government affairs. “We are reviewing the details of the proposal and will continue to remain engaged on ways to refine the approach and facilitate the transition.”

“A smooth and speedy transition will be key to meeting consumers’ demand for mobile broadband services,” said Scott Bergmann, CTIA vice president-federal regulatory affairs, in a blog post. “We are glad that the FCC is working actively to prepare for the transition and welcome the opportunity for input.”