Intel miscalculated the “level of congestion” in the...

filings, said NAB. “The result inadvertently distorts the breadth of the challenge of repacking broadcasters.” The inaccurate filings demonstrate “how little is commonly understood about the task of relocating broadcasters who do not participate in the auction,” NAB said. In a study filed in docket 12-268 in March (http://bit.ly/WKg7Dl), Intel said 98 percent of TV markets have three or fewer stations above Channel 37, which NAB said suggests that the 600 MHz band is much clearer than it really is. “More than one-third of all full power and Class A TV stations (602 out of 1702 stations) in the UHF band are located above channel 37,” NAB said. Instead of basing its study on DMAs, Intel used each station’s city of license as its market, leading to “nonsensical results,” according to NAB. “The more appropriate approach would consider the effect of repacking through a DMA lens,” said NAB. The Intel study “considers Florida stations licensed to Leesburg and Melbourne to be in different markets despite the fact that the stations are located at the same transmitter site,” said NAB. The Intel study also contained “the head-scratching conclusion that Fairbanks, Alaska, is the most congested TV market in the nation,” NAB said. Intel said in an email Friday that its study is “directly derived from the FCC’s own database of broadcasters” and that it had discussions with NAB about the study before filing it that “generated no objections to use of the same FCC city-aggregated data.” Intel also said it concedes in its filing that “rigorous analysis of adjacent market interference will be necessary” to create a working band plan. The data from the Intel study were referenced by T-Mobile in reply comments filed in 12-286 earlier this month (http://bit.ly/11GXoVg). “According to Intel’s analysis, in 59 percent of markets, there are no broadcast television channels above Channel 37,” said T-Mobile in comments outlining its proposals for a 600 MHz bandplan. “Obviously, in those markets, 84 MHz can be made available without clearing or repacking any broadcasters at all,” said T-Mobile. T-Mobile did not comment. NAB said the record needed to be corrected so the communications industry and the commission can “work from the same page to properly analyze and address the enormous challenge of repacking and relocating broadcasters.”