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‘Everyone Makes Mistakes’

FCC Shouldn’t Include TVStudy in Auction Order, says NAB’s Kaplan

The FCC shouldn’t include the TVStudy software planned for use in the incentive auction and repacking in its upcoming auction report and order, said NAB auction expert Rick Kaplan in an interview Friday. NAB commented Friday (http://bit.ly/1ghCXqp), urging the commission to use the original Office of Engineering and Technology-69 software instead, because even when running the same specifications as the original software, TVStudy produces different calculations for stations’ coverage area and population served. “Some stations lose and some stations gain, but Congress instructed the FCC to protect all stations,” Kaplan said. FCC officials and industry associations have said TVStudy has features the original OET-69 software doesn’t (CD June 3 p7), and it would be difficult to do the auction without them. “Not only does the new software improve upon the previous iteration, but it also contains features that will be necessary to conduct the incentive auction,” commented CTIA in docket 12-268.

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It makes sense for the FCC to use the most current software available, said CEA Vice President-Regulatory Affairs Julie Kearney in an interview. “Why wouldn’t you want to use the most recent, most accurate data?” she said. FCC engineers who will conduct the auction have selected TVStudy, said Kearney. “We update software all the time."

NAB disagrees that the new software is necessary to quickly calculate interference and coverage areas for the reverse and forward auctions. “You can totally run the auction on the old software,” Kaplan said. TVStudy has features useful for running the auction, but it’s possible to modify the original software to use many of them, said engineer Bill Meintel of Meintel Sgrignoli, who designed the original OET-69 software. Meintel has done consulting work for NAB on this issue.

TVStudy uses more accurate geographical data, and makes it much easier for the officials running the auction to check for interference between adjoining coverage areas, Bill Meintel said. Without modifications, the original software doesn’t have the capability to check for overlaps between station coverage, or store much of the data needed to make the calculations for the auction, he said.

"After all of this time and effort devoted to numerous different versions of its new software, TVStudy has been unable to replicate -- or even come close to replicating -- the results of OET-69,” said NAB. When configured to run using the same parameters as the older software, TVStudy results in a loss of coverage area for around 88 percent of the stations studied, NAB said. If TVStudy is run in the fully updated version using the parameters it would presumably use during the auction, it results in a loss of coverage area for around 52.3 percent of the stations studied, NAB said. It also said 52.1 percent of the studied stations lose population served under the newer study. The FCC declined to comment.

That TVStudy doesn’t get the same answers as the original software when running the same data is concerning, Bill Meintel said. It’s “an unanswered question” why the numbers come up different, and that erodes the confidence of broadcasters in TVStudy, Meintel said. The problem could be that the original software was designed to run on Unix computers from Sun Microsystems, but was updated to run on a PC and translated into a different computer language when it was updated to become TVStudy, Meintel said. The computers’ different processors or possibly some bad code introduced during the update could be behind the differing numbers. “It’s a very complicated program,” Meintel said. “Everyone makes mistakes.” That the reason for the differing numbers isn’t clear is enough reason not to use TVStudy, Kaplan said.

Using the updated software isn’t intended to reduce station coverage but to accurately record it, CTIA and other commenters in the auction docket have said. NAB has argued that updating the software is changing the methodology of OET-69, which Congress required the FCC to use in the auction. Though commenters have argued that a software update doesn’t constitute a change in methodology, the differing numbers shows this isn’t the case, Kaplan said. “If you were just changing software, you should be able to get the same results.”