CCA Analysis Gets Repacking Dynamics Wrong, NAB Says

“Despite it being in their members’ interest to fully come to grips with how long it will take to clear broadcasters from their 600 MHz channels across the country, CCA’s approach is lackluster and misleading,” wrote Franca. “Following the broadcast spectrum incentive auction, the FCC will require hundreds, if not more than a thousand, stations to move to new channels. No one knows, however, exactly how many stations will be forced to move or even the scope of what those moves will require.”

In the real world, repacking “is more than an academic exercise,” Franca said. He said NAB commissioned its own report, by engineering consultant Digital Tech Consulting, on the complexity of repacking: “DTC’s report remains the only analysis in the record of the time and resources needed to complete a nationwide repack of television stations, as safely and as quickly as possible.” Among problems with the CCA study is that it asserts DTC overestimates how many stations will have to move, he said. “This is curious,” because DTC’s estimate of 860 to 1,164 stations largely overlaps with CCA’s estimate of 756 to 888 stations, Franca said. “At a minimum, then, CCA’s study confirms that the lower end of the DTC estimate is a reasonable projection.”

CCA said the DTC study doesn't account for “sources of efficiency found in the field,” such as the deployment of broadband antennas that can operate on a broad range of channels in the UHF band, Franca said. “Unfortunately, CCA did not consult an economics professor with any broadcast engineering experience,” he said. “Had it found one (or simply hired a broadcast engineer), it would have learned that broadband antennas cannot realistically be used for broadcast TV station repacking in most cases.” CCA also said DTC significantly understates the number of qualified tower crews available for repacking work, he said. CCA claims that 41 qualified tower crews are available now, Franca said. “That’s interesting, because the FCC’s own Widelity Report concludes that no more than 14 qualified tower crews are available to work on complex and tall towers, and that ‘there is likely to be more work than these crews can handle in a timely fashion.’”

CCA also argues that the repacking task is “modest relative to the DTV transition,” Franca said. “No one who has seriously studied this issue -- or was even around during the DTV transition -- could possibly come to that conclusion.”

CCA fired back. “CCA’s study makes clear that the post-auction repacking process can be competed in the FCC’s 39-month timeframe, whether repacking 700 stations or 1000+ stations," CCA President Steve Berry said in an emailed response. That time frame "was selected after NAB’s extensive discussions with Congress about the time needed. In the Spectrum Act, Congress requires the FCC to reimburse broadcaster relocation costs within 36-months. Finally, NAB has already litigated this issue at the DC Circuit and lost." Berry agreed repacking may be complex: "But with careful planning and coordination, as outlined in our study by one of the world’s foremost auction experts, and in a soon-to-be-released engineering study, it can be done in a timely fashion. And just like every FCC Commissioner noted at a recent oversight hearing in front of Congress, stations will not go dark."

The difference of opinion between carriers and broadcasters on the FCC deadline was a big issue in October at CCA’s annual conference (see 1510080026).