NAB, T-Mobile Offer Different Takes on Incentive Auction Reporting Forms
The FCC must get the questions it asks right as it establishes reporting requirements for “repacked” broadcasters on their progress moving to new channels following the close of the TV incentive auction, NAB said in comments posted Thursday. T-Mobile, which made no secret of its interest in the 600 MHz spectrum being sold, encouraged the FCC to get as much information as possible. Earlier this month, the Incentive Auction Task Force sought comment (see 1701100057) on whether to require progress reports of repacked stations that don't receive repacking reimbursement funds. Comments were due Wednesday in docket 16-306, said a public notice.
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“The proposed reporting form the Media Bureau and Incentive Auction Task Force have released sets forth 14 questions, some with subparts, and requests a yes or no answer to each question,” NAB commented. “While NAB generally believes the questions are substantively appropriate, many questions simply are not amenable to yes or no responses. Throughout the repacking process, broadcasters will face numerous uncertainties, and forcing a yes or no response in these circumstances will materially lessen the accuracy of the information the Commission collects and makes available to stakeholders.”
The association cited proposed question 8, which asks if a station’s post-auction facility will require tower construction or modification. “Many broadcasters will be wholly unable to provide any meaningful response to this question until tower studies have been completed,” NAB said. Other questions ask whether a station will require Federal Aviation Administration approval or permits or environmental impact reviews, NAB said. “Until tower studies have been completed and a station understands the scope of tower construction or modification work that may be required, a station may have no way of knowing whether FAA approval, permits or reviews will be required,” the group said. “A station may not be able to state whether structural tower studies are required (question 4) until it receives engineering analysis of the station’s new channel and determines whether it needs a new antenna and, if so, the size and weight of that antenna.”
T-Mobile expressed its concerns about having as complete a view as possible as repacking unfolds. The FCC should “require additional information for a more complete and accurate understanding of construction milestone achievements, and to identify trouble spots during the Transition,” and nonreimbursable stations should be required to submit progress reports, the “uncarrier” commented. “A reporting structure that balances the needs to provide accurate and timely information to the public with a reasonable and focused paperwork obligation would facilitate a timely Transition.”
Information is critical to completing the transition in the 39 months provided by the FCC, the carrier said. “As T-Mobile and other commenters have indicated in this proceeding previously, there is a need for robust project management, transparency of status, and ongoing reporting from broadcasters to ensure there is an iterative process with the continuous feedback loops necessary to evaluate -- and adjust or correct as needed -- the Transition schedule in real time.” T-Mobile has extensive history in repacking and spent years working with government agencies to clear the AWS-1 band after it was the dominant bidder in that 2006 auction.
Donald Everist, an engineer at Cohen, Dippell, was the only individual commenter. Everist mostly raised technical issues in his filing. “While this firm understands the need for additional information through periodic updates, this proposed requirement seems to be in part duplicate of the required response in FCC Form 2100, Schedule 399,” he said.