Challenges in Implementing Television Repacking

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Joseph M. Davis, P.E. Chesapeake RF Consultants, LLC Radiofrequency Consulting Engineers Digital Television and Radio Challenges in Implementing Television Repacking for Society of Broadcast Engineers Chapter 78 Blue Ridge, VA January 8, 2015 01/08/2015 Joseph M. Davis, P.E. 1

Today s Topics: A little DTV history What is Frozen UHF Band Plan and Auction Info DTV Repacking: New Channel and OET Bulletin 69 Timelines and Milestones Planning, Construction, and Bottlenecks Reimbursement Procedures Impact to LPTV & translators 01/08/2015 Joseph M. Davis, P.E. 3

Brief Analog & Digital TV History 1941 Black & white television broadcasting begins in the U.S. U.S. National Television Systems Committee (NTSC) formed. 1950 s B&W television widely introduced throughout the world 1953 NTSC color television standard adopted in the U.S. 1954 Color television broadcasts commence in the U.S. 1970 s Color television in world wide use 1980 s Channels 70-83 to cellular and public safety Lobbying Battle begins between U.S. broadcasters and the mobile communications industry for more unused TV channels 1993 Grand Alliance formed for High Definition TV 1997 DTV approved by FCC Stations to borrow second channel Ch. 52-69 (700 MHz band) repurposed to carriers and Public Safety 01/08/2015 Joseph M. Davis, P.E. 4

Brief Analog & Digital TV History Mar 1998 First DTV station goes on-air (27 total in 1998) DTV Construction Deadlines May 1999 Top 10 Markets, 4 network affiliates Nov 1999 Markets 11-30, 4 network affiliates May 2002 All Commercial Stations May 2003 All Noncommercial Stations Many stations initially built reduced facilities and maximized later July 2005 July 2006 Use it or Lose it deadline Commercial stations Use it or Lose it deadline Noncommercial stations 2005-2006 Channel Elections for Post-Transition Election conflict resolution 2009 Analog operations terminate DTV operations on final channel 01/08/2015 Joseph M. Davis, P.E. 5

Revisiting TV Spectrum Reallocation 2009 +/- Rumblings of a Repacking to move more spectrum from TV broadcasting to wireless carriers Roasting the Pig to Burn Down the House: A Modest Proposal Mar 2010 FCC Releases The National Broadband Plan Feb 2012 The Middle Class Tax Relief and Job Creation Act of 2012 a.k.a. Spectrum Act Oct 2012 FCC NPRM, Docket No. 12-268 Expanding the Economic and Innovation Opportunities of Spectrum Through Incentive Auctions June 2014 Oct 2014 FCC Incentive Auction 1 st Report & Order FCC Incentive Auction 2 nd Report & Order and FNPRM 2015 2016 Planned Incentive Auction 01/08/2015 Joseph M. Davis, P.E. 6

What is Frozen Jun 2010 May 2011 Aug 2011 Apr 2013 Jun 2014 Indefinitely postponed filing opportunity for new LPTV and translator stations for all markets No more channel substitution petitions accepted No expansion of Ch-51 DTV stations, no more LPTV/translators on Ch-51, pending apps for Ch-51 need alternate channel; OK to move DTV off of Ch-51 No expansion of any DTV or Class A station contour (limited exception for Class A digital conversion) No more applications for new Digital Replacement Translators. No more displacement applications for LPTV & translator stations unless there is new interference. 01/08/2015 Joseph M. Davis, P.E. 7

Post Auction Band Plan All Paired, Down from 51 5 MHz Blocks MHz Recovered 3 MHz Guard 7-11MHz Guard Band 11 MHz Duplex Gap Downlink Uplink Most markets - uniform band Constrained markets less spectrum recovered Possible issues with inter-service interference ( ISIX OET Bulletin 74) 01/08/2015 Joseph M. Davis, P.E. 8

FCC Report Statistics of Full Power and Class A Television Stations in the United States as of February 22, 2012 Report No. TAB 2013-01 July 16, 2013 01/08/2015 Joseph M. Davis, P.E. 9

Roanoke, VA TV Database Within Study Chesapeake RF Consultants, LLC TV Records within 75 km distance of 37 11' 46" N, 80 9' 17" W 1/6/2015 Ch. Status Call Svc Location File Number ERP HAAT Bear Dist Full Service DTV 3 LIC WBRA-TV DT ROANOKE, VA BLEDT-20131218CHV BLUE RIDGE PUBLIC TELEVIS 9.8 614 0.00 0.00 13 LIC WSET-TV DT LYNCHBURG, VA BLCDT-20091013ABE WSET INCORPORATED 28.7 625 73.81 47.96 17 LIC WFXR DT ROANOKE, VA BLCDT-20090609ABS GB ROANOKE LICENSING LL 695 594 42.59 0.05 17 CP WFXR DT ROANOKE, VA BPCDT-20120927ALB GB ROANOKE LICENSING LL 1000 614 42.59 0.05 18 LIC WDBJ DT ROANOKE, VA BLCDT-20090714AAW WDBJ TELEVISION, INC. 675 606 230.07 0.19 20 LIC WWCW DT LYNCHBURG, VA BLCDT-20090619ABM GB LYNCHBURG LICENSING 916 500 73.17 48.32 24 CP WTLU DT DANVILLE, VA BPCDT-20080317AIL M ORNING STAR BROADCAS 63 378 111.60 55.81 30 LIC WSLS-TV DT ROANOKE, VA BLCDT-20110615ABO M EDIA GENERAL COM M UNI 1000 592 47.14 0.77 36 LIC WPXR-TV DT ROANOKE, VA BLCDT-20020510AAB ION M EDIA LICENSE COM PA 700 623 215.30 0.34 Digital LPTV/Translator 4 LIC W04AG-D LD GARDEN CITY, ETC., VA BLDTV-20110119AAM WDBJ TELEVISION, INC. 0.006 0 72.85 20.55 5 LIC W05AA-D LD ROANOKE, VA BLDTV-20120430ACX WSET INCORPORATED 0.097 0 67.04 10.33 26 LIC WEDD-LD LD ROANOKE, VA BLDTL-20130807AAX JONES BROADCASTING, L.L 15 0 203.49 0.37 28 CP W28EM-D LD ROANOKE, VA BDCCDTT-20120710ABX REGAL M EDIA, INC. 15 0 67.04 10.33 40 CP WYAT-LP LD MARTINSVILLE, VA BDFCDTL-20121001AHE M ARTINSVILLE M EDIA, INC. 15 0 153.91 61.31 44 LIC W44CL-D LD ROANOKE, VA BLDTL-20110715AEF VENTANA TELEVISION, INC. 15 0 45.51 28.12 Analog LPTV/Translator 40 LIC WYAT-LP TX MARTINSVILLE, VA BLTTL-20060508AAA M ARTINSVILLE M EDIA, INC. 70 0 153.91 61.31 49 LIC W49AP TX ROANOKE, VA BLTTL-19890504IE REGAL M EDIA, INC. 36.2 0 67.04 10.33 01/08/2015 Joseph M. Davis, P.E. 10

Roanoke, VA TV Database Within Study Chesapeake RF Consultants, LLC TV Records within 125 km distance of 37 11' 46" N, 80 9' 17" W 1/6/2015 Ch. Status Call Svc Location File Number ERP HAAT Bear Dist Full Service DTV 3 LIC WBRA-TV DT ROANOKE, VA BLEDT-20131218CHV BLUE RIDGE PUBLIC TELEVIS 9.8 614 0.00 0.00 8 LIC WVNS-TV DT LEWISBURG, WV BLCDT-20050923AGX WEST VIRGINIA M EDIA HOLD 3.68 577 322.94 80.51 10 LIC WSWP-TV DT GRANDVIEW, WV BLEDT-20100210AAQ WEST VIRGINIA EDUCATIONA 24 318 316.87 107.12 13 LIC WSET-TV DT LYNCHBURG, VA BLCDT-20091013ABE WSET INCORPORATED 28.7 625 73.81 47.96 14 LIC WGPX-TV DT BURLINGTON, NC BLCDT-20060418ADO ION M EDIA GREENSBORO LI 95 213 156.97 114.23 17 LIC WFXR DT ROANOKE, VA BLCDT-20090609ABS GB ROANOKE LICENSING LL 695 594 42.59 0.05 17 CP WFXR DT ROANOKE, VA BPCDT-20120927ALB GB ROANOKE LICENSING LL 1000 614 42.59 0.05 18 LIC WDBJ DT ROANOKE, VA BLCDT-20090714AAW WDBJ TELEVISION, INC. 675 606 230.07 0.19 20 LIC WWCW DT LYNCHBURG, VA BLCDT-20090619ABM GB LYNCHBURG LICENSING 916 500 73.17 48.32 24 CP WTLU DT DANVILLE, VA BPCDT-20080317AIL M ORNING STAR BROADCAS 63 378 111.60 55.81 30 LIC WSLS-TV DT ROANOKE, VA BLCDT-20110615ABO M EDIA GENERAL COM M UNI 1000 592 47.14 0.77 31 LIC WXII-TV DT WINSTON-SALEM, NC BLCDT-20050627AAU WXII HEARST 815 572 192.14 93.17 32 LIC WUNL-TV DT WINSTON-SALEM, NC BLEDT-20091112ABR UNIVERSITY OF NORTH CAR 575 499 192.02 93.12 36 LIC WPXR-TV DT ROANOKE, VA BLCDT-20020510AAB ION M EDIA LICENSE COM PA 700 623 215.30 0.34 40 LIC WLFB DT BLUEFIELD, WV BLCDT-20120228ACM LIVING FAITH M INISTRIES, IN 1000 399 271.89 97.76 46 LIC WVVA DT BLUEFIELD, WV BLCDT-20060929AEJ WVVA TELEVISION, 1000 372 274.48 91.38 50 LIC WOAY-TV DT OAK HILL, WV BLCDT-20070426AAK THOM AS BROADCASTING C 600 200 314.26 121.98 Digital Class A 43 LIC WTLU-CD DC LYNCHBURG, VA BLDTL-20100111ACB M ORNING STAR BROADCAS 15 0 78.09 90.14 01/08/2015 Joseph M. Davis, P.E. 11

TV Incentive Auction Greenhill s FCC information package 10/01/2014 From SIEPR Incentive Auction Design Conference Feb 2013 01/08/2015 Joseph M. Davis, P.E. 12

Broadcaster Auction Options Auction participation is not mandatory. Participation is confidential. Bid options for participating stations: 1. License relinquishment 2. Change bands (U to Hi-V, U to Lo-V, Hi-V to Lo-V) 3. Share channel with another station Post-Auction: Repacking Non-participating stations may have to change to a new channel within the same band. Coverage areas and service population are protected. Participating stations whose bids are not accepted may have to change channel within the same band FCC to reimburse for reasonable expenses by involuntary channel changes No reimbursement for stations changing bands (they get auction proceeds) 01/08/2015 Joseph M. Davis, P.E. 13

Replication to New Channel New channel assignment based on licensed antenna location and height No change to directional pattern UHF Power changes with dipole factor Normalized to 615 MHz (Ch. 38) -2.31 db on Ch. 14 +1.03 db on Ch. 51 1000 kw on Ch. 50 = 546 kw on Ch. 20 1000 kw on Ch. 18 = 1256 kw on Ch. 28 (cap at 1000 kw) Coverage area and population served evaluated with OET Bulletin 69 New channel to provide same area and population served: May receive up to 0.5% new interference from another station Aggregate interference considering multiple other stations higher No hard aggregate limit, FCC will avoid more than 1% Same applicable to stations not changing 01/08/2015 Joseph M. Davis, P.E. 14

01/08/2015 Joseph M. Davis, P.E. 15

01/08/2015 Joseph M. Davis, P.E. 16

NAB & Sinclair Pending Lawsuit NAB s Issues TVStudy - new computer implementation of OET Bulletin 69 Preservation of Coverage Area and Population (terrain losses, unpopulated areas) Sinclair s Issues Not enough time to implement repacking Participation of at least TWO competing licensees 01/08/2015 Joseph M. Davis, P.E. 17

Timelines and Milestones Auction Comment Public Notice 3Q 2014 Adopted 12-11-2014 Initiates Pre-Auction process: to seek public input on auction design issues, opening prices, amount of market variation in band plan, initial clearing target, and the final television channel assignment process Repack - Proposed Channel Reassignment Optimization Priority Factors: 1. Maximize stays : number of TV stations to stay on current channel no expenses, disruptions, terrain loss issues 2. Minimize number of stations to receive total new interference over 1% 3. Avoid reassignment of stations with high buildout costs Auction Procedures Public Notice 1Q 2015 Resolves implementation issues from Comment PN; provide explanations and instructions; final procedures 01/08/2015 Joseph M. Davis, P.E. 18

Timelines and Milestones PN Announcing Pre-Auction Licensing Deadline 1Q 2015 90-day notice of date by which existing CP s, channel substitutions, Class A digital conversions completed by this date will be protected Final Catalog of Costs released 1H 2015 Outreach to broadcasters regarding reimbursement procedures, postauction transition to new channels, and consumer education OET Releases Updated Baseline Data 1H 2015 List of specific facilities to be preserved, technical parameters, and coverage areas/population served Before Auction Stations must review baseline data to certify accuracy of facility information or provide corrections. (survey) Form 2100 Schedule 381 01/08/2015 Joseph M. Davis, P.E. 19

Timelines and Milestones Incentive Auction Mid 2015 2016 Participating stations must submit application Conduct Mock auction, conduct Reverse and Forward Auctions Auction closes when Final Stage Rule is satisfied ASAP After Auction Concludes Forward auction licenses are granted, disbursement of auction proceeds are made to broadcasters that are relinquishing spectrum Relinquishing and channel sharing stations must vacate pre-auction channels within 3 months Channel Reassignment Public Notice Final TV channel assignments and parameters announced Post-Auction period begins t = 0 Ready Set GO! 01/08/2015 Joseph M. Davis, P.E. 20

Timelines and Milestones Deadline at t + 3 Months Repacked stations must file Construction Permit applications and estimated channel relocation costs Crunch time to plan new facility and transition After t + 3 Months, 36 month Broadcast Construction Period begins CP s are issued ASAP FCC establishes construction deadlines for new channel implementation Deadlines to vary by region, complexity, and other factors Some stations will have less than the full 36 month period FCC reviews cost estimates and issues initial allocation of funds 80 percent of estimated to commercial stations 90 percent of estimated to noncommercial stations 01/08/2015 Joseph M. Davis, P.E. 21

Timelines and Milestones Meeting Construction Deadline At t + 39 months, all operations on pre-auction channels must cease 6-month extension of construction deadline upon suitable request Subsequent extensions via much stricter criteria Must go dark if not ready at t + 39 12 months silent = automatic license expiration FCC can reinstate with waiver if involuntarily dark and if equity and fairness apply Interim operations will be necessary for many stations Existing or new auxiliary transmitter/antenna Temporary installation OK On pre-auction and/or post-auction channel Reduced facilities Alternate site OK Temporary channel OK 01/08/2015 Joseph M. Davis, P.E. 22

Facility Planning Limited opportunity for pre-planning until repack results are available By t = 3 months must apply for Construction Permit 01/08/2015 Joseph M. Davis, P.E. 23

Facility Planning 1. Pre-planning (t = 0) 2. RF Engineering 3. Structural Engineering 4. Negotiate with tower owners 5. Permitting 6. Estimated Costs to FCC for Reimbursement (negotiation?) ------ t = 3 months ------ 7. Acquire equipment/manufacturing 8. Tower Work 9. Field Engineering 01/08/2015 Joseph M. Davis, P.E. 24

Planning and Application Procedures Construction Permit Applications: Three filing deadlines depending on nature of proposal 1. Generally conforming applications Comply with new parameters, no contour expansion Interference study not required, serve > 95% reference population Expedited grant by FCC Slight contour extension up to 1 percent OK if needed to achieve the new assignment or to address a loss area on the new channel Interference is <0.5% to any other station Antenna pattern must closely conform to new assignment 1 percent contour extension limit not applicable to winning bidders going from UHF to VHF due to pattern matching issues 01/08/2015 Joseph M. Davis, P.E. 25

Planning and Application Procedures Last two filing deadlines follow FCC processing of first set of applications 2. Priority Expanded Facilities (Maximization) and Alternate Channels Applicable if new assignment can t be constructed for reasons beyond station s control. MB to describe qualifying categories. Contour extension over 1 percent Interference is <0.5% to any other station 3. Non-Priority Expanded Facilities and Alternate Channels Contour extension over 1 percent Interference is <0.5% to any other station After processing initial CP applications in 1, MB to issue PN s with deadlines for 2 and 3, processing guidelines, standards for priority filing, cut-off and MX resolution 01/08/2015 Joseph M. Davis, P.E. 26

Antennas Most stations use a single-channel antenna, must replace UHF slotted cylinder dominant Antenna length Shared broadband antennas also common, may work on new channel UHF Panels typically OK over only part of UHF band Hi-VHF Panels typically OK over Ch s 7-13 Combiner modifications necessary Last 10 years, addition of vertically polarized component has been common Stacked antennas prevalent during transition 01/08/2015 Joseph M. Davis, P.E. 27

Coaxial line usually rigid Transmission Line 20 ft, 19.75 ft, and 19.5 ft sections for single-channel antennas Fixed length sections may not be compatible on new channel Broadband systems have minor, non-repeating changes to section lengths engineering review needed to determine suitability on new channel Lower power stations may use flexible line, continuous run; OK on new channel Some waveguide installations exist, likely to require replacement for new channel 01/08/2015 Joseph M. Davis, P.E. 28

Towers Tower Structural Analysis EIA/TIA RS-222-G (2005) now in effect most jurisdictions Rev-F (1996) in effect during country's greatest build out of towers Availability of as-built documentation Limited number of structural engineers 01/08/2015 Joseph M. Davis, P.E. 29

Transmitters New channel - transmitter modification or replacement? Tube (IOT) or Solid State Banding issues Manufacturer support availability Parts availability for older technology 01/08/2015 Joseph M. Davis, P.E. 30

Reimbursement for Eligible Expenses $1.75 billion available Reimbursement to broadcasters involuntarily repacked Hard and Soft Costs are eligible Hard: Equipment replacement & installation Modification of existing equipment Tower work Soft: Legal fees Engineering fees (RF and structural consultants) Health care facility notification Can opt to forego reimbursement for a waiver of service rule ( Flex use ) Non-ATSC transmission Still must provide at least 1 free TV program stream Case-by-case review of waiver request 01/08/2015 Joseph M. Davis, P.E. 31

Reimbursement for Eligible Expenses Funds deposited in individual US Treasury account, available to draw as expenses are incurred Reimbursement goes to station involuntarily repacked Impact at shared sites TV stations not changing channel FM stations, other tower users Does contract specify obligations? After t = 3 months 80 percent of estimated to commercial stations 90 percent of estimated to noncommercial stations can vary depending on overall totals of all stations Update estimated costs as circumstances change & final costs known Upon completion or by a deadline TBD by FCC, file actual expense info and any remaining estimates. Excess goes back to FCC (details TBD). All payments must be made by t = 39 months (statutory 3 year) 01/08/2015 Joseph M. Davis, P.E. 32

Reimbursement for Eligible Expenses FCC to hire contractor to administer reimbursement process Waste & Fraud Progress reports required Keep receipts & documentation 10 years Audit, site visit, data validation by FCC or contractor During and following reimbursement period For transition concluding after t = 39 months, submit final expense docs Money recovered where actual < estimated can be disbursed to those stations where actual > estimated What if $1.75 billion not enough? MB to prioritize claims Can dispose of old equipment at will Re-use at another station or donate 01/08/2015 Joseph M. Davis, P.E. 33

Reimbursement for Eligible Expenses Reasonable costs determined case-by-case must take reasonable steps to mitigate costs and share expenses FCC Catalog of Costs to be released general guidance not guarantee Provide justification for estimates that exceed catalog Will not cover incremental costs for certain optional items Expansion beyond 1% for non-priority stations (OK for priority) Optional features beyond existing equipment s options New models may have improved functionality built-in - OK Will cover interim facilities (additional transmitter, antenna, alternate site, temporary channel, modification to existing backup, purchase or rental) No reimbursement for lost revenues or employee salary 01/08/2015 Joseph M. Davis, P.E. 34

Reimbursement for Eligible Expenses Catalog of Costs - Samples from Widelity Report Sample line items Transmitter, two IOT, retune existing New replacement $145,500 - $225,000 $815,000 - $855,000 UHF Top-mount slot antenna $150,000 - $225,000 Tower reinforcement minor $100,000 - $150,000 Tower rigging - antenna & line replacement for tall tower $100,000 - $200,000 01/08/2015 Joseph M. Davis, P.E. 35

Reimbursement for Eligible Expenses Sample Repacking --- Case study from Widelity Report 01/08/2015 Joseph M. Davis, P.E. 36

Vendor and Service Provider Capacity Depressed marketplace for equipment, industry has contracted Threat of repacking, FCC freezes, general economy Severe impact on high-power TV antenna manufacturers and tower crews capable of working on tall and complicated towers Antenna Manufacturers Principally: Dielectric, ERI both anxious and ready to ramp up Others: Jampro, SWR, RFS, Kathrein Tower crews: No more than 14, current estimate is 5 to 10, for complex sites 30-40 regional crews Transmission Line & Mask Filters: several suppliers, should be OK but need lead time. Copper source is overseas 01/08/2015 Joseph M. Davis, P.E. 37

Vendor and Service Provider Capacity Transmitter Manufacturers, high power GatesAir (Harris) Rohde & Schwarz Comark Service & support only Acrodyne Axcera Larcan (via Maple Leaf RF Systems & Service LLC) 01/08/2015 Joseph M. Davis, P.E. 38

Vendor and Service Provider Capacity Engineering Resources Limited Capacity Structural Engineers All firms at peak can do total of 40 structural analyses per month Field Engineering Transmitter installation & modification through 2009 est. >100 now, est. 30 more available to do RF sweeps of antenna/line RF Consulting Engineers Some TV groups handle internally, most stations will need help est. 35, half of which positioned to handle more than 5-10 stations 01/08/2015 Joseph M. Davis, P.E. 39

Impact to LPTV, Television Translator, DRT Not protected through repack Many expected to be displaced by spectrum reallocation or repacked station No reimbursement for channel change FCC Mitigation Special filing window for displaced operating facilities opens after t = 3 months and DTV expansion/alternate channel filing MX apps settlement window, DRT priority, then auction Facilities in 600 MHz band may continue to operate until notified by new licensee (120 day notice); if on guard band must cease at t = 39 months 01/08/2015 Joseph M. Davis, P.E. 40

Impact to LPTV, Television Translator, DRT Additional FCC Mitigation October 10, 2014: Public Notice 2 nd Report & Order and FNPRM 1. Public Notice - Avoid double build issues, extension requests Suspends 09/01/2015 conversion deadline and expiration dates 2. FNPRM with proposals: Allow additional DRT opportunity to recover losses at repack Consider channel sharing Use FCC repack software to determine displacement channels for LPTV Consider permanent Franken-FM radio service on Channel 6 01/08/2015 Joseph M. Davis, P.E. 41

Additional Impact LPTV and translator station modifications and buildout will exacerbate challenges and shortages, as will Winning full power bidders for band changes Site consolidation / expansion opportunity for others All will draw from the same manufacturer and service provider resources that repacked stations will require 01/08/2015 Joseph M. Davis, P.E. 42

Collateral Damage MVPD s receiving OTA signals must be ready Advance notice required from TV stations of changes 30 days ceasing operation 30 days sharing channel 90 days changing channel coordination required for cutover MVPD s reasonable expenses are reimbursed without regard to must-carry or retransmission consent reimbursement is via station for must-carry signal delivery to headend Other users of UHF TV Spectrum Wireless Microphones Whitespace Devices BAS Part 74 microwave operations in TV band 01/08/2015 Joseph M. Davis, P.E. 43

Comments, Questions? Must be Miller Time Thank You! Chesapeake RF Consultants, LLC Radiofrequency Consulting Engineers Digital Television and Radio RF Sniffer 01/08/2015 Joseph M. Davis, P.E. 54