LPTV NEWS NEWS
WED. - FEB. 11, 2015 - EARLY AM EDITION



The 144-MHz Clearing Is Real!

Greenhill 2.0 confirms LPTV's worse-case scenario, that the FCC is planning for a total displacement "taking" of all legislatively unprotected spectrum, from UHF TV channels 51-27, in each and every TV DMA it can.  And in most DMA, with few exceptions, there is a greater than 50% chance it can.  

With the "switch & bait" opening bid prices of Greenhill 2.0, (see NAB ex parte filing) the FCC has begun its' "final solution" for the elimination of "secondary to everyone else" LPTV.



Can and will Congress do anything?  No, not at this time.  
Remember, it is because of the 112th Congress, back in 2012, that the FCC has the discretionary power to clear the full 144-MHz.  And 114th Congress just got notified that it will be getting the first phase of First Net paid for, in addition to a $20 billion payment towards deficient reduction.  So they are loath to do anything at all to upset the Incentive Auction, especially when it could generate two to three times more towards the deficient.  And the LPTV GAO study, which the 113th Congress asked for, well it has not even been started yet.

Readers of this newsletter will remember that in December we predicted that with the 84-MHz clearing (51-38), the 2,650+ LPTV and TV translator licensed stations and new digital construction permits currently with channel assignments there, had enough spectrum to displace into from 36 and below. But that was before the AWS auction ended last month at such high levels. 

So now, with direct empirical evidence produced by the FCC's own TV Study software, and using over 5000 DMA simulations the FCC itself generated, we can safely say..."we are toast".  (Hidden within this analysis, is the seed corn for an entirely new LPTV service, and one embodied with hope for the future.  More on this in a later edition - WE GOT YOUR BACK LPTV!).

The intention of the FCC is to "start" with the 144-MHz clearing, and see how far they can go in each DMA to clear "impaired" and "unimpaired" spectrum blocks.  The AWS auction showed the FCC that they can sell both, extract value from both, and so the 144-MHz clearing is now the goal.  This is in contrast to the exact language they have been using, such as, "51 and down".  It is really "27 and up"!


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HOW MUCH IS LPTV SPECTRUM WORTH NOW, AND THEN WHEN THE INCENTIVE AUCTION IS OVER?


The bright folks over at TV Technology take out their slide rulers and fire up the adding machine, and make a back of the napkin analysis about just how much the Greenhill 2.0 Opening Bids will total, and the number is BIG.  The Coalition is doing the same type of analysis for what we think LPTV spectrum is and will be worth.  TV Technology Totals

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WIRELESS MICROPHONE COMMUNITY MAY BE USED FOR ILLEGAL SPECTRUM GRAB BY UNLICENSED SPECTRUM ADVOCATES



Last week, the FCC put on circulation to the Commissioners, "Amendment of Parts 15, 73 and 74 of the Commission's Rules to Provide for the Preservation of One Vacant Channel in the UHF Television Band For Use By Wireless Microphones and White Space Devices."  The Commissioners have had this item for almost a week now, so we expect a decision out soon.  Then again, this item totally is not what the Incentive Auction legislation mandated about LPTV, that none of its spectrum usage rights should be changed.  

The Coalition believes that our friends over in the wireless mic world will have plenty of unlicensed spectrum to use, as they do now.  And that to link them with the spectrum grab by the TV white space advocates, is not warranted. While there are sometimes not enough bandwidth for large scale venues, it does not mean that entire channels of essential spectrum for "licensed" LPTV users will not be available.  Heck, why don't they just lease it from us!


 
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GOOGLE WANTS FOR FREE 12-MHz OF LPTV SPECTRUM IN EACH TV DMA (MORE THAN 2500 MHz NATIONWIDE!)  

REQUEST ALSO INCLUDES THE USE OF "PERSONAL/PORTABLE" 
DEVICES IN CHANNELS 7-20!  

Now look folks, I would wager that our Coalition has had more face to face, telephone, and email conversations with Google than any other broadcast TV advocacy group.  Together we are actively exploring how both LPTV and unlicensed users can peacefully co-exist in the post-Incentive Auction operating environment called "spectrum neighborhoods".  And we really think they are on to some excellent new uses and proposed "rules of the road" for "dynamic spectrum sharing".  But remember, LPTV is a "LICENSED" service, and we got rights!

So with this all in mind, we urge all LPTV licensees, the consulting engineers who enable them, and the lawyers which protect them, to read Google's latest filing into the Part 15 NPRM, the Amendment of Part 74 rules, and the Incentive Auction rules.



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FCC LPTV WEBINAR
TUE. FEB. 17TH
10:30 AM EASTERN

 TO DISCUSS ISSUES RELEVANT TO LOW POWER TELEVISION AND TELEVISION TRANSLATOR STATIONS IN CONNECTION WITH THE TELEVISION SPECTRUM INCENTIVE AUCTION

Well folks, LPTV will finally get an information session of its own about the Incentive Auction and repacking...but it will be a one-way, no audience, no LPTV participants, and questions totally selected by the FCC to answer.  This is not really what we all had asked for, an airing of our concerns, our potential problems, issues raised and answered by our own experts...no this is a audio call with slides.  But a BIG thanks for it anyway, it will help.

The FCC will tell the call participants about the issues raised both in the Incentive Auction Report and Order passed last year, and the just recently completed 3rd LPTV NPRM.  

The Coalition is submitting questions we want answered ahead of time..although we fear that only a few will actually be asked and answered, and again, they are all pre-selected by the FCC.  In other webinars, participants have had the chance to submit live questions during the event, and we expect that this will also be allowed this time.  

Use the Coalition "special page" for submitting your very own questions, and also have access to all of the information and related filings.



Even if you do not want to submit any questions, you just got to check out this page!


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Special presentation by Dielectric made at the Association of Federal Communications Consulting Engineers January meeting (thanks Mike et al). Check it out, very useful information.  Note, the auction timeline presented has now been changed.  


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Check out this story about our PBS/CPB/APTS friends and what they are now doing to prepare and plan for the impacts from the Incentive Auction.  Our Coalition is committed to working with them to find a solution to the areas in the country they might lose coverage, and also the funding of their translator relocations (and all LPTV and TV translator relocation funding).

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Broadcasting & Cable have again come out with an in depth story about what is happening with Diginets.  Check it out before they put it behind some paywall.  Lots of great reference material in it.  


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HELP US HELP YOU!
If you have not yet participated in the Coalition LPTV Legal Defense Campaign then it is your turn!  We need to keep filing comments, reply comments, and prepare for battle in the courts to protect YOUR spectrum usage rights.


WE GOT YOUR BACK LPTV!

Mike Gravino
Director
LPTV Spectrum Rights Coalition
(202) 604-0747
lptvcoalition@gmail.com