1303 Days Since The Incentive Auction legislation was passed 
191 Days Until The FCC Says Auction Starts
PAPAL INSPIRED RANT 

WE FORGIVE 
THE FCC & CONGRESS

With Pope Francis visiting DC this week, and in the spirit of the intent of his visit, we here at the Coalition forgive the FCC and Congress for the following:
  • We forgive Congress for not including more than 7500 LPTV and TV translators in the upcoming 2016 Incentive Auction.  While they acted rashing and with bad data when they made their decision, more than 1300 days ago, we now know that key members of Congress understand the mistake, and will now attempt to help LPTV/TX as best they can.
  • We forgive the FCC for giving bad data to Congress during the writing of the Incentive Auction legislation, about LPTV and TV translator secondary spectrum usage rights.  While they knew better about our rights, the FCC now acknowledges that they need to do whatever they can to help us.
  • We forgive the FCC Chairman for not meeting with our industry until over 18 months in office, and then only with all other broadcasting groups.  His prejudice against our licensed service may have clouded his judgement, but we now think he understands his wrong, and will serve, as his office demands, to honor the FCC licenses and permits we have been issued, and for our valuable and unique services be accommodated.
  • We forgive FCC Commissioner Rosenworcel for her attempt to change the LPTV and TV translator "secondary status", from one of being secondary only to licensed primary broadcasters, to one of being secondary to all others, licensed and unlicensed.  She knew what she was doing while Senate Committee counsel and as Commissioner when she promoted "the Rosenworcel Doctrine".  But we trust she will see the error of her opinions, especially when she understands that by promoting unlicensed over licensed in the Vacant Channel notice, it will be legally challenged, and could result in a 6 to 9 month delay in the auction.  
  • We forgive the Media Bureau for not allowing discovery about LPTV contracts with any of the recent MVPD mega-merger deals.  They say they do not have the authority from Congress to do this under the Incentive Auction legislation, although how to make sure the networks LPTV carries is of concern.  The FCC also says that it is not relevant to know how many LPTV are carried or not in a merger review - really?  We trust they will see the errors of their position on this.
  • We forgive the Video Division for their long war of attrition with LPTV.  While they did not come to our defense when the Incentive Auction legislation was passed, and accurately described our secondary rights, we forgive them.  While they have gone on a totally biased campaign to deny Class-A auction eligible status to more than 75 licensees, and downgraded them to LD status after they could or would not pay a large fine, we forgive them, but are curious why primary broadcasters are not threatened with a similar service demotion?  And we also forgive the Video Division for not accurately conducting recent ownership reports by failing to study translator ownership at all, nor knowing about the 2400 licenses and permits held by more than 200 local government entities.  But we trust the Video Division will find true compassion in their hearts to do whatever they need to do to give LPTV and TV translators favorable rules in the repack and displacement process.
  • While we are in a forgiving mood, we also forgive the Googleplex and their minions in the public interest organizations they sponsor. While they have cloaked their own corporate interests in the rhetoric of what is in the public interest and innovative public policy, they do not honor the incumbent licensees in any way, and are choosing to use internet-age disruption to squish multi-cultural independent small businesses.  We trust they will do better to live up to their corporate motto of "do no evil".  
  • And we forgive the NAB for not supporting having LPTV eligible for the Incentive Auction in the first place, nor giving us a way to have a vote in NAB, nor in the past not embracing LPTV as broadcasters.  NAB has come a long way since then and we believe they now see LPTV as integral to their own fate, so we are thankful for that.

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AND BACK TO BUSINESS

...and, we will not be taking the FCC to court over the Incentive Auction rulemaking, just yet. But we will challenge the attempt to use the vacant channel order to put unlicensed over licensed.  We believe that the FCC will soon understand a problem they have.  The Incentive Auction legislation, according to the FCC, says that the FCC has the discretion to repurpose the band, and to provide spectrum for unlicensed use.  However, the legislation also directs the FCC to not change the spectrum usage rights of LPTV and TV translators.  So, the FCC is attempting to use its' discretion for the first part, but is then in conflict with the second part.  We believe the FCC is obligated to go back to Congress to have this clarified, or drop the vacant channel order.

Check out from last month our special on this issue:



BREAKING TODAY...


BREAKING TODAY...
  BREAKING THIS WEEK...
TECHNICAL NEWS


Fig. 1: Derived from Fig. 23, page 453 of FCC document 14-50 dated May 15, 2014 by Stanley Knight


Did you know... that there are as many as 7500+ LPTV and TV translator built/licensed facilities, as well as new construction permits located in as many as 2247 cities of license within the 210 TV DMA? That is about 45,000 MHz of spectrum!

   

BUT NOW LOOK WHEN YOU ADD IN THE NEW CONSTRUCTION PERMITS




AND THEN LOOK AT THE DISTRIBUTION
OF THE BUILT AND LICENSED FACILITIES


LPTV & TV TRANSLATOR POST AUCTION
CHANNEL REPACKING STUDIES 

We are pleased to announce that we have cleared our backlog of studies and have now begun to automate the process so that we can study your station and market quickly and get you a much clearer picture as to what will happen with your station, license, or new construction permit.  What is the probability you will be displaced? WIll there be enough channels in your market?  Will you be forced into the VHF? What will be the timing of your move?  It is the best $250 you will spend on your LPTV investment this year.  Includes a printed report, simulations, and a phone consultation.  Support the Coalition and find out the latest thinking and impacts from the FCC rulemaking.




READ THE ARTICLE
Did you know... that the 7500+ LPTV and TV translator built/licensed facilities, have a collective 1.6 Billion coverage-pops?  And that the 2117 or so eligible Incentive Auction primary and Class-A stations have a collective 4.5 Billion coverage-pops?


READ THE ARTICLE

READ THIS EDITION






Mike Gravino,  Director
LPTV Spectrum Rights Coalition
202-604-0747