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BREAKING NEWS...
FCC 3RD LPTV R&O TO BE PUBLISHED NEXT MONDAY 2/1/16



WHAT THIS MATTERS?
The key reason this matters is that the 30-day clock to file directly into the Court of Appeals starts.  At this point in the process who wants to wait through the lengthy and rigged Petitions for Reconsideration process?  Nope, the clock is starting to get some MAJOR fixes to our post-auction realities.

HISTORY RANT


WHY WERE LPTV AND TRANSLATORS KEPT OUT OF THE AUCTION?

OUTSPENT, OUTNUMBERED, AND OUTMANEUVERED, THE THREE KEY ADVOCACY AND LOBBYING EFFORTS HAD DIFFERENT GOALS, OBJECTIVES, AND BUDGETS - AND NOT MUCH TIME TO GET IT DONE

But despite the odds, two of the lobbying efforts scored the two key points about LPTV and translators in the spectrum incentive auction bill in early 2013, almost exactly 4 years ago from today. For those of you not following too closely, what these efforts won was the infamous language to not alter LPTV and translator rules, and the option for auction-eligible stations which do not take relocation funds to apply for flexible use authority (which did not include LPTV). The third group tried to get a $1.50/coverage pop buy-out for licensees, but that got stopped by Speaker Boehner at the last minute. So all of the advocacy and lobbying to get LPTV in the auction, and to open a new Class A window, and to get flex-use for all LPTV, well those did not carry the day.  But the 400+ Class-A's were in the auction, so many felt they got the best deals possible, considering the way the sausage was made in the middle of the night.

So the Incentive Auction legislation passed, and now 1430+ days (4 years) later we are still in the dark about the potential negatives effects of PEA's, ISIX, TVStudy, and regional repacking.  And the future is no better with the unknown timing, possibilities, and costs of ATSC 3.0.  

But the real reason over 7800 LPTV and TV translator licenses and construction permits were not included is that a legal theory emerged out the Senate committee staff, which soon took hold in the House committee staff, and just like an airborne virus spreads spread into a legal mumbo-jumbo epidemic.  From the mountains of Aspen, to the corridors of K Street, the mantra went out - "they (us) are secondary to everyone and everything!"

Little did they know, since not a one of them did the legal research, that the LPTV and TV translator "right of displacement", would block the plan to take our spectrum after the auction.  We will have the right to go find new channels, and the privilege of paying to do it.

Some interesting numbers:
  • about 2100 full power primary stations = 12,600 MHz of spectrum
  • these primaries have about 4 billion coverage pops, or 24 billion MHz-pops for you mobile folks
  • about 420 Class A's = 2,520 MHz of spectrum
  • these Class A's have about 500 million coverage pops, or 3 billion MHz pops
  • about 7800 LPTV and TV translator licenses and new permits, with 100's of 2009 filing window applications still being processed
  • these 7800 licenses and permits = 46,800 MHz of spectrum
  • which have about 1.6 billion coverage pops, or 9.6 billion MHz pops
So, about 10,300 broadcast television licenses and permits.  And with an estimate of about 400 or so stations sold in the auction, we are left with about 9,900 licenses and permits.  

Let's look at auction data we had analyzed for us while helping to craft LPTV auction or buyout legislation (thanks to our members for paying for this study which was done by District Economics).



and we then made some assumptions based on the 2015 AWS-3 auction and ran the numbers for LPTV and translator spectrum:



So you can see above that the 1.6 billion LPTV and translator coverage-pops, airing from 7800 stations (once all built out), in 2264 cities of licenses, in 210 TV DMA markets, which we now have to say 416 PEA's.  Well these 7800 licenses and permits are worth a collective $13 billion based on AWS-3 final prices, or $56 billion based on the incentive auction Greenhill 2 opening bid pricing.  Heck, the Class-A's only have $5 billion in opening bids. What is left, us, well we are worth 10X the Class-A's, and we have 3X the coverage and MHz pops.

To make it simple, take your coverage pops, and multiple times $15.18. That is your AWS-3 comp.  Understand that we mapped the AWS-3 prices against the 2264 cities of license to include the variations, which are extreme between NYC and Glendive.  So your number will also vary.  But on a national blended basis, $13 billion is a lot, and the AWS-3 numbers are a good comp, that is, until the incentive auction happens and a true apples to apples comp can be made.

Hang in there folks, your 6-MHz has value!  Then again, if you want to sell, well that going price per pop has been between $0.01 to $1.00 per pop.  The price all depends on whether or not you have read the Art of the Deal, or if need to get out now, or maybe have a 5-year investment horizon. 
  HOLLYWOOD AGREES WITH LPTV AND BEGINS COUNTER ATTACKING THE GOO!



CONTACT DAN VILES


ON-AIR SPOT FOR STATIONS TO USE TO ALERT THE PUBLIC TO THE DISPLACEMENTS WHICH COULD HAPPEN TO YOUR LPTV AND TV TRANSLATOR STATION BECAUSE OF THE AUCTION



SAN DIEGO BORDER ZONE MAJOR MARKET LPTV STATION FACED WITH YET ANOTHER DISPLACEMENT AND REQUESTS THAT THE FCC COORDINATE WITH MEXICO RATHER THAN FORCE LICENSEES TO DO IT THEMSELVES

from the filing by KSDY-LD



THIS IS THE KIND OF BIG DATA OUR COALITION HAS INVESTED INTO IN ORDER TO SEE THE IMPACTS TO OUR INDUSTRY.  THE FCC AIN'T DOING IT, AND THE FEES WE PAY THEM, WHILE MUCH LOWER THAN THE PRIMARY FULL POWERS, WELL YOU GET WHAT YOU PAY FOR.  BUT HECK, THEY REALLY HAVEN'T GIVEN US OUR MONEY'S WORTH.  BUT WE DO THANK THE VIDEO DIVISION FOR THE MAPS BELOW.


THESE MAPS WERE GREAT TO GET FROM THE VIDEO DIVISION, AND IT HELPS TO SEE THE SEPARATION OF LPTV AND TRANSLATORS TO SEE THE DISTRIBUTION OF EACH.  BUT OUR BIG MAP PROJECT SAID, LET'S DO THEM ALL!  CD-CA-LD-LP-TX-AND MOST IMPORTANT, THE CP'S.


IT WOULD BE NICE IF THE VIDEO DIVISION DID OUR INDUSTRY A SOLID, AND CREATED AN LPTV AND TRANSLATOR, LICENSES AND PERMITS, OVERLAY ONTO THE 416 PEA'S.  


When the reality of being left out of the auction, and being forced to move and have to pay for it, while everyone else gets paid to move, well if you can get passed that...here is the future!



Communications Law Attorneys representing clients before the FCC, the federal courts, and other regulatory, and governmental agencies on communications matters.

Chip Grange & Wray Fitch
(703) 873-7349 - www.gg-law.com

 


FREE & PAID LISTINGS FOR:
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  • ENGINEERS
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LPTV AFFILIATES WANTED NATIONWIDE
CLEARED IN SF, LA, CHICAGO, HOUSTON, DALLAS, FRESNO...



IF YOU ARE GOING TO THE APRIL NAB SHOW IN LAS VEGAS 
PLAN TO STOP BY AND SHOW YOUR SUPPORT 
FOR LPTV AND TV TRANSLATORS!  

SPONSORED FOOD AND BAR, AND LOTS OF DOOR PRIZES.  

LAST YEAR WE HAD OVER 300 PEOPLE ATTEND, AND 
MORE THAN 20 SPONSORS FROM EQUIPMENT VENDORS, 
PRODUCT AND SERVICE PROVIDERS, PROGRAMMING 
NETWORKS, AND LICENSEES.


IT'S LIMBO TIME
"Low power is an important voice 
in the community, and translators as well."

"I think there are multiple things we can do for them within the statutory framework...we will help them find new channels after the moving of channels...we don't don't know which low powers are going to be affected because we don't know what is going to happen in the auction...we don't know what going to be available to move, we we don't know about the auction.  We kind of have to stay in limbo and watch for that."

FCC CHAIRMAN WHEELER
HOUSE SUBCOMMITTEE TESTIMONY - JULY 2015


HOUSE SUBCOMMITTEE CHAIRMAN WALDEN (R-OR) 
ADDRESSING LPTV LICENSEES  IN  HIS HOME DISTRICT



COALITION COMMENTARY
Ok folks, the above two reports from last summer are your weekend reading this winter.  Really, go back through these and you will see what we are faced with.  An then, just like in all of those political ads in the early states, get open you wallet, checkbook, and credit card because the 30-day window starts next week to go to court over the LPTV and translator repacking rules.






AND WE WELCOME NEW MEMBERS:

KGEC-LD
Millie Cooper
Cooper Communications LLC 
Redding, CA 

KTRV Boise ID - 
WDRB Louisville, KY - 
WMYO Salem, IN
WBKI Campbellville, KY - 
WAND Decatur, IL - 
W31BX-D Danville, IL
W46ER-D Effingham, IL - 
W40CV-D Jacksonville, IL 
WLIO Lima, OH - 
WOHL-CD Lima, OH - 
WFND-LD Findlay, OH
WLMO-LP Lima, OH -  WLQP-LP Lima, OH
Frederick Vobbe
West Central Ohio Broadcasting Company

THANKS FOR YOUR SUPPORT!

If you would like to be part of our collective effort to make sure LPTV and TV translators are treated fairly in the Incentive Auction and channel repacking JOIN US today!


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