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VACANT CHANNEL UPDATE RANT
Sub Silencio
Latin for "beneath the silence"
Adverb - legal - "in a clearly implied but not overtly stated way"
"... this proceeding, sub silencio, abandons the Commission's longstanding spectrum allocations policies relative to the priorities of unlicensed Part 15 devices versus licensed stations operating in allocated frequency bands."
"...to the extent that there is a prioritization of any Part 15 WSD over a licensed broadcast or broadcast auxiliary station in spectrum allocated to broadcast and broadcast auxiliary services, the Commission's proposal is flatly untenable."
"...the Commission should take no comfort that this Notice proposal provides any substantive accommodation for displaced Part 74 licensed WMs in the UHF television broadcast band going forward in any market. It does not."
"...for the reasons set forth hereinbelow, therefore, SBE urges that the Commission not proceed with the instant proposal for making available a single television UHF channel for combined WM and WSD operation at the potential expense of disaccommodating a displaced television broadcast station, LPTV station or TV translator."
The Society of Broadcast Engineers (SBE) is the only organization devoted to the advancement of all levels and types of broadcast engineering. I has more than 5,100 members and 114 local chapters.
COALITION COMMENTARY
As we went back through these Proceedings, we were struck by the direct language which SBE used to describe, from their professional opinions, just what a crock 15-146 is.
Let's look further at what many rural groups have to say about this Proceeding...
"In May of 2013, many of the groups represented on this letter wrote to urge the Commission to study seriously the impact of its decisions on television translator service. At that time we also asked for public hearings on the impact of the Commission's incentive auction policy choices on rural America."
"We were concerned then - and remain concerned today - that the Commission is continuing to undertake measures that will cause permanent damage to a service that offers real, irreplaceable value to viewers in rural areas and on native lands."
"What we find uniquely puzzling about this proposal is that it contemplates considerable additional translator loss in exchange for highly speculative benefits from unlicensed devices - benefits that have not yet materialized and may never materialize."
"We find it extraordinary that the Commission would consider displacing television translators serving rural communities based on nothing more than a gamble that unlicensed spectrum will - someday - provide some benefit to our communities."
"We urge you to study this issue carefully, and not to take action that will deprive rural viewers of service we rely on today."
- American Agri-Women
- American Farm Bureau
- Federation Intertribal Agriculture Council
- National Association of Farm Broadcasting
- National Association of State Departments of Agriculture
- National Black Growers Council
- National Farmers Union
- Rural & Agriculture Council of America
- U.S. Cattlemen's Association
- Women Involved in Farm Economics
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