A Year  From  Now...

Will you have succeeded in generating significant wealth from selling your spectrum in the incentive auction?  
Have you entered into a potential revenue generating channel share of your spectrum?  Or are you paying to be in one?
Or have you been displaced, and have to pay for your own move, but get to stay on-channel for 39 months?  
Or will you have to move within a year or two since a repacked primary or Class A displaced you?
Or will need to go beyond your contour for 30 or so miles to find a new suitable site to transmit from with acceptable interference?
What happens if you can't find an allowable channel within your extended contour, then what?
Will the FCC's potential plan to open LPTV and TV translator channel sharing so that you could go share 6 MHz anywhere in any market, would this interest or help you?  
And what about those of us displaced by that naturally occurring vacant channel? In many DMA, multiple LPTV and TV translators already share a channel, but they each now have 6 MHz of their own, and are far enough apart to make it work in a geographically large market.
Does anyone care about the more than 200 local government agencies, with as many as 2400 operating LPTV and TV translators?  They also have to pay for their own displacements and relicensing.  Does this sound like an unfunded government mandate to you?
The consulting engineers in the field will be busy, in demand, and growing their businesses. But are they up to providing the potential new set of interference studies to LPTV and TV translators so these licensed services do not interfere with unlicensed bands?  What is this new additional aggregate displacement cost to the industry? 
Why is the country forgoing over $18 billion in auction revenues so that a giveaway can happen of unlicensed spectrum to the wealthiest companies?  Why does Google and Microsoft need $18 billion of free spectrum, when they can not prove to CBO the unlicensed economy is capable of generating revenues for the common good?
The tower folks are always busy, and the industry will need to ramp up quickly next spring and onward.  But are there enough crews to do the big iron sticks as well as all of the LPTV and TV translators within the 39 month repack?
Can more than 1000 full power and Class A stations be relocated in 39 months?   And can as many as 4000 LPTV and TV translators be re-engineered and constructed within 39 months?
And what about more than 3000 already issued new construction permits?  While they have to wait until after the first displacement window to file, many of them are eager to build as soon as possible.
Will the ATSC 3.0 rulemaking be accomplished within two years from today, which would be a year after the auction?
The FCC legal bar will have many transactions, advisories, and opinions, and work will be plentiful.  Or will it be?  The chase for who will get to represent the 100's of newly minted Class A millionaires, for the almost LPTV licenses they have.  Many of the large communications law shops which do not currently rep any LPTV stations will soon be calling.
And LPTV and TV translators have to pay for their displacement moves. Those funds will not come from the FCC under current authority.  And Congress, well they are in need of some time to get their governing model and new speaker voted in, and who know what the budget will look like, and no pre-auction legislation for us has been announced.  
Broadcast industry equipment suppliers have been suffering ahead of the Incentive Auction with the stoppage of most all new orders.  But a new day and bright horizon awaits them in 2016.  As soon as the Incentive Auction band plan is announced, say mid-late January or thereabouts...at that time, a potential displacement cost estimate for LPTV and TV translators can be done.  And at that time business plans can start to be made.  But it will take all of 2016 for the equipment sales orders to start to come in.
After the Incentive Auction, a year from now, many Class A licensees will start to spend a lot more money due to reinvestment of their Incentive Auction winnings back into their LPTV and TV translator licenses and permits. 
Only built and licensed facilities, which are displaced, may enter the first window six months after the auction ends.  Could be exactly this time next fall.  The media brokers are already licking their chops and preparing for lots of deals to assist with those wanting to buy and sell.
A year from now, life is good for those who won in the auction, and the licenses and permits they buy for cheap from those who are ready to get out.  For the rest of us, it is all money out, lots of waiting around for tower crews, and for us as licensed services, to prove we do not interfere with unlicensed services.  

Thanks Congress, your enlightened corporate welfare program for the Googleplex, AT&T, Verizon, T-Mobile, etc.  It is  truly  inspiring to see how messed up it all is.  

The fixes the FCC are beginning to do to lessen the impacts to LPTV and TV translators are welcome, and we trust the 3rd LPTV Report and Order will also be more the same.  

But stay tuned for the LPTV cases in the Court of Appeals.  Big issues for the Court to hear about.


In the Revitalization of the AM Radio Service, MB Docket No. 13-249, of the FIRST REPORT AND ORDER, FURTHER NOTICE OF PROPOSED RULEMAKING, AND NOTICE OF INQUIRY.... 

Adopted: October 21, 2015
Released: October 23, 2015
         "5. There are, however, several commenters who suggest that the end result of any proceeding involving the AM service must be, in the terms of the Catholic Radio Association, "not to revitalize it, but to transition it."
Specifically, CRA and others believe that the medium wave AM band is too beset by environmental noise and other forms of interference to remain a viable communications medium, and instead advocate that we open up the 76-88 MHz band (VHF television Channels 5 and 6) to relocate current AM stations to that band to operate as FM broadcasters.
Despite the calls for this solution, we cannot consider it at this time.
First, as we announced in the Further Notice of Proposed Rulemaking and Report and Order in the 2014 Quadrennial Review proceeding, migrating AM services to VHF Channels 5 and 6 has the potential to interfere with our implementation of the Congressional directive to reassign television stations following the upcoming Incentive Auction process.
Second, as several commenters note, AM radio has distinct advantages over other media during times of disaster and emergency, including the wide area coverage of some stations."

A recent research run of TV Study showed us that there are about 112 LPTV and TV translator channel 6's, and 87 channel 5's.  So it is good news that the Incentive Auction repacking and displacement process can continue on as scheduled without additional burden on us.  The use of analog channel 6's across the country for FM radio service is a growing business model.  Current and future operators are awaiting a decision by the FCC in the upcoming 3rd LPTV Report & Order before the end of the year.

Adopted: October 21, 2015
Released: October 26, 2015


The research needed to craft solutions for the LPTV and TV translator industry just doesn't happen by itself.  Members of our Coalition have stepped up and provided the basic funding, but we also need your financial support to keep the process moving forward.  Rather than go to the Courts, we are trying to get favorable legislation passed, and the research we do is essential.  If you have a license or construction permit, then it is in your vital interest to support this research and advocacy process.  


Mike Gravino, Director
LPTV Spectrum Rights Coalition