There is a lot to cover as we take this quick overview of the latest Incentive Auction filings:   

Google's Reply Comments will take you on a merry ride through Wishful Valley, where the FCC can just wave its' General Authority, and all will be as Google wants, and 100's of billions each year will be added to the economy.   But rather than bore you with how this will stop the auction before it starts, let's look at the really bad stuff, the Goo of the MicroGoo.  

Google first makes this claim: Implementing the Vacant Channels Proposal Will Not Significantly Affect Broadcasting. What makes this interesting is this Goo..

" This action, moreover, will impose only a small burden on broadcast licensees, which is more than justified by the benefits it will create for millions of consumers and the U.S. economy. "

So, some 9,726 TV broadcast licensees and permittees (2172 primary and Class A, and 7554 LPTV, translators and new permits) are pitted against the benefits to millions of consumers and the entire fraking U.S.A. economy!... GOO GOO GOO. What they fail to point out, is that the urban LPTV stations, and rural translators have a combined coverage population of 1.6 billion. So we got a lot of potential viewers. The primaries and Class A's have a combined population of over 4.5 billion. When Google says that what they want has more public interest, we challenge that.

Remember, all that the MicroGoo cares about is a free government subsidy so that they can undercut licensed spectrum based businesses. Now, there is so much Goo, we will let you just read the filing yourself. There is one key point which we do need to expand on.

Google asks the FCC to implement the Vacant Channel order using TV DMA. This means that they want three 6-MHz channels (18-MHz) contiguous, within that TV DMA. Where the Goo gets deep, is when you realize that the 210 TV DMA vary greatly in geographic size. And that common practice for LPTV and translators is to have multiple licenses on the same channel, but geographically dispersed at opposite ends of the DMA. In reality, most DMA have multiple licenses on the same channel. Multiple stations of 2, 3, 5, up to 8 channels in the same channel, geographically dispersed in the DMA.  

What this means is that when you ask for an entire channel in the DMA, in all 210 DMA, you may be wiping out 2 to 8 LPTV and TV translator potential channel assignments. And three channels means the distinct possibility of 6 to 24 per stations per DMA being denied channels to displace to. Don't believe me MicroGoo? Well da facts are da facts.

Here is the data:  

So the Goo would have you believe that taking three channels will not matter. But three channels, which eliminate new displacement channel opportunities for as many 24 stations, adds up real quick when you multiply x 210 DMA. Nuff truth for one post.


Microsoft's filing is even worse, slamming LPTV and translators whenever they can. Really? Microsoft just can't understand why they need to pay for spectrum. And why should those secondary services be upset, like they had a Class A window 15 years ago, wasn't that enough? Don't they understand that they are now secondary to the holy unlicensed users of mythical economic value? Market disruption is easy when you don't pay for an essential cost which others have to. Does Microsoft pay for electricity? How about toilet paper for its staff. Computers? Insurance? Property taxes? Ya see, they want the spectrum for free because they think they swing a big....and that LPTV and translators, and for that matter all broadcasters, are just a dying industry. Goo Goo Goo.  We are licensed, deal with it. We have public interest obligations, deal with it.

The auction will not be able to proceed without the FCC's vacant channel proposal getting through the courts. And that will take time.  So if MicroGoo wants to be blamed for stopping the auction...well that won't work. The are not buyers in the auction, or are they?

Suck Up The Goo
Keep the Auction on Track for 3/29/16!

I say again, if they want free unlicensed spectrum, and won't pay their full share of taxes for the 100's of million in offshore tax dodges, then bar MicroGoo from the auction bidding.
additional filings...

Major network affiliates combined together for comments about wireless mic's, and the limitations of the vacant channel order. 

One Media, the ATSC 3.0 spinoff from Sinclair, goes into why the vacant channel order could hinder the roll-out of the next generation TV standard. 

PBS, CPB, and APTS, argue the same point as we did above, in that a long standing Commission policy would be changed.  " The term "community" as used in both the Commission's must-carry rules and the digital television Table of Allotment rules refers to a community of license, not a DMA."

Media General, one of the largest LPTV and translator operators, comes out swinging against the unproven TV white space "pipe-dream".

ATBA (Advanced Television Broadcasting Alliance) offers a detailed legal analysis of why the FCC is obligated to continue to process broadcaster applications, and a detailed technical analysis of the problems with unlicensed users in the TV band and ecosystem.

FAB (Free Access & Broadcast Telemedia), a frequent commentator in this Proceeding, and one of the parties in the Court of Appeals cases to stop the Incentive Auction, makes the legal argument against the vacant channels.
" Sennheiser fully supports the Commission's plan to preserve at least one UHF white space channel in each area for use by both wireless microphones and white space devices, and additionally supports proposals to set aside two preserved white space channels in each market."

If you are an LPTV or TV translator licensee or permit holder, and you have not participated in the funding for research, advocacy, and lobbying the Coalition has been doing, well, what are you waiting for?  Just as much as MicroGoo is a leach and freeloader on taxes and spectrum, you all with vested interests in LPTV and TV translator spectrum need to keep funding this work. Don't be a victim of the federal spectrum games, ante up some funds to keep the work happening.    

Mike Gravino,  Director
LPTV Spectrum Rights Coalition