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Comments on Spectrum Auction Proceeding

Below is a link to the comments I filed yesterday on proceeding 12-268 about the FCC's incentive auction.

Link: http://apps.fcc.gov/ecfs/document/view?id=7022129689

Comments

1. On Wednesday, March 13 2013, 06:26 by Tripelo

Well done, Trip.

Your broad interest in this field allows uncommon insight in such a complex process as the spectrum auction.

This is an opportunity to advance broadcast TV via something like ATSC 3.0. Hopefully those that have some control can see efficiency in doing some (or all) of the things you suggested.

The saying, "If not now, when?" applies very well. One might add, "how, and at what cost, later?"

2. On Thursday, March 14 2013, 21:42 by Brian in CT

Great job with your comments, Trip. I hope they get passed around among the FCC's big decision makers. Just one quibble, though. If ASTC 3.0 can be stuffed with as much data as you say, why not chop all the remaining channels in half. With 3 Mhz. wide channels, allocation of frequencies and spacing would be much more flexible. Also, competing broadcasters won't have to share a channel. When the time comes, old channels 7-13 would be renumbered 1-14, and old channels 14-36 would be renumbered 15-60.

3. On Friday, March 15 2013, 08:00 by Trip Ericson

One of the goals of my proposal is to save money. If you rechannel everyone on narrower channels, you're having to invest in twice as much gear as if you just have two licensees on a given 6 MHz channel/transmitter.

4. On Saturday, March 16 2013, 21:03 by w9wi

A few thoughts...

- I think they're indeed going to find any reassignment of VHF-low for any type of radio broadcasting to be beyond the scope of the proceeding.

- I'm having trouble locating any solid information about ATSC 3.0 -- I rather get the impression that it's a work in progress.

I like the idea of offering broadcasters the flexibility of selecting alternative modulation schemes and codecs.

However, virtually all existing receiving equipment is *not* compatible with any modulation scheme except 8VSB and cable-suited varieties of QAM; it's not compatible with any codecs except MPEG-2 and AC-3; and it's not compatible with any channel width except 6MHz. ATSC 3.0 might make it *permissible* to use alternate standards but any station taking advantage of it would vanish as far as its OTA audience is concerned.

I would imagine that by 2022 enough receiving equipment would be replaced to make these updates practical. PROVIDED that we put setmakers on notice NOW that they need to support these alternatives.

(but I have my doubts the Commission is willing to wait that long)

Brian: the neat thing about PSIP is that it really doesn't much matter how the channels are numbered. Your TV's tuner will know how to check each valid frequency for a signal; that signal will tell the TV what channel to tell the viewer that frequency is. We can call 178.5MHz "channel 7A" or "channel 7 upper" or "New Channel 2" or "Channel G2" or "Gork" or "178.5MHz". The only place this designation needs to show up is in the FCC regulations and on the station's license.

5. On Sunday, March 17 2013, 20:16 by Brian in CT

Sorry w9wi, some habits die hard. Just because a virtual channel can technically be any number or thing, doesn't mean I have to like it. This may be antiquated thinking, but if a TV station transmits on channel "x" it should I.D. as channel "x." My favorite function on my Zenith convertor box is "Manual (RF) Tuning." I use it frequently during tropo season. Scanning the band without dealing with channel remaping is a big plus to me.

6. On Wednesday, March 20 2013, 01:48 by w9wi

(I'd rather be known as "Doug" but since the FCC ensures "w9wi" is unique I use that for a handle (grin))

Really, "Channel 7" doesn't exist as a physical concept. The definition of TV channel 7 depends on what country you're talking about; in Japan, in China, in Eastern Europe, in Western Europe, in Australia, and in North America you're talking about six different frequencies.

In the analog era, WFSB broadcast on 61.25MHz. When you punched in "03" on your TV, it checked a lookup table, knew you meant 61.25MHz, tuned to that frequency, and found WFSB.

In the digital era, when you punch in "03" on your TV, it checks a lookup table, knows you mean 584.31MHz, tunes to that frequency, and finds WFSB.

The only difference is, in the analog era the lookup table was published in the FCC regulations. (73.603) In digital, the table is built when you do the initial channel scan.

Imagine you lived in Chicago and wanted to watch The Amazing Race on CBS. Without channel remapping, to watch CBS in Chicago, you'd punch in:

Analog, pre-transition: 02
Digital, during transition: 03
Digital, post transition: 12
-- unless you live downtown in which case you might want 26 instead.

With channel remapping, to watch CBS in Chicago, you'd punch in:

Analog, pre-transition: 02
Digital, during transition: 02
Digital, post transition: 02

No, remapping doesn't make DXing any easier, but it sure makes things better for the 99.99% of viewers who just want to see their favorite program!

7. On Wednesday, March 20 2013, 23:07 by Morgan Wick

This raises some questions for me:
*Would NJTV be able to direct their signal towards the New Jersey side of their stations' respective markets without causing problems to adjacent signals on the same tower?
*Echoing Doug's comments, how far along is ATSC 3.0? I know Wikipedia only recently even acknowledged its existence, and I'm not sure ATSC 2.0 has even been finalized yet. Is it possible for ATSC 3.0 to be ready by 2020? Is it even known whether two ultra-high definition feeds will fit in the space of a current channel, with or without Mobile DTV?
*How important is the adoption of on-demand and other non-real-time content in ATSC 2.0 and 3.0, or is it not bandwidth-efficient enough to be more than a gimmick?
*This applies both to the current repack and your proposal, but more to your proposal: if it is possible for multiple "stations" with multiple owners to occupy a single "channel", what would this mean for subchannels? Could a station owner's ability to launch a subchannel effectively become an end-around the duopoly restrictions? Would this require the end of subchannels as we currently know them and a return to "one licence one channel"? You seem to imply a minimum of two stations per channel, but you also state that stations could voluntarily agree to pack themselves in three or more to a channel. If stations are using different amounts of spectrum, and spectrum could mean quantity and not just quality, how can duopoly restrictions be both enforceable and fair? This is especially important since you don't want to put rural stations through the same process, meaning some parts of the country would be on the old bandplan and others on the new.

The FCC could divide the entire broadcast spectrum into up to four clusters; if some markets use the entire high-VHF spectrum, those seven channels are enough for 14 stations, more if they agree to pack themselves in more. That's enough for the Big Six, two PBS stations, an independent, Ion, three Spanish stations, and one more programming service like TBN. The remaining 23 UHF channels could be broken up into three blocks, two of eight channels and one of seven, allowing larger markets to have two more stations. That would allow markets to be fairly tightly clustered, but only if the FCC doesn't blindly follow the Nielsen market list.

For example, New York could have room for the seven legacy VHF channels, WNJN, WNYE, WEDW, WPXN, WXTV, WNJU, WFUT, WMBC, and WTBY, while Los Angeles would have room for the legacy VHFs, KCET, KLCS, KMEX, KVEA, KFTR, KPXN, KWHY, KTBN, and one more, with other stations either getting squeezed in with stations willing to share more spectrum or moving to a location in Orange County. Even more space could be made available by dividing the spectrum into thirds (20+ stations per market) or halves (30+ stations per market). Indeed, many stations that are now Class A or low-power could be able to upgrade to full-power status this way, and stations that use multiple transmitters to cover an entire market (and have done so since the analog era) may no longer need to do so. The only spacing that could matter for any station in a market could be the spacing for all stations in the market.

8. On Wednesday, April 3 2013, 01:33 by Morgan Wick

Okay, I've done some preliminary analysis based on the current spacing requirements and realistically, splitting the spectrum into halves won't work. Splitting it into thirds might barely work, but only if you're willing to merge the Washington/Baltimore, Boston/Providence, and Hartford/Springfield/Holyoke markets. I also wonder about what happens with adjacent mountainous markets; which gets the VHF block?