Relocating television stations to new channels following the close of the TV broadcast spectrum incentive auction will be the most complex transition the Federal Communications Commission has ever overseen. We know that many stations will be repacked, we know that there are constraints on the resources available to perform this work, and we know there are hugely complex interference relationships between broadcast television stations.
But we don’t yet have a full picture as to which stations will be moving to new channels, and what the ramifications of those moves will be. For example, many towers that are home to repacked television stations are also home to FM radio stations, which are not being repacked.
During the incentive auction rulemaking, NAB and others asked the Commission to allow repacked television stations to reimburse other broadcasters, including FM stations located near repacked television stations, for costs those stations might incur during the repack. It seems reasonable to us that, if an FM station, an innocent bystander to the repack, needs to construct alternative facilities to stay on the air during repacking work performed on a nearby television station, this should be considered a reasonable expense associated with the repack. The FCC disagreed, citing the language of the legislation authorizing the incentive auction.
Regardless, those FM stations and their millions of listeners are still there. They still face the real possibility that repacking may disrupt their operations, even though they have literally nothing to do with the incentive auction. Work on nearby television antennas may require FM stations to reduce power, or seek alternate facilities. A repacking plan that does not take FM stations into consideration risks depriving listeners of local radio on which they rely. The right answer is to coordinate repacking efforts to minimize disruption, while also reimbursing bystander stations for costs they incur to maintain service – not to make them collateral damage.
Over the coming months, the scope of work for the repack will become increasingly clear. The FCC has already informed television stations, confidentially, of their new channel assignments, and in April we expect the FCC to release this information publicly, providing a more definite understanding of the post-auction landscape. A balanced, reasonable repacking plan will treat all stakeholders fairly, including all affected broadcast stations, whether they are repacked or not.