Tagged: incentive auction Toggle Comment Threads | Keyboard Shortcuts

  • Patrick McFadden 1:20 pm on March 23, 2016 Permalink
    Tags: , incentive auction,   

    Time to Stick to the Facts and Find the Right Answer 

    These are exciting times. The long-anticipated broadcast television spectrum incentive auction is scheduled to begin in less than one week. Designing the reverse and forward auctions has been a herculean task, and the Federal Communications Commission (FCC) staff deserves a great deal of credit for bringing the auction to this point in a timely fashion. But, unfortunately for the Commission, once the auction is complete, its work is only half done. That’s because the end of the auction brings perhaps the most challenging phase of all: repacking many hundreds – if not more than a thousand – broadcasters to new frequencies in the television band.

    As NAB has repeatedly documented, broadcasters have serious concerns about the arduous repacking process ahead. After all, it took the better part of a decade and three extensions of time to complete the digital television (DTV) transition, which involved relocating far fewer broadcasters, did not rely on flash cuts and was buttressed by tens of millions of dollars designed to help consumers make the switch to digital. Above all, however, the greatest worry with respect to the upcoming 600 MHz transition is the Commission’s current rule requiring every broadcaster to complete its involuntary relocation within only 39 months following the auction. If the FCC is serious about repacking as many as 1,300 broadcasters, anyone who has any understanding of the broadcast industry knows that it is impossible to accomplish that task in such a short period of time.

    Fortunately, the FCC commissioners have uniformly recognized the challenges associated with the repack and have indicated in testimony before Congress that – despite the current rules – they in no way want to see any broadcaster forced off the air for reasons beyond their control.

    On the other hand, the FCC’s chairman has continued to insist that the 39-month timeline is sound. When pressed by Congress to defend that deadline given that the FCC has not done any serious analysis of what it would actually take to conduct a nationwide repack, the chairman explained that 39 months was a reasonable timeline, because, after all, even NAB had originally suggested that 30 months would be sufficient. This answer is disingenuous, and given that it has been repeated on several occasions by Commission staff, it’s time to address and bury it once and for all.

    More than three years ago, NAB submitted its initial comments in the incentive auction proceeding (then under Chairman Julius Genachowski) recommending that the FCC extend its proposed timeline for moving stations to new channels following the upcoming broadcast spectrum incentive auction. The FCC had proposed a minuscule 18-month timeline, to which NAB responded, “[t]he 18-month construction time frame proposed in the Notice for relocating stations is unrealistically short.”[1] At the time, NAB assumed, as many did, that the Commission was considering relocating “approximately 400 to 500 stations.”[2] Thus, NAB recommended that the FCC extend the deadline to 30 months, which should be enough time to “allow most stations to complete” the transition.[3] In addition, to stretch that 30 months as long as possible, NAB also proposed that “the forward auction should not be deemed completed until, or after, the time at which stations file their construction permit applications,”[4] which the Commission did not adopt. And finally, NAB made clear that “based on television stations’ experiences in the DTV transition, stations in certain metropolitan areas (such as New York City and Denver) and stations in border areas requiring international coordination could require substantially longer than even three years to construct new facilities.”[5]

    Thus, not only did NAB rely on information at the time that suggested only 400 to 500 stations would move, and seek to push back the starting point for the timetable until after construction permits were issued, we also asserted that even repacking all of 400 to 500 of stations would require more than 30 months.

    Beyond those inconvenient details, there have been three important developments in the intervening three-plus years. First, the FCC released a set of sample repacking scenarios in the summer of 2014, suggesting that the Commission is likely to repack far more stations than NAB anticipated in our 2013 comments. Instead of moving perhaps 400 stations to new channels, the FCC’s publicly released simulations suggested that the FCC could require more than 1,300 stations to relocate. Second, once the FCC released this data, NAB commissioned a study – the first of its kind – to examine each of the challenging elements that make up a nationwide repack of many hundreds or more than 1,000 stations. Third, in May 2014, the FCC surprised everyone by adopting a “death penalty” repacking rule that would require stations unable to complete their transitions within 39 months – no matter what the reason – to go off the air. The rule did not contemplate any exceptions or extensions – a rigid and inflexible deadline that no one anticipated.

    Faced with this new information, NAB re-evaluated the timeline for the upcoming broadcaster transition. It became immediately clear that 39 months would not provide sufficient time to repack the number of stations the Commission was anticipating. As a result, NAB has asked the Commission to establish aggressive, but achievable, deadlines for repacked television stations after the auction, when more is known about many stations will move, where they are located and to which channels they will be moved.

    This evolution is certainly reasonable. New facts and circumstances demand new solutions. While it is concerning that some continue to hide behind comments NAB submitted more than three years ago under different circumstances, it’s frightening that these same officials are hiding at all. The point of the repacking conversation is not to prove who is right; rather it’s to get it right. As the FCC pivots to thinking about repacking – which is now likely less than a year away – rather than being cute about past comments, it should actually engage and wrestle with the enormously complex repacking problem ahead. Only that course will give the broadcasting and wireless industries confidence that the post-auction transition will be a success.

    [1] Comments of the National Association of Broadcasters at 50, GN Docket No. 12-268 (Jan. 25, 2013).

    [2] Id. at 50.

    [3] Id. (emphasis added).

    [4] Id.

    [5] Id. (emphasis added).

     
  • Rick Kaplan 1:20 pm on April 29, 2014 Permalink
    Tags: , incentive auction,   

    I Suppose It’s Worth A Try (When You Are On a Roll…) 

    There is overstating and then there is overstating.

    Last week, NAB proposed to the FCC commissioners some changes to the 600 MHz band plan included in the draft incentive auction order currently under review at the Commission. Specifically, NAB asked the FCC to shelve its planned 6-to-11 megahertz duplex gap that would be shared between wireless and unlicensed services, and instead adopt NAB’s “Plan B” and use a flat 10 or 11 megahertz duplex gap, of which 4 or 5 megahertz would be reserved exclusively for wireless microphones. NAB believes this is both fair and essential, as licensed wireless microphone users will be foregoing the current two exclusive 6 megahertz channels in favor of only 4 or 5 megahertz vital to providing breaking news coverage in local communities throughout the country.

    In response, New America Foundation’s Michael Calabrese blasted NAB’s proposal, saying that it “would be a death sentence for unlicensed broadband and innovation post-auction.”

    That statement almost made me feel badly. Were we essentially recommending an end to unlicensed innovation as we know it? Would our proposal lead to no more WiFi, garage door openers or cordless phones? Are we proposing to kill off baby monitors, and putting infants at risk across the nation? What have we become?

    After some serious soul-searching, my grandmother’s famous chicken soup (good for the soul) and a long hard look in the mirror, I looked to the facts to see if Mr. Calabrese was really on to something.

    Fact #1: In March, the FCC massively expanded the spectrum designated for unlicensed services by allocating more than 100 megahertz for that purpose in the 5 GHz band.

    Fact #2: Just last week, the FCC launched a proceeding to free up as much as 150 megahertz more spectrum for unlicensed services, this time at 3.5 GHz.

    Fact #3: In the draft incentive auction order, the proposal for the 600 MHz band is likely to render the duplex gap unusable for unlicensed services. It envisions scenarios where the duplex gap would be anywhere between 6 and 11 megahertz. Any plan allocating less than 11 or 12 megahertz between LTE uplink and downlink will, according to the unlicensed community, render that spectrum far less valuable.

    Fact #4: The FCC’s draft incentive auction order opens up channel 37 and a new guard band that will give unlicensed users brand new nationwide bands, including, for the first time, spectrum in major markets such as New York and Los Angeles.

    Fact #5: Under the draft incentive auction order, not only do wireless microphones lose well over half of their shared spectrum, but licensed wireless mic operators lose all 12 megahertz that are designated for exclusive use. Thus, if approved, wireless microphones will have gone from more than 60 megahertz of exclusive spectrum to zero in just five years. If there is any kind of “death sentence” in the draft order, it’s clearly just for wireless microphones.

    Unlicensed spectrum advocates – primarily Google and Microsoft – are on a serious roll in the spectrum department. In proceeding after proceeding, they keep racking up more free spectrum. And I completely subscribe to the theory of when you are on a roll, you should keep shooting. Mr. Calabrese’s play is really no more than a “heat check” for the spectrum world and Mr. Calabrese, along with Google and Microsoft, is probably feeling a lot like the Golden State Warriors’ Steph Curry right now.

    Thirty-foot jump shots aside, it is clear that absolutely no innovation is lost under NAB’s “Plan B.” In fact, the unlicensed community will exit 2014 having earned massive allocations of spectrum, including new nationwide spectrum blocks in the 600 MHz band. Thus, NAB’s proposal does nothing to drive a stake through the beating heart of unlicensed broadband innovation.

    On the other hand, it is hard to overstate the harm the current draft order would do to wireless microphones and the essential public service they help deliver. These devices – an innovation themselves, for what it’s worth – help broadcasters on a daily basis cover breaking news and weather in local cities and towns across the nation. When the president followed developments in the Boston bombing tragedy, he watched multiple local Boston broadcast TV stations to get well-informed, up-to-date, on-scene reporting. In order for that to happen, broadcasters relied on wireless microphones to deliver the news as it was breaking.

    Some unlicensed spectrum advocates believe the TV white spaces database to be some kind of panacea. It is not. FCC rules require that devices check the database only once every 24 hours. Thus, broadcasters can only be sure to be free from interference from unlicensed devices sharing their wireless microphone channels if the world is kind enough to inform them of breaking news a day in advance. And even if the FCC finally amends its rules to permit more frequent checking – which it should have done at the outset – in times of crisis wireless networks often go down, rendering the database useless. That is exactly what happened in Boston following last year’s horrific bombing.

    In a more temperate moment, Mr. Calabrese also noted that his coalition “strongly supports the NAB’s position that the FCC should continue to reserve two vacant broadcast channels for priority use by licensed wireless microphones.” He states that “[t]hese channels could be designated post-auction in each market and therefore would not in any way reduce the Commission’s flexibility during the auction.”

    To be clear, NAB’s “Plan A” that Mr. Calabrese refers to involves retaining today’s two exclusive channels pre- and not post-auction. This is because a post-auction reservation means essentially nothing in all of the major markets. In most of the top 100 markets, following the auction there will be no spectrum whatsoever available for reservation. Repacking and reallocation will take care of that.

    Now I understand the eagerness of many companies – especially major tech companies and wireless carriers – to feed off of the broadcaster carcass in the upper 600 MHz band. The Chicken Little approach, however, won’t get it done. Facts will. And the fact is that wireless microphones need some small exclusive home in their 600 MHz band in order for newsgatherers to keep providing the kind of on-scene up-to-date information for their viewers. There is a place for nearly everyone in the incentive auction, and both NAB’s Plan A and B for wireless microphones reflects the best and most appropriate balance.

     
  • Rick Kaplan 12:40 pm on January 13, 2014 Permalink
    Tags: incentive auction,   

    Spectrum Reflections: It’s Time for A Moment of Reflection, CCA 

    CCA, please tell us you are kidding.

    In December, the Competitive Carriers Association (CCA), a trade association that represents most wireless carriers with the exception of Verizon Wireless and AT&T, filed comments at the Federal Communications Commission (FCC) in response to the FCC’s proposed rulemaking to eliminate the so-called UHF television discount. The filing would be downright funny if it wasn’t so desperate, specious and irresponsible.

    The UHF discount proceeding is a pure broadcast television issue. By way of brief background, the broadcast television ownership rule prohibits a single entity from owning stations that reach in the aggregate more than 39 percent of total television households nationwide. The “UHF discount” allows stations broadcasting in UHF to count toward that cap only half of the TV households in their markets, as opposed to all of the households for VHF stations. The FCC has proposed to eliminate that discount.

    The issue has absolutely no impact on the wireless industry. So why would CCA file? Was it a mistake?

    CCA’s comments prodded the FCC to “examine . . . rules applicable to broadcast stations and take action to eliminate remaining regulatory distortions. . . . [T]he Commission should carefully consider how the existing rules and proposed reforms would affect broadcast stations’ incentives to relinquish spectrum in the upcoming 600 MHz incentive auction and adopt reforms in light of that vital consideration.”

    In plain English, CCA expressly asked the FCC to strong arm broadcasters into participating in the wholly unrelated voluntary broadcast spectrum incentive auction. CCA’s theory is that if the FCC takes actions that affirmatively harm broadcasters, more broadcasters will participate in the voluntary auction, and then CCA’s members will have access to more spectrum than they would have otherwise. 

    Underlying CCA’s advocacy is the notion that broadcasters benefit from regulations that “distort” the market. Presumably CCA is not referring to all of the obligations imposed on broadcasters (that are not imposed on the wireless industry), such as children’s programming mandates, indecency regulation and captioning requirements, just to name a few. 

    I don’t know whether to laugh or cry. Maybe both.

    Let’s have a good laugh first. CCA apparently neither understands the regulatory regime under which broadcasting is governed nor the concept of irony.

    First, no industry is more heavily regulated by the FCC than broadcasting. Unlike any other industry, the FCC’s regulations govern many facets of broadcasters’ operation. The very structure of our industry is dictated by the federal government. For example, as noted above, in terms of ownership, Congress set a cap on how big any one television group can get: no entity can reach more than 39 percent of the U.S. population. There is no corresponding rule in the wireless industry. Indeed AT&T and Verizon Wireless produce maps claiming to cover more of the country than the other. The government has also imposed a number of mandates on broadcasters to which no other industry is subject. Broadcasters have to produce a certain amount of children’s programming for example. CCA’s members, on the other hand, just have to throw up a tower and let whatever comes across – and we sure know what can come across – reach the end user. Speaking of the Internet, unlike wireless companies (including those that got their spectrum “for free”), the FCC has imposed decency standards on broadcasters. Cable channels don’t even have the same obligations. Broadcasters are also subject to accessibility regulations far beyond what CCA’s members could fathom. So it is safe to say that broadcasting is not an industry propped up by regulation – unlike small wireless carriers (a point to which I will return) – we are primarily saddled with government regulation.

    Second, unlike broadcasters it is CCA’s members that depend on government regulation.  Government intervention is their oxygen. In a largely deregulated wireless industry, CCA pays visits to the Commission time and time again, imploring the FCC to give its members preferential treatment. In fact, in the incentive auction proceeding itself, CCA is virtually begging the Commission to give its members a leg up on AT&T and Verizon Wireless. CCA also routinely seeks forced interconnection among wireless carriers, so that its members can free ride on the investment of others who have invested billions to build their networks. It asks the FCC to subsidize its members through the Universal Service Fund so they don’t have to invest. And it routinely seeks to force other carriers to interoperate with its members so they can ride off the bigger carriers’ backs on equipment orders. CCA is an association that has never met a regulation it hasn’t liked. It relies on, and affirmatively seeks to increase, government intervention in the marketplace.

    This characterization is not simply my opinion; all it takes is a quick walk through CCA’s recent filings to discover its government-prop-us-up mission. Just over the past year, CCA has fervently advocated in favor of the following market interventions:

    • Revision of the spectrum screen to impose government-mandated limits on the amount of spectrum commercial carriers may aggregate;
    • Adoption of auction rules that limit the amount of spectrum large carriers may  acquire, as well as bidding credits and other mechanisms to favor other carriers, and license areas tailored to the desires of CCA’s membership;
    • Forced provision of data roaming arrangements;
    • Mandated interconnection obligations for  incumbent Local Exchange Carriers following the IP transition, including the full panoply of Section 251 and 252 requirements;
    • Forced interoperability of handsets;
    • Revision of the USF rules to increase subsidies for rural wireless service providers;
    • Conditions on the merger of AT&T and Leap, including divestiture of spectrum in markets where AT&T exceeds the spectrum screen, as well as forced offering of roaming arrangements on the same terms and conditions carriers previously negotiated with Leap; and
    • Conditions on the Verizon-AT&T spectrum swap, including an interoperability mandate.

    Now for the part that’s no laughing matter.

    Somewhere along the way, CCA – and they are not alone in this – conveniently overlooked Congress’s clear direction that the incentive auction must be voluntary. “Voluntary” means that no broadcaster, by any means, can or should be coerced into participating in the auction. CCA is asking the FCC to violate the law by forcing broadcasters, through regulatory arm twisting, to give up their spectrum. If the FCC turns up the heat enough, says CCA, then broadcasters will have no choice but to “volunteer.” That is a big no-no, although CCA seems not to care about staying within the bounds of the law.

    If CCA were the only organization heading down this road, I likely would not be writing this post. For if a tree falls in a forest…well, you know the rest. But there are others out there with similar motives. And it is time to shine light on an issue that needs to be crystal clear. The FCC cannot, under the law, take any action designed to harm broadcasters with an eye towards encouraging participation in the auction. The lone incentive for participation is the market-based auction itself, and the compensation broadcasters are offered to relinquish their licenses.  Anything else is unlawful, and it is no laughing matter to push the FCC to violate the law.

    The voluntary broadcast spectrum incentive auction can be a success. The Commission does not need to cheat in order to make it so. NAB, as always, stands ready and is committed to doing what we can to see the Commission succeed in its auction and to do so in a way that adheres to the law.

     
  • Rick Kaplan 1:10 pm on December 18, 2013 Permalink
    Tags: incentive auction,   

    Spectrum Reflections: The Impending Sprint-Mo and the Auction Oh-No 

    I have to imagine that AT&T and Verizon Wireless (and their troops in Washington, in particular) are taking some pleasure in the recent stories suggesting that Sprint and T-Mobile are once again contemplating a merger. The potential for such a union adds a new level of intrigue in the campaign these four wireless heavyweights have been waging over whether the Federal Communications Commission (FCC) should limit the amount of spectrum any one carrier can acquire in the FCC’s upcoming voluntary broadcast spectrum incentive auction.

    For more than a year, AT&T and Verizon Wireless, aka “the big guys,” have been slugging it out with Sprint and T-Mobile, aka the “not-quite-as-big guys,” over whether the FCC should impose caps on the amount of spectrum the big guys can acquire in the voluntary broadcast spectrum incentive auction. The not-quite-as-big guys have been arguing that, if the FCC does not limit the amount of spectrum the big guys can acquire in the incentive auction, the not-quite-as-big guys will be frozen out, and the already expansive gulf between the big guys and not-quite-as-big guys will expand. The big guys respond that an “open auction” – one without restrictions – will yield the largest payday for the U.S. Treasury, as any artificial limits could hamper the auction’s overall success. As one might imagine, the not-quite-as-big guys disagree with this analysis, and what has followed is a massive subsidy of the economics profession in the United States, as each side has enlisted countless economists to support their respective worldviews.

    The recent revelation concerning Sprint and T-Mobile has now fueled a new element of the wireless competition debate. Namely, how does this potential merger affect, if at all, the auction eligibility rules the FCC has been designing with today’s wireless industry in mind?

    To illustrate the specific challenge this merger poses, let’s assume that the FCC is contemplating rules that would ensure that each of the top four wireless carriers has a reasonable shot at acquiring spectrum in the incentive auction. What happens, then, if those rules are enacted, and Sprint and T-Mobile subsequently reach a deal to merge, but prior to the auction itself? Or, what happens if the two companies participate in the auction independently, benefit from competitive rules designed for them, and then merge with spectrum assets they wouldn’t have had access to had they merged pre-auction?

    The plot has certainly thickened.

    The National Association of Broadcasters (NAB) has not taken a formal position on whether the FCC should enact any rules within the voluntary broadcast spectrum incentive auction to foster competition in the wireless industry. While competition in the wireless industry is certainly a good thing for broadcasters (e.g., Sprint’s deal to activate FM chips in cell phones when the big guys passed on the public safety opportunity), we haven’t studied carefully the effects of various rules imposed in an auction and their likelihood of success.

    For the Commission, the rumors of a Sprint/T-Mobile merger seriously raise the stakes for the wireless competition issue; one that has already had more airplay than any other. One way to think about the added complication of the potential merger is through the eyes of those designing the rules. Any competitive rules being considered by the FCC necessarily have some “ideal” number of national carriers in mind. For example, the Commission could determine that no bidder should win more than 25 or maybe 33 percent of the licenses in each market area. The former (25 percent) is likely based on a desire for at least four carriers, while the latter (33 percent) for at least three. If the Commission chooses four (i.e., a 25 percent cap on each carrier), but then Sprint and T-Mobile merge post-auction, the new “Sprint-Mo” could walk away with 50 percent of the licenses in a given area, potentially undermining the Commission’s long-term competitive aims.

    One may argue that this alleged problem is overblown, as a newly merged Sprint-Mo (pre-auction) could give even smaller carriers a shot at spectrum in the auction. One could also assert that a post-auction merger would likely result in serious spectrum divestitures, thus benefitting small wireless carriers. But, time has shown that most small carriers cannot survive the capital-intensive wireless business long-term, and they ultimately end up either relying on significant government intervention to survive (e.g., data roaming, interoperability, special access reform, the Universal Service Fund, auction rules to their benefit), or more likely, they simply sell out to the big guys in the end, anyway. This is likely why the Department of Justice focused almost exclusively on the nationwide providers in the competition analysis it submitted to the Commission last April.

    The challenge for regulators is that the commercial wireless industry is consolidating at a rapid rate, therefore providing a moving target. It is difficult to employ effective competitive auction rules if you have no idea what the industry you are trying to keep competitive will look like when those rules take effect (i.e., in an auction at least 18 months away). This is not to suggest, in any way, that the FCC should not be looking closely at how to foster a competitive wireless marketplace, and even do so in the context of this auction. Rather, I’m merely highlighting the high degree of difficulty in getting it just right.

    The major concern for AT&T and Verizon Wireless is that Sprint and T-Mobile may have a chance to end run the process. If they are savvy, they may be able to achieve favorable auction rules, win convincingly at auction and then merge. The FCC would then be in the tough position of having to either deny that merger or exact major divestitures, the latter of which (divestitures) has historically been a disaster. On the other hand, if approved, the resulting Sprint-Mo would be a spectrum powerhouse, having navigated the regulatory wireless morass in a way that only DISH Chairman Charlie Ergen has managed to so far.

    And speaking of Charlie, let’s not forget that his 40 – oops, soon to be 50 – megahertz is still out there, lonely, fallow and perhaps waiting for a call from Sprint-Mo as well.  

    It should be a fun first half of 2014. Happy New Year!

     
  • Rick Kaplan 10:04 am on December 17, 2013 Permalink
    Tags: incentive auction,   

    Representing Broadcasters and True Incentive Auction Success 

    At last week’s Senate Commerce Committee hearing on “Crafting a Successful Incentive Auction,” the executive director of the Expanding Opportunities for Broadcasters Coalition (EOBC) sounded the alarm that the Federal Communications Commission’s (FCC) upcoming incentive auction was on the path to complete failure. The reason? The FCC is allegedly not moving fast enough to inform broadcasters exactly how much money the agency plans on shelling out for their spectrum licenses and that the agency may be considering reverse auction rules that approximate the actual value of spectrum licenses. He concluded that anything that gets in the way of paying broadcasters handsomely for their spectrum licenses is going to lead to auction catastrophe.

    Let me ease your minds: There is no cause for alarm. The sky is not falling. Broadcasters are patient, digesting what emerges from the FCC and recognize that this is a long, complex process.

    The National Association of Broadcasters (NAB), along with the Association of Public Television Stations (APTS), represents the true interests of all broadcasters. Our aim is to serve America’s local broadcasters and to expand their opportunities in the 21st century, whatever they might be. We have members who will continue broadcasting for decades to come and others that may look to the incentive auction as an opportunity to exit the business after a long history of serving their communities.

    The EOBC, while apparently made up of companies that hold licenses in the broadcast band (its membership list is a closely guarded secret), does not represent broadcasters. In many respects, this group seems to stand in stark contrast to what is in the best interests of broadcasters and broadcasting. Its mission is singular: to capitalize on regulatory arbitrage. Its aim is to make sure that its members are paid as much money as possible and paid as quickly as possible for their spectrum licenses. 

    While there is nothing wrong with having one’s own interests at heart, we must take the comments of this coalition in that context. This context explains why, as opposed to NAB, APTS, as well as the representatives of wireless companies and associations, cable companies and associations and public interest groups, the EOBC is not concerned with the resulting 600 MHz band plan, how international coordination impacts the future of television, interoperability, co-channel interference, or any other issue beyond how much they get paid and how quickly. The day their checks are cashed, their engagement in this auction ends; the EOBC has no interest in the subsequent repacking or consumer welfare.

    The FCC staff is working hard to solve dozens of challenges in this extremely complicated auction. The agency is not close – nor should it be at this point – to determining starting prices in markets or even to confirming which markets are eligible for auction. These are very difficult questions among many others that need to be sorted out over time.

    If done right, the FCC will make it as easy as possible for willing broadcasters to participate in the auction. In practice, this means ensuring that broadcasters understand the rules of the road and that their participation does not require an army of economists or mathematicians. There should be low barriers to entry. The process will take time, and in all likelihood will require the cooperation of those such as NAB and APTS, that truly represent broadcasters. These broadcast advocates want to weigh the potential benefits of participation, not just quick-hit investors looking to turn a quick profit because of the government’s unique offer to buy back licenses.

    NAB has been engaged with the FCC to ensure the auction’s success and viewer protection from start to finish. Success for us includes, but goes far beyond, those looking to profit on their licenses. So, when Congress, the FCC and the public ask where broadcasters stand, and how can we ensure success for the auction – both for participants and non-participants – they should look to NAB and APTS. These associations represent America’s television broadcasters – not just companies that happen to hold licenses – and are focused on both the short- and long-term success of the industry. 

     
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