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Release of Information Related to Incentive Auction Repacking

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Released: July 22, 2013

PUBLIC NOTICE

Federal Communications Commission

News Media Information 202 / 418-0500

445 12th St., S.W.

Internet: http://www.fcc.gov

Washington, D.C. 20554

TTY: 1-888-835-5322

DA 13-1613

Released: July 22, 2013

INCENTIVE AUCTION TASK FORCE RELEASES INFORMATION

RELATED TO INCENTIVE AUCTION REPACKING

GN Docket No. 12-268

ET Docket No. 13-26

As stated in the Notice of Proposed Rulemaking, the incentive auction will have three major pieces: a reverse
auction, a forward auction, and a reorganization or "repacking" of the broadcast television bands, which is likely
to include the reassignment of some television stations to new channels.1 The data and updated software we are
releasing in connection with this Public Notice are relevant to the repacking component of the incentive
auction. Specifically, the material being released represents the results of a staff analysis of whether a television
station could be assigned to particular channels in the incentive auction repacking process, consistent with
statutory and other requirements, based on certain preliminary assumptions. The assumptions are necessary for
completing the analysis but are for illustrative purposes only; the Commission has made no decision on them yet.
As discussed below, we anticipate that additional elements of the incentive auction repacking process, including
details about how bids will be selected, how channels will be assigned, and algorithms for carrying out these and
other elements of the repacking process, will be made public in the coming months. As is the case with the
repacking component of the incentive auction, final decisions regarding these elements of the incentive auction
will be made by the full Commission. We believe our action today is an important step in the process of
designing a successful incentive auction.
In order to build a record on which Commission decisions can be based, and to improve the ability of
interested parties to analyze issues on which the Commission has sought comment, we will be releasing in
connection with this Public Notice updated software and two types of information related to repacking:
Updated TVStudy computer software and supporting data for determining the coverage area and
population served of each broadcast television station using the methodology described in OET Bulletin
69.2
Data about Canadian and Mexican television allotments as well as domestic incumbent licensees in the
broadcast television bands. These data are already publicly available, but not in a form that is easy to use

1 Expanding the Economic and Innovation Opportunities of Spectrum Through Incentive Auctions, Notice of Proposed
Rulemaking
, 27 FCC Rcd 12357, 12359 5 (2012) (NPRM).
2 The Commission is required by statute to make "all reasonable efforts to preserve, as of February 22, 2012, the coverage
area and population served of each broadcast television licensee, as determined using the methodology described in OET
Bulletin 69 of the Office of Engineering and Technology." Middle Class Tax Relief and Job Creation Act of 2012 (Spectrum
Act), Pub. L. No. 112-96, 6403(b)(2), 125 Stat. 156 (2012). OET Bulletin 69 is available at
http://transition.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet69/oet69.pdf.

for purposes of this analysis or that is limited to relevant information. In order to facilitate analysis and
comment by stakeholders, we have aggregated the data in a format that can be used more easily with the
updated software.
Descriptions of how one could pre-calculate which stations could be assigned to which channels in the
repacking process, and which stations cannot operate on the same channels or adjacent channels because
of their geographic locations (and links to data that were developed using certain preliminary
assumptions).3
The information described in this Public Notice and the attached Technical Appendix could be used for a
number of purposes in the incentive auction. For example, during the bidding in a reverse auction this material
could be used to check the feasibility of assigning channels to a given set of stations without violating any
statutory or other constraints. That is, the data could be used to determine whether channels could be assigned to
all broadcasters remaining on the air in a manner consistent with the applicable constraints if a given set of
reverse auction bids from broadcasters were to be accepted. Such a "feasibility check" could be conducted
rapidly during the course of bidding in the reverse auction because it would only require determining whether a
channel assignment is feasible for a set of stations, not that it represents the optimal channel assignment.
Optimization analysis is time-consuming; conducting it during the course of bidding in the reverse auction would
restrict the Commission's auction design options.4 The same data also could be used to optimize channel
assignments after the bidding is completed, however, without slowing down the bidding process. Such
optimization analysis could consider, in addition to the applicable constraints, additional factors such as
minimizing the number of channel changes and minimizing the estimated costs of repacking. Also, if the
Commission chooses to use a sealed-bid auction design, then optimization could be used to determine which bids
to accept in order to obtain a given amount of spectrum at minimum cost.
We are releasing the information described here and in the attached Technical Appendix in the interest of
transparency and to give interested parties the opportunity to provide input regarding aspects of the repacking
process. Releasing it at this time will enable interested parties to provide input regarding how permissible
channel assignments might be determined and how that information might be used during the incentive auction.
In addition, interested parties will be able to validate that the Commission's databases contain accurate
information regarding their stations or facilities and that the staff has correctly identified all relevant constraints
on repacking. Releasing this material also provides a common set of input values that interested parties may use
to generate new analyses based on different assumptions, should they wish to do so.
This Public Notice and the attached Technical Appendix relate to the technical aspects of repacking and
auction design, and are responsive to those commenters who have requested the opportunity for comment on such
details. We emphasize that to participate in the reverse or forward auctions, bidders need not know or master the
technical details discussed herein or in the attached Technical Appendix or in subsequent similar releases. The
Commission has announced the principle that incentive auction participation, particularly for broadcasters, should
be as simple as possible.5

3 Although some stations may be reassigned to a new channel as a result of the repacking process, the Commission has not
proposed to require any station to change the location of its transmission facilities.
4 Given that the Commission has not yet decided on an auction design, it is possible that the Commission will pick a design
that would allow for the use of optimization analysis during the auction.
5 See NPRM, 27 FCC Rcd at 12361-62 para. 10.
2

The NPRM explained that information about the feasibility of channel assignments will play a direct role in
the reverse auction as part of the determination of which bids to accept.6 Although the information we are
releasing in connection with this Public Notice does not reflect how the Commission will select bids in the reverse
auction or assign broadcast television licensees to specific channels in the repacking process, it is a critical
element in the auction design process. We anticipate that additional elements of the repacking process, including
details about how the Commission will select bids, how it will assign channels, and algorithms for carrying out
these and other elements of the repacking process, will be made public in the coming months. Consistent with the
Commission's expectation in the NPRM, we also anticipate that interested parties will have an opportunity to
provide input on these elements before the Commission reaches a final decision on a repacking methodology.7
Updated Computer Software
The updated computer software we are releasing for determining the coverage area and population served of
each broadcast television station using the methodology described in OET-69 will allow parties to analyze
potential interference on a station-to-station, or "pairwise," basis.8 OET released an earlier version of this
software on February 4, 2013.9 The version of the software being released at this time (TVStudy v.1.2) operates in
the same way as the earlier version (TVStudy v.1.1.2), but has an improved user interface and enhanced
capabilities for pairwise analysis.10 In using this software to generate preliminary data for the restrictions on
channel assignments discussed below, we set various parameters incorporated in the software to implement the
updates on which OET sought comment in its Public Notice, with the exception of a proposed change in the
default assumption of signal coverage for certain areas.11 We emphasize that the Commission has made no
decision on the proposed updates, and that whether to implement them in the repacking is subject to a final
Commission decision. The setting of the switches is for illustrative purposes only, but will help to ensure that
interested parties are working with the same software settings and input values in analyzing the information we
release in connection with this Public Notice.

6 See NPRM, 27 FCC Rcd at 12390 98, 12397 113.
7 See NPRM, 27 FCC Rcd at 12376 50.
8 The second and third of the approaches proposed in the NPRM for making all reasonable efforts to preserve population
served in the repacking process are based on "pairwise" analysis of data. See NPRM, 27 FCC Rcd at 12394 106-107.
9 Office of Engineering and Technology Releases and Seeks Comment on Updated OET-69 Software, Public Notice, 28 FCC
Rcd 950 (rel. Feb. 4, 2013). OET also released a minor update of the software on April 26, 2013. See Office of Engineering
and Technology Releases Updated TVStudy Software, Public Notice, DA 13-865 (rel. Apr. 26, 2013).
10 Among other things, TVStudy v.1.2 makes it possible to conduct pairwise studies more easily, add or remove stations to a
repacking scenario at runtime , run the software without a command line, choose which output files to create, including a new
"summary" that condenses the outputs of multiple scenarios into a single file, and add additional information to the output
cell file, such as the coordinates of the study point in a cell.
11 See Public Notice, 28 FCC Rcd at 952 ("In developing the TVStudy software, we have identified various parameter choices
consistent with but not specified in OET-69 that we believe are necessary for improved accuracy in our modeling and
analysis. We incorporated "soft-switches" into the TVStudy software to permit the user to evaluate the effects of the different
choices. We note that the different parameter choices may yield results for both coverage and interference different from
legacy versions of software that have been used in the past."). A list of the settings we used to create the preliminary data
files is included in the attached Technical Appendix. As with the previous version of the software, this version of the
software allows users to set the switches in various ways to evaluate the effects of the different parameter choices.
3

Data about incumbent licensees in the broadcast television bands
We have culled relevant data from FCC databases and aggregated it in a format that can be used to run on the
updated computer software. The data include information about domestic broadcast television stations and
Canadian and Mexican allotments. Again, the information reflects assumptions that are intended for illustrative
purposes only so that interested parties can conduct an analysis of the technical aspects of repacking and auction
design. As such, the data are subject to a final decision by the Commission. In particular, the inclusion or
exclusion of certain domestic broadcast facilities does not indicate which facilities the Commission will
ultimately make all reasonable efforts to preserve in the repacking.12 Interested parties may add facilities to, or
subtract facilities from, the data we are releasing to analyze different preservation assumptions using the process
described in the attached Technical Appendix, and we invite submissions based on such analyses.
Restrictions on channel assignments
The repacking process will involve assigning channels to broadcasters who will remain on the air following the
voluntary incentive auction.13 The permissibility of channel assignments in the repacking process will be
constrained by statutory and other requirements. The assignment of channels must take into account all
incumbents in the TV band: domestic full power and Class A television stations, Canadian and Mexican
television allotments protected by treaty, certain land mobile and radio astronomy facilities, and wireless medical
telemetry devices. The assignment of channels is subject to the statutory mandate to "make all reasonable efforts
to preserve, as of the date of the enactment of this Act [February 22, 2012], the coverage area and population
served of each broadcast television licensee, as determined using the methodology described in OET Bulletin
69."14 To illustrate how the FCC could determine what channel assignments are permissible for every domestic
television station in the repacking process, we used the updated software and the incumbent data from FCC
databases identified above to create a data set or "constraint files" for each station, comprised of what we call a
"domain file" and an "interference_paired file." A "domain file" is a list of the television channels to which a
given station could be assigned in each of three bands--low and high VHF and UHF--considering fixed
constraints, that is, incumbents in the band that are entitled to protection other than domestic television stations.15
For example, the domain file for a specific station might reflect that Channels 2, 3, and 4 in the low VHF band,
Channels 7, 8, and 9 in the upper VHF band, and Channels 21 through 30 in the UHF band are permissible
channel assignments for the station, not considering where other domestic television stations are assigned. An
"interference_paired file" is a list of the domestic full power and Class A television stations that could not be

12 See NPRM, 27 FCC Rcd at 12397 113 (proposing to interpret the statutory mandate to seek to preserve coverage area and
population served "as of the date of the enactment of this Act" to require preservation only with regard to facilities that were
licensed, or for which an application for license to cover authorized facilities already was on file with the Commission, as of
February 22, 2012, but not to prohibit the Commission from granting protection to additional facilities where
appropriate). Specific assumptions that the staff applied in conducting the analysis are set forth in the Technical Appendix.
13 Non-participating stations and stations whose bids are ultimately rejected will be assigned channels in their pre-auction
bands Low VHF, High VHF or UHF. A participating station may be reassigned from a UHF to a VHF channel in the
repacking only if it prevails in its reverse auction bid to voluntarily relinquish UHF spectrum usage rights in exchange for
assignment to a VHF channel and a share of the incentive auction proceeds. See Spectrum Act 6403(b)(3) (prohibiting
involuntary reassignment from a UHF to a VHF channel).
14 Spectrum Act 6403(b)(2).
15 These incumbents are Canadian and Mexican TV stations and certain land mobile, radio astronomy and wireless telemetry
devices. The assumptions regarding Canadian and Mexican TV stations are generally conservative with respect to
interference potential, as explained in more detail in the attached Appendix, and we may be able to use different assumptions
in the future based on negotiations with Canada and Mexico.
4

assigned to operate on the same channel or on an adjacent channel16 to the station in question in each of the three
bands, based on the second of three proposals in the NPRM for making all reasonable efforts to preserve
population served in the repacking.17 So, the interference file for that same station would list any and all stations
that could not be on the same channel as the station or on an adjacent channel to the station in the low VHF band,
in the upper VHF band, and in the UHF band, based on given interference protection criteria.
We are releasing at this time preliminary data sets or constraint files for domestic broadcast television
licensees that may be protected in the repacking process. Again, the constraint files we release at this time are for
illustrative purposes only
, and necessarily reflect certain assumptions that are subject to a final decision by the
Commission. In particular, as stated above, the constraint files reflect staff application of the second of three
proposals in the NPRM for making all reasonable efforts to preserve population served in the repacking process.
We also are including a detailed description of how the staff generated the constraint files.
***
This Public Notice is being issued pursuant to sections 0.31, 0.51, 0.61, and 0.131 of the Commission's rules
by the Office of Engineering and Technology and the International, Media, and Wireless Telecommunications
Bureaus, members of the Incentive Auction Task Force.18 Comments may be filed using the procedures for ex
parte
submissions in permit-but-disclose proceedings set forth in section 1.1206 of the Commission's
rules.19 When filing comments, please reference GN Docket No. 12-268. The constraint files will be accessible
via a link on the FCC's LEARN website under the Repacking Section, which can be found at
http://wireless.fcc.gov/incentiveauctions/learn-program/repacking.html.
For further information, contact Sasha Javid at 202-418-2392, or via e-mail at Sasha.Javid@fcc.gov. For
further information regarding data about domestic broadcast television licensees, please contact Hossein
Hashemzadeh at 202-418-1658, or via e-mail at Hossein.Hashemzadeh@fcc.gov, or Kevin Harding at 202-418-
7077, or Kevin.Harding@fcc.gov.
-FCC-

16 We list the adjacent channels above and below the station in question (N+1 and N-1) separately because the interference
relationships are different.
17 NPRM, 27 FCC Rcd at 12394 106 ("Under this approach, no individual channel assignment, considered alone, could
reduce another station's specific population served on February 22, 2012 by more than 0.5 percent.").
18 47 CFR 0.31, 0.51, 0.61, 0.131.
19 See 47 CFR 1.1206(b)(2).
5

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