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Media Bureau Seeks Comment on Widelity Report and Catalog

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Released: March 20, 2014

Federal Communications Commission
445 12th St., S.W.

News Media Information 202 / 418-0500


Washington, D.C. 20554

TTY: 1-888-835-5322

DA 14-389

Released: March 20, 2014



GN Docket No. 12-268

Comments Due: April 21, 2014
Reply Comments Due: May 6, 2014

The Spectrum Act1 establishes a $1.75 billion TV Broadcaster Relocation Fund to be used for
reimbursement of eligible relocation costs.2 In the Broadcast Television Incentive Auction NPRM, the
Commission sought comment on the types of costs broadcasters and MVPDs are likely to incur and how
to determine whether such costs are “reasonable” for purposes of reimbursement under the statute.3
Comments in response to the NPRM suggested that the Commission establish cost estimates for
categories of reimbursable expenses.4 The Commission engaged Widelity Inc. (Widelity) to aid the
Commission in understanding the process and costs associated with the post-incentive auction transition.
In September 2013, the Commission released a Public Notice seeking comment on an initial “Catalog of
Eligible Expenses” and encouraging commenters to identify additional expense categories that include
costs broadcasters and MVPDs are likely to incur in the post-auction transition.5 The Commission also

1 Middle Class Tax Relief and Job Creation Act of 2012, Pub. L. No. 112-96, §§ 6402, 6403, 125 Stat.
156 (2012) (“Spectrum Act”).
2 Id. at § 6403(d)(1); 47 U.S.C. § 309(j)(8)(G)(iii)(I). The Spectrum Act requires that the Commission
“reimburse costs reasonably incurred by” broadcast television licensees that are reassigned to new
channels as a result of the incentive auction. Spectrum Act § 6403(b)(4)(A)(i). In addition, the Spectrum
Act requires the Commission to reimburse MVPDs that reasonably incur costs in order to continue to
carry the signals of licensees reassigned to new channels as a result of the reverse auction or repacking
process. Id. at § 6403(b)(4)(A)(ii).
3 Expanding the Economic and Innovation Opportunities of Spectrum Through Incentive Auctions, Notice
of Proposed Rulemaking
, 27 FCC Rcd 12357, 12470 ¶ 343 (2012) (“NPRM”).
4 See, e.g., Comments of Nat’l Ass’n of Broadcasters, Jan. 25, 2013, at 53 (entities should receive an
initial payment based on a schedule of estimated costs established by the Commission).
5 See Media Bureau Seeks Comment on Catalog of Eligible Expenses and Other Issues Related to the
Reimbursement of Broadcaster Channel Reassignment Costs, GN Docket No. 12-268, Public Notice (rel.
September 23, 2013).

held two public workshops specifically on the reimbursement process. Widelity has produced the
attached report, “Response to the Federal Communications Commission for the Broadcaster Transition
Study Solicitation” along with a “Catalog of Potential Expenses and Estimated Costs” (Appendix B to the
Report). In producing both of these items, Widelity conducted confidential interviews of a broad range of
industry players, including TV broadcast group engineers, radiofrequency and structural engineers,
suppliers, support companies, manufacturers, attorneys, and network engineers.6 The Widelity Report
recognizes that the post-auction repacking process will be complex and that the complexity will vary from
station to station. Nevertheless, the Report concludes that, despite the significant challenges that the
industry will face, “[w]ith cooperation as well as patience, creative problem solving, and guidance from
the FCC and industry groups such as the National Association of Broadcasters, Association of Public
Television Stations, and state broadcast associations, the transition can be achieved with the desired
We seek additional input from interested parties on the report and particularly on the Catalog of
Potential Expenses and Estimated Costs. This second iteration of the Catalog includes, for the first time,
Widelity’s suggested prices, or range of suggested prices, for many of the Catalog items. Widelity
developed the suggested prices by conducting confidential interviews directly with industry participants,
including both sellers and purchasers of equipment and services with direct knowledge of pricing. The
Commission had no role in the development of the suggested prices. Accordingly, these suggested prices
are estimates only and are not meant to indicate that reimbursement will reflect the suggested prices. In
addition, we note that several additional categories have been added to the Catalog as a result of the
comments received last fall.8 As we have stated previously, this Catalog is not exhaustive, and inclusion
or exclusion of a particular category of expenses should not be read to state or imply that the expense will
or will not be eligible for reimbursement.
We now seek additional comment from industry participants on these suggested prices, as well as
any comments on the report and any further comments on the categories of costs included. A final
Catalog of Eligible Expenses and Estimated Costs will be released prior to the auction, and we believe the
Catalog will provide useful guidance to broadcasters and MVPDs as they navigate the post-auction
Interested parties may file comments and reply comments on or before the dates indicated on the
first page of this document. When filing comments, please reference

GN Docket No. 12-268


6 Widelity Report, at 7.
7 Id.
8 See, e.g., Comments of Nat’l Ass’n of Broadcasters, Nov. 4, 2013, at 7 (indicating that the Catalog
should include RF exposure studies where the RF environment at a tower site changes); Comments of
LARCAN Inc., Oct.30, 2013, at 1; Comments of Ass’n of Public Television Stations, Corp. for Public
Broadcasting, and Public Broadcasting Service, Nov. 4, 2013, at 7 (noting that the Catalog should include
liquid-cooled solid state VHF transmitters) (“PTV Comments”); Comments of American Tower Corp.,
Nov. 4, 2013, at 4 (noting that the Catalog should include tower sites requiring a helicopter lift); PTV
Comments at 7 (noting that the Catalog was unclear regarding the installation of elevators in new towers).
9 The NPRM in this proceeding included an Initial Regulatory Flexibility Analysis (“IRFA”) pursuant to 5
U.S.C. § 603, exploring the potential impact of the Commission’s proposal on small entities. NPRM, 27

Comments may be filed using the Commission’s Electronic Comment Filing System (ECFS) or
by filing paper copies.10 Comments filed through the ECFS can be sent as an electronic file via the
Internet to Generally, only one copy of an electronic submission must be
filed. If multiple docket or rulemaking numbers appear in the caption of the proceeding, commenters
must transmit one electronic copy of the comments to each docket or rulemaking number referenced in
the caption. In completing the transmittal screen, commenters should include their full name, U.S. Postal
Service mailing address, and the applicable docket or rulemaking numbers. Parties may also submit an
electronic comment by Internet e-mail. To get filing instructions for e-mail comments, commenters
should send an e-mail to, and should include the following words in the body of the
message, “get form.” A sample form and directions will be sent in reply. Parties who choose to file by
paper must file an original and four copies of each filing. If more than one docket or rulemaking number
appears in the caption of this proceeding, commenters must submit two additional copies for each
additional docket or rulemaking number.
Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-
class or overnight U.S. Postal Service mail (although we continue to experience delays in receiving U.S.
Postal Service mail). Parties are strongly encouraged to file comments electronically using the
Commission’s ECFS. All filings must be addressed to the Commission’s Secretary, Office of the
Secretary, Federal Communications Commission, 445 12th Street, S.W., Washington, D.C. 20554.

Effective December 28, 2009, all hand-delivered or messenger-delivered paper filings for
the Commission’s Secretary must be delivered to FCC Headquarters at 445 12th St., SW,
Room TW-A325, Washington, DC 20554. All hand deliveries must be held together with
rubber bands or fasteners. Any envelopes must be disposed of before entering the
building. The filing hours at this location are 8:00 a.m. to 7:00 p.m.

Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority
Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.

U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th
Street, SW, Washington DC 20554.
Parties shall also serve one copy with the Commission’s copy contractor, Best Copy and Printing,
Inc. (BCPI), Portals II, 445 12th Street, S.W., Room CY-B402, Washington, D.C. 20554, (202) 488-5300,
or via e-mail to
Documents in GN Docket No. 12-268 will be available for public inspection and copying during
business hours at the FCC Reference Information Center, Portals II, 445 12th St. S.W., Room CY-A257,
Washington, DC 20554. The documents may also be purchased from BCPI, telephone (202) 488-5300,
facsimile (202) 488-5563, TTY (202) 488-5562, e-mail
To request materials in accessible formats for people with disabilities (Braille, large print,
electronic files, audio format), send an e-mail to or call the Consumer & Governmental
Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (tty).

FCC Rcd at 12523-44. The matters discussed in this Public Notice do not modify in any way the IRFA
we previously issued.
10 See Electronic Filing of Documents in Rulemaking Proceedings, GC Docket No. 97-113, Report and
, 13 FCC Rcd 11322 (1998).

This matter shall be treated as a “permit-but-disclose” proceeding in accordance with the ex parte
rules.11 Persons making oral ex parte presentations are reminded that memoranda summarizing the
presentations must contain summaries of the substance of the presentations and not merely a listing of the
subjects discussed. More than a one- or two-sentence description of the views and arguments presented
generally is required.12 Other requirements pertaining to oral and written presentations are set forth in
section 1.1206(b) of the rules.13
For additional information on this proceeding, contact Kim Matthews,,
(202-418-2154), Pamela Gallant,, (202- 418-0614), or Mary Margaret Jackson,, (202-418-3641) of the Media Bureau, Policy Division. Press contact:
Janice Wise, (202- 418-8165).
- FCC -

11 NPRM, 27 FCC Rcd at 12494-95, ¶¶ 416-417; see also, 47 C.F.R. § 1.1200 et seq.
12 See 47 C.F.R. § 1.1206(b)(2).
13 47 C.F.R. § 1.1206(b).

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