NAB attorneys and engineers expressed concerns about the interference analysis...

of Engineering and Technology, NAB said it had “serious reservations” with the a Public Notice released last week that contemplated changes to its previous software, called OET Bulletin No. 69. The changes would invite “unnecessary delay into the process and would cause widespread uncertainty for broadcasters who may be deciding whether to participate in the auction,” the ex parte notice said. The trade association has three central issues with the FCC’s plan to update the software. First, it said proposed changes to the software’s methodology appear to violate the act of congress that gave the FCC the authority to hold the incentive auction. That law referenced OET-69. Second, the proposed changes may need to be made at the commission level, not at OET, it said. “Given the high profile nature of the incentive auction ... it makes better sense to explore such changes, if at all, in the sunlight of the full commission.” And third, the NAB said it’s the wrong time to update OET-69. “It creates instability in the process that can only serve to undermine the auction,” it said. “NAB does not oppose an in-depth examination of improving coverage and interference prediction methodologies,” it said. “This proceeding is not an appropriate forum because, beyond speeding up the processing of the nationwide repack ... the package of changes contemplated are highly unlikely to yield any appreciable benefit” for any auction stakeholder, it said.