TVStudy Input Error Leads to Undervalued Class A's, Padden Says
FCC TVStudy repacking software undervalues the coverage area of some Class A TV stations due to a flaw in how data on the stations is inputted, said the Expanding Opportunities for Broadcasters Coalition in an informal comment filed Friday. The incorrect data causes TVStudy to underpredict some Class A contours and interference, and would cause the affected stations to be undervalued in the auction or to experience interference issues on being repacked, EOBC Executive Director Preston Padden told us. It should not be hard for the FCC to correct the input error and fix the problem, and he expects that it will do so, Padden said. The EOBC's spotting an error in the software is an example of why the FCC has tried to be transparent about the incentive auction, an agency spokeswoman told us, saying the commission welcomed the EOBC filing.
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Unlike the previous edition of the commission's OET-69 software, TVStudy doesn't double the vertical antenna patterns of Class A's when it calculates their interference potential, said EOBC. Doubling those values has been a standard FCC practice for 10 years, and by not doing so TVStudy comes up with reduced coverage areas for the affected stations, Padden said. By redoing TVStudy's calculations with the error corrected, EOBC has been able to come up with interference predictions that closely match the stations' original coverage areas, said the group. The code of the TVStudy software shows that it isn't doubling the vertical antenna patterns, said Don Everist, president of broadcast engineering firm Cohen Dippell. Everist and his firm checked the software's code after being informed of Padden's filing by Communications Daily Friday.
Though loss of station coverage areas is one of the primary issues raised by NAB in its court challenge of the FCC auction order, Executive Vice President-Strategic Planning Rick Kaplan said the vertical antenna issue is only one of a host of problems with TVStudy. If the FCC fixes the calculation, it won't address many of the issues NAB has with the software, he told us. “This shows the peril of trying to change OET-69." While Kaplan said he would be happy if the FCC fixed the issue, the problem should reinforce NAB's arguments before the U.S. Court of Appeals for the D.C. Circuit, he said.
The error in interference calculation would be a serious problem for owners of Class A's if it isn't fixed, said Fletcher Heald broadcast attorney Peter Tannenwald. Stations that aren't participating in the auction would find themselves repacked with reduced coverage areas and false estimates as to the interference they would cause or receive, said Don Everist, president of broadcast engineering firm Cohen Dippell. Stations planning to participate would likely find their auction price lower than they deserved, since the Incentive Auction Task Force has indicated that prices in the auction will likely be determined by how much interference a station causes, said Tannenwald.
Fixing the problem should be relatively simple for the FCC, Padden and Everist said. The FCC could address the matter on reconsideration, suggested Kaplan, and others said an order on delegated authority is possible. The FCC declined to comment on how the filing would be addressed.