Intel miscalculated the “level of congestion” in the UHF band above Channel 37 in comments filednin the incentive auction proceeding, said NAB in an ex parte filing Thursday (http://bit.ly/13Yciuq). TMobilenlater used the same bad data in its own filings, said NAB. “The result inadvertently distorts thenbreadth of the challenge of repacking broadcasters." The inaccurate filings demonstrate “how little is commonlynunderstood about the task of relocating broadcasters who do not participate in the auction,” NABnsaid. In a study filed in docket 12-268 in March (http://bit.ly/WKg7Dl), Intel said 98 percent of TV marketsnhave three or fewer stations above Channel 37, which NAB said suggests that the 600 MHz band is muchnclearer than it really is. “More than one-third of all full power and Class A TV stations (602 out of 1702 stations)nin the UHF band are located above channel 37,” NAB said. Instead of basing its study on DMAs, Intelnused each station’s city of license as its market, leading to “nonsensical results,” according to NAB.n“The more appropriate approach would consider the effect of repacking through a DMA lens,” said NAB.nThe Intel study “considers Florida stations licensed to Leesburg and Melbourne to be in different marketsndespite the fact that the stations are located at the same transmitter site,” said NAB. The Intel study alsoncontained “the head-scratching conclusion that Fairbanks, Alaska, is the most congested TV market in thennation,” NAB said. Intel said in an email Friday that its study is “directly derived from the FCC's own databasenof broadcasters” and that it had discussions with NAB about the study before filing it that “generatednno objections to use of the same FCC city-aggregated data.” Intel also said it concedes in its filing thatn“rigorous analysis of adjacent market interference will be necessary” to create a working band plan. The data from the Intel study were referenced by T-Mobile in reply comments filed in 12-286 earlier this monthn(http://bit.ly/11GXoVg). “According to Intel’s analysis, in 59 percent of markets, there are no broadcastntelevision channels above Channel 37,” said T-Mobile in comments outlining its proposals for a 600 MHznbandplan. “Obviously, in those markets, 84 MHz can be made available without clearing or repacking anynbroadcasters at all,” said T-Mobile. T-Mobile did not comment. NAB said the record needed to be correctednso the communications industry and the commission can “work from the same page to properly analyzenand address the enormous challenge of repacking and relocating broadcasters.”
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