1. Panel on Methodology for Repacking Members: Lynn ClaudyWilliam Meintel Bruce Franca James Ocon Mel Frerking Joseph Snelson Ira GoldstoneByron St. Clair John McCloskeyJohn Viall 1

2. Topics  Response to Question 1 Review of OBI modeling and assumptions Industry studies and results  Response to Questions 2-5 DTV service and interference issues Interference protection rules Modeling and service rules Viewing practices  Response to Question 6 Impact of channel sharing 2

3. Question 1  Summarize status of our new modeling efforts and review assumptions behind them  OBI study presents two scenarios: 2:1 Channel Sharing  120 to 60 MHz recovered Repacking (without channel sharing)  42 to 6 MHz recovered 3

4. OBI Study  Only limited summary results of scenarios presented Total number of TV stations differed in all six scenarios (1743-1824?) Unclear what spectrum recovered?  Basic trends show: Protecting Border stations has significant impact on the amount of spectrum recovered  120 to 60 MHz for 2:1 Channel Sharing  42 to 6 MHz for Repacking Impact on viewers function of amount of spectrum recovered 4

5. Industry Study Results  How many DMAs are impacted and have stations that must share channels? More complete impact of channel sharing covered in Question 6 ScenarioStations Required to Share Channel with Another Station Number (Percentage) of DMAs where Sharing Required Full Power, LM, No Class A, No Border Protection 12442 (20%) Full Power, LM, Class A, No Border Protection 28166 (31%) Full Power, LM, Class A, Border Protection 36685 (40%) 5

6. Review of OBI Study Assumptions  Considers only full power DTV stations Different Number of Stations in All Six Results  Does not take into account Class A TV stations, LPTV or translators  Lists amount of “recoverable spectrum” but not its location (VHF or UHF or both?)  Uses three U.S. Border conditions No restrictions and protecting only current “active” allotments appear unrealistic  Unclear whether results include Public Safety/Land Mobile protection 6

7. Population Losses from OBI Studies Scenario Border Condition Recoverable Spectrum Stations with Service Loss Ave. Pop. Loss/Station Total Pop. Loss* (Millions) OBI 2:1 Sharing Results Treaty/ Agreements 6055837,74121.0 Active allotments 7262943,09727.1 No Border Restrictions 12088456,90450.3 OBI Repacking Results Treaty/ Agreements 613018,0842.35 Active allotments 4239437,97814.9 No Border Restrictions 4238638,85915 * Population Loss is equal to stations with service loss multiplied by average population loss per station. Viewers losing multiple channels are counted based on the number of channels lost. Therefore, a viewer that losses two channels is counted the same as two people that lose 1 channel each. 7

8. What’s Missing/Needed from Analysis?  A complete scenario that assesses impact by progressively adding conditions  What is the impact of recovering 120 MHz from UHF band?  Factors considered 1735 full power DTV stations* Protection of Public Safety/Land Mobile 520 class A LPTV stations* Canada/Mexico treaty obligations  Determine what the impact is and where it occurs? Goal is to determine trends * Consistent database used /totals include stations in continental US only 8

9. Industry Repacking Studies  Study Assumptions: Locate all broadcast operations between TV channels 2 and 30 Retain existing TV channel 2 to 6 stations operations (but do not add more low VHF operations) Full Repacking allowed within channels 7 to 30  Repacking based on reduced station spacings (190 km for both low and high VHF and 180 km for UHF, adjacent channel 10 -70 km) All studies protect existing LM operations Studies done with and without class A TV stations Studies done with and without protection of border operations 9

10. Industry Study Results  How many stations can not be given a channel assignment and must share with another station?  Minimum number of stations that must share are two times the number shown in second column 124 X 2 = 248 stations compares closely with 204 stations in OBI study ScenarioStations Not Accommodated and Required to Share Channel with Another Station Full Power, LM, No Class A, No Border Protection 124 Full Power, LM, Class A, No Border Protection 281 Full Power, LM, Class A, Border Protection 366 10

11. Summary of Industry Results  Adding Class A has impact similar to border protection More than doubles number of stations required to share Markets impacted increase from 20% to 31%  Protecting Class A stations and protecting border stations Increases the number of stations that must share from 124 to 366 (factor of 3) Increases the number of markets where sharing occurs from 20% to 40%  All scenarios include markets where greater than 2:1 sharing is required and markets where 100% of stations must share 11

12. 12 DMAs Where Sharing Required Full Power, LM, Class A, Border Protection DMAs where ALL stations must channel share

13. Question 2 & 3  Question 2 - How could the TV service and protection standards be adjusted for more efficient packing of channel assignments? Co-channel, adjacent channel interference Noise-limited service areas, planning factors Maximum allowed facilities  Question 3 – Are today’s interference protection rules still relevant? 13

14. Background  FCC decisions throughout DTV transition based on “replication of service” concept FCC’s ATSC standard decision DTV Table of Allotments and Assignments DTV viewer notification requirements  Supports viewer expectations 14

15. 15 Background (Analog/DTV IX Differences)  Analog Interference can increase by about 8 dB before viewer “sees” difference Interference can increase by about 20 to 30 dB before picture “unusable” Normal Analog Picture Analog TV with Varying Interference

16. 16 Background (Analog/DTV IX Differences)  Digital Most DTV sets went from perfect picture and sound to no picture or sound in 1 dB Several DTV sets went from perfect picture and sound to no picture or sound in 1/10 th of a dB  Suggests more careful approach to interference [See OET DTV Receiver Report at 15.2-15-3 for analog/digital description] No Signal Normal Digital Picture DTV with Interference

17. Background  Interference governed primarily by DTV receiver performance Currently only co-channel and adjacent channel restrictions apply to DTV 17

18. 2007 FCC DTV Receiver Study 18

19. Question 2 & 3 Response  DTV based on co-channel and adjacent channel protection only  Technical evidence suggests other factors could impact DTV service More power for High VHF channels Interference concerns from N±2, IM, Multiple interferors, etc.  Changes/adjustments not likely to result in “more efficient packing of channel assignments” but require additional protections and have opposite effect  Current rules still relevant 19

20. Question 4  Are there better models or better rules? 20

21. 21 Question 4 Response  Different propagation models are available Results may be different in specific cases but expected to be similar overall No indication other models more accurate on the whole than Longley-Rice No indication they would lead to more efficient plan or recovery of more spectrum  VHF Planning Factors should be reviewed  Margins should be considered for DTV

22. Question 5  Should protected service areas be adjusted to more accurately reflect viewing practices and, if so, how? 22

23. 23 Question 5 Response  Should protected service areas be adjusted to more accurately reflect viewing practices and, if so, how?  From a technical view, difference between analog and digital has an effect Issue is not the “protected contour” but the fact that some viewers may not have adequate DTV receive margin (either indoor or outdoor) because of the cliff effect  In overlapping markets, it is difficult to accurately assess viewing practices of the viewers in that region

24. Question 5 Response  35 million NTIA coupons redeemed 64 million coupons requested 50 million DTV converters sold according to CEA  Nielsen reports 10.9 million over-the-air ONLY homes  Hispanic households, for example, has a higher percentage of over-the-air viewing (Nielsen) 20% in LA 35% in Houston 28% in Phoenix 24

25. 25 Question 6  What are the impacts on channel- sharing?  OBI Report: “We are not suggesting that channel sharing would be the right approach for all broadcast stations …” p. 23

26. Impact of Channel Sharing Scenario Stations Required to Share Channel Number/ (Percentage) of Markets where Sharing Required Number of Markets where Greater than 2:1 Sharing Required Number of Markets where 100% of Stations Required to Share 2:1 Number of Markets where 80% or more Stations Required to Share 2:1 Full Power, LM, No Class A, No Border Protection 12442 (20%)458 Full Power, LM, Class A, No Border Protection 28166 (31%)51018 Full Power, LM, Class A, Border Protection 36685 (40%)122129  Channel sharing required in many markets  In some markets, all or most stations have to share 26

27. 27 DMAs Where Sharing Required Full Power, LM, Class A, Border Protection DMAs where ALL stations must channel share

28. 28 Question 6 Response  Amount of channel sharing required is related to the amount of spectrum recovered and the protections included  Channel sharing impacts large number of stations especially in the larger DMAs Impacts or eliminates current and future DTV services