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REPLY COMMENTS OF APTS, CPB AND PBS IN THE MATTER OF SPECTRUM...

Reply Comments of APTS, CPB and PBS in the Matter of Spectrum Incentive Auction, August 28, 2015

The Public Broadcasting Service (“PBS”), Association of Public Television Stations (“APTS”), and Corporation for Public Broadcasting (“CPB”) (collectively, “PTV”) supports efforts to maximize the options for television stations to continue serving their communities over-the-air after the incentive auction and repacking process have concluded. Accordingly, PTV agrees with other commenters that the Commission’s channel sharing rules should provide stations with as much flexibility as possible, regardless of whether a particular channel sharing agreement is entered into in connection with the incentive auction or at a later time.

As explained in PTV’s prior comments, channel sharing is not a panacea. Sharing a channel may dramatically limit HD and multicast capabilities, potentially impinge coverage areas, and restrict the option of deploying new services of vital importance to local communities. Nonetheless, PTV agrees that operating on a shared channel may in some circumstances be one means of preventing the emergence of unserved areas lacking any public television service. As other commenters have explained, many of the proposals in the channel sharing NPRM released on June 12, 2015, could help make channel sharing a more feasible option in some cases. But there are additional steps the Commission can and should take to provide potential channel sharing partners the flexibility and clarity they need with respect to their rights and obligations.

To read the filing, click here.