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Reply Comments of PBS, APTS and CPB on Defining “Commencement of Operations” in the 600 MHz Band, May 18, 2015

The Public Broadcasting Service (“PBS”), Association of Public Television Stations (“APTS”), and Corporation for Public Broadcasting (“CPB”) (collectively, “PTV”) hereby submit these reply comments in response to the Commission’s Public Notice seeking comment on certain aspects of the “procedures governing the transition of broadcast television services and other operations out of the 600 MHz Band” as a result of the incentive auction and repacking. In particular, PTV commends the Commission for proposing a transition process that would allow television translator stations—including those operated by noncommercial public television station licensees—to continue providing important services to their communities until it becomes genuinely necessary to displace the station for a new 600 MHz Band licensee that is launching commercial service. As many of the commenters recognize, the proposal to allow continued operations is a good step in achieving the Commission’s “central objective” of ensuring that spectrum is put to its “highest and best use” by minimizing the amount of time valuable spectrum is permitted to lie fallow. Accordingly, the Commission should adopt its proposals that (1) a 600 MHz Band licensee “commences operations” in an area when the licensee begins site commissioning tests and (2) a notice that a 600 MHz Band licensee has commenced operations covers only “the area served by the licensee’s commercial service infrastructure deployment.”

To read the filing, click here.