Still a work in progress, but an excellent opportunity both to see what the FCC has in mind  and also to suggest possible improvements to the form before it takes final shape.

A couple of weeks ago we reported on a Federal Register notice announcing the start of a two-month period for the filing of comments about a new FCC form (Form 2100, Schedule 381, to be exact – a/k/a “Certification of TV Broadcast Licensee Technical Information in Advance of Incentive Auction”). We noted then that no copy of the form was included in the Federal Register notice and that our request for a copy (emailed to the Commission) had gone unanswered, so we couldn’t shed much light on what the form might look like.

We got word earlier today that the form is indeed available and, sure enough, when we emailed the Commission again asking for a copy, we got one lickety-split. Here’s a link to what was sent to us. (Actually, we received a Word version, which we have converted to PDF.)

As a quick glance indicates, it’s still something of a work in progress. That’s to be expected when the FCC invites comments on a form: by definition the form is subject to change based on the comments that get submitted. So here’s your chance to take a look at the Commission’s current draft and chip in your two cents’ worth.

As we noted previously, Schedule 381 is designed to provide the Commission assurance that the technical profile of the television industry as reflected in the FCC’s database is accurate. That’s obviously important because that profile will be used both to identify the facilities to be sold in the reverse auction and to form the starting point for the spectrum repacking effort which is the ultimate goal of the auction. Secondarily, the completed forms will provide the FCC with a comprehensive database of all the specific transmission equipment (transmitters, antennas, transmission line) currently in use. The detailed information about equipment will be used in determining relocation reimbursements.

All full-power and Class A TV licensees entitled to mandatory protection in the auction – and those with Commission-afforded discretionary protection – will have to complete and submit Schedule 381. Those folks all presumably have an idea of who they are, but they will know for sure when the FCC issues its “Eligibility Public Notice” spelling out the facilities that the Commission believes to be entitled to protection. The notice will specify a deadline by which protected licensees will have to submit Schedule 381. (We’re guessing that that won’t happen before the late summer of 2015, but you never know.) Completion of the form will entail a number of separate and distinct chores.

Database Certification. A licensee’s “Eligible Facilities” will be those specified in a specific authorization file number that will be pre-filled in the Schedule 381 for each station. Each respondent will have to review that authorization and confirm that the authorization accurately reflects the facilities actually used by the station. Additionally, respondents will have to do the same for

all underlying technical data that sets forth the operational parameters of the Eligible Facility, including but not limited to technical information that may be found in the Commission’s Consolidated Database System and Antenna Registration System.

Ideally, the precise metes and bounds of that latter category – referred to as “Database Technical Information” – will be tightened up some before the form is finalized. CDBS and ARS are, after all, fairly expansive databases in which a wide variety of not-necessarily-consistent information “may be found”. Since the FCC will be asking respondents to certify to the accuracy of certain information, the respondents should be given the clearest possible direction as to what information they’re certifying about.

Once the authorization and all the Database Technical Information (DTI) have been reviewed, the respondent will have to certify that one of three circumstances applies: (1) the authorization and DTI are all consistent with themselves and with the station’s actual facilities; (2) the authorization and the DTI vary in some respects; or (3) the station’s actual operating facilities differ from those specified in the authorization/DTI. In the latter two events, explanatory exhibits must be included.

(Also, if the station’s facilities don’t match up with the authorization/DTI, the licensee will have to apply for (1) a minor mod – to bring its authorization into conformity with its facilities – and (2) an STA to operate with its variant facilities until its mod application is granted. But note that that won’t affect the facilities protected in the auction/repacking process: each licensee can expect to be protected only to the extent of the parameters set out in the Eligibility Public Notice.)

Since review of the authorization and DTI really can’t get started until the authorization is identified and the notion of DTI is clarified just a bit, it’s probably too early to worry about that end of things just yet. But it’s not too early to gather the information sought by the rest of the form.

Information on Eligible Facility. As currently drafted, the second and final chunk of the form asks for details about the equipment currently used in the station’s transmission system:

Transmitter. The “main” or “primary” (the form uses both descriptives) transmitter must be identified by make and model number (no dashes or spaces, thank you very much), and its maximum power output capacity according to the manufacturer’s specs must be provided. You will also have to indicate whether it’s solid state or tube.

Antenna. No need for make/model number, but you will have to specify (from a list of options) what kind of antenna it is (e.g., slot, panel, batwing, etc.) and how it’s mounted (e.g., top-mount, side-mount, candelabra, etc.). If the options listed in the form don’t cover your particular antenna, you’ll have to provide an explanatory exhibit. You’ll also have to say whether it’s a broadband unit – that is, whether it can operate over multiple channels – and, if it is, you’ll have to provide its frequency range. And the Commission wants to know whether you’re sharing the antenna with another station and, if so, which station (call sign and Facility ID number, please).

Transmission line. In this portion, you’re supposed to say whether your transmission line is flexible or rigid – no real problem there – and if it’s rigid, you’re supposed to indicate the “length sections”. But then the form adds parenthetically that “If no single component consists of 90% or more of the entire transmission system, include an explanatory Exhibit.” We suspect that the term “entire transmission system” may refer to the “entire length of transmission line from transmitter to antenna”, but we’re not sure.

Antenna Support Structure. And the last portion involves the station’s antenna support structure. In its current draft the form first asks “In what year was the last structural analysis conducted on the structure?” The possible answers are “select year” or “other”. It’s not clear how you could answer a question starting with “in what year” in any way that does not involve selecting a year but, of course, if you were to pick “other” you’d have to provide an explanatory exhibit.

The second tower question is “Under what structural standard was the last structural analysis conducted?” Your choices: TIA 222-Revision F, TIA 222-Revision G, and (of course) Other. Again, an “other” answer requires an exhibit.

And the third question: Does the respondent licensee own the tower and, if not, who does?

It seems like that third question might be more usefully moved up to the first question. After all, if you’re just a lessee on a tower, will you necessarily know when the last structural analysis was done? And even if you happen to know the date, how likely are you to know the structural standard used? It seems far more likely that the tower owner, rather than its lessees, will have that information. And if that’s the case, why not ask first if the respondent/licensee is the owner? If it is, then it can answer the follow-up questions; if it isn’t, it can provide the tower owner’s contact information for the FCC to follow up with.

Virtually all of this information will probably need to be assembled by a competent engineer (although, as noted, the tower structure information will most likely have to be obtained from the tower owner). Again, it’s extremely important that the description of the station’s actual facilities be accurate because that description will be an important determinant in calculating the licensee’s relocation reimbursement. While the particular way in which the Commission asks for this information may ultimately be revised somewhat from the current draft of Schedule 381, it’s pretty definite that this is the information the Commission will be looking to obtain one way or the other. If you have suggestions that might improve this information collection process, now would be a good time to let the FCC know.

And the bad news for those of you who happen to be using a distributed transmission system (DTS): you’re going to have to complete a separate Schedule 381 for each separate transmitter/antenna.

Again, let us emphasize that the form is still in a formative state: nothing is etched in stone, and input from the folks who will eventually be subject to the form may prove useful both to themselves and to the Commission. We encourage one and all to go through it carefully and let the FCC know what you think.

So there you go – Form 2100, Schedule 381, all set for review and comment. If you have any suggestions, you’ve got until February 2, 2015 to let the Commission know.