Article 7FHS Attention, TV Licensees: The Pre-Auction Technical Certification Form Has Been Approved

Attention, TV Licensees: The Pre-Auction Technical Certification Form Has Been Approved

by
FHH Law
from CommLawBlog on (#7FHS)

One more step toward the incentive auction ...

Form%20318%20PRA.JPGLate last year we reported on a draft of Form 2100, Schedule 381. That's the form (technical title: "Pre-Auction Technical Certification Form") to be completed and filed by (a) all full-power and Class A TV licensees entitled to mandatory protection in the upcoming incentive auction as well as (b) those with Commission-afforded discretionary protection. (Don't worry if you're not sure whether you're in the universe of those who will have to file: the FCC is going to be releasing, possibly by the end of this summer, an "Eligibility Public Notice" spelling out the facilities that the Commission believes to be entitled to protection.) 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.

The latest news: The Office of Management and Budget has approved Schedule 381, so the form is now technically "effective". It doesn't appear to have changed significantly since our December, 2014 report on the draft. You can check out a copy of the schedule on the OMB website.

The deadline for completing and filing Schedule 381 has not yet been set. It's expected to be announced in the Eligibility Public Notice. Still, many if not most affected licensees presumably know whether or not they'll be on the list. Anybody likely to be on the list would be well-advised to take a close look at the form - NOW - and begin to gather the necessary information. Some should be relatively easy - transmitter and antenna specs in particular. Other stuff, not so much. F'rinstance, do you know when the last structural analysis of your tower was performed? How about the structural standard under which that analysis was performed? (Hint: Two possibilities are TIA 222-Revision F and TIA 222-Revision G. There's also a general "Other" option - you're on your own for that one.)

The information gleaned from Schedule 381 will be used by the Commission 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. Additionally, the completed forms will provide the FCC with a comprehensive database of all the specific transmission equipment (transmitters, antennas, transmission line) currently in use, a database which will be used in determining relocation reimbursements.

In other words, Schedule 381 information will be central to the incentive auction process and its aftermath. That being the case, everyone will be best served if that information is collected and reported with the utmost accuracy.

Check back here for further developments as they arise.

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