Responses to clarification questions on ISED’s 600 MHz — Proposed TV Transition Objectives and Methodology

A1. ISED is reviewing the current certificate application process in an effort to streamline the process during the transition.

A2. While ISED does not currently anticipate significant changes to the current DTV rules and framework as a result of the 600 MHz repacking, some technical parameters will be updated to reflect the repurposing results, including the frequency range for the TV broadcasting service.

A3. ISED intends to release the joint allotment plan and the joint transition plan, and identify daisy chains / station dependencies shortly after the U.S. incentive auction concludes. It is important to note that this will also mark the beginning of the transition. The two SOI documents are expected to be released within 30 days of the allotment plan release.

A4. Though similar, Canada has proposed slightly different transition priorities and objectives from those proposed by the U.S. (e.g. Canada's priority is to allow additional time for Canadian stations to transition, whereas the U.S. priority is to clear stations in the 600 MHz band). The joint Canada‑U.S. transition plan and schedule will be developed to account for and balance the transition needs and priorities of both countries. Canadian and U.S. stations that have dependencies will be treated equally.

A5.  The potential for temporary interference occurs when there is a mix of stations operating on their pre‑repacking channel and post‑repacking channel within geographical proximity. In the worst case scenario, temporary interference may be present from the on‑air testing period of phase 1 until the completion of the transition, although this is highly unlikely. Furthermore, in ISED's proposal:

• temporary interference is limited to 2% pairwise (i.e. station‑to‑station) during the transition; and
• potential interference exceeding 2% pairwise will be confined to the on‑air testing periods and mitigated by coordination among broadcasters involved in a linked‑station set (i.e. stations that could potentially interfere with others transitioning in the same phase).

A6. The joint Canada‑U.S. transition plan and schedule has not yet been finalized. While ISED proposes to extend the transition in Canada beyond 39 months with additional phases, the relationship between TV stations and mobile deployment is part of transition framework negotiations.

Q7a) Can ISED elaborate on what is meant by stations with "Canadian only dependencies" which would not cause interference to other stations?

A7a)

• Stations with "Canadian‑only dependencies" include stations that have dependencies only with other Canadian stations.
• Stations with "no dependencies" include stations that do not have any dependencies with any other Canadian or American station.

Q7b) Will stations with "Canadian‑only dependencies" be treated differently than those with "no dependencies"?

A7b) ISED has proposed to schedule stations within both of these groups in later phases to allow additional time for their transition. Stations with "no dependencies" were proposed to be scheduled later than those stations "with dependencies" as they have less of an effect on the overall transition schedule and do not impact the ability of other stations to change channel and/or convert to digital. The actual station dependencies for individual stations will not be determined until the new channel assignments are known after the conclusion of the U.S. incentive auction.

Q7c) How will the "regions" be selected or defined?

A7c) The intent is to group stations based on the main market they serve, despite the physical location of their transmitter. For example, stations physically located in Gatineau (QC) or Ottawa (ON) whose main market is the National Capital Region would be part of the same region.

A8. Similar to the calculation of additional interference used in the repacking process, the temporary 2% additional interference is calculated with respect to the baseline interference‑free population of the current station. The baseline interference‑free population is defined as the population within the noise‑limited bounding contour (NLBC) predicted to receive service.

Q9a)  How will ISED ensure that the maximum number of Canadian stations will retain their existing channel assignments in the new joint allotment plan?

A9a) Channel assignments are part of the repacking process. The repacking system will use optimization techniques to determine a final television channel assignment plan. In addition to satisfying the constraints outlined in the SOI, stations will be repacked based on maximizing the number of stations assigned to their current channels instead of being assigned to new channels. The same optimization algorithm will be applied to all Canadian and U.S. stations to ensure that stations in both countries are treated equally.

Q9b) Will moving U.S. stations in the mobile band first increase the extent or duration of temporary interference to Canadian stations?

A9b) The impacts will not be known until the close of the U.S. auction. However, depending on the configuration of the new DTV allotment plan, moving U.S. stations in the mobile band first may increase the extent and duration of temporary interference to some Canadian stations. On the other hand, scheduling Canadian stations in later phases may also increase the extent and duration of temporary interference to some U.S. stations. The transition plan and schedule will be developed to account for and balance the transition needs and priorities of both countries.

A10. "Month 0" refers to the publication of the new DTV allotment plan.

A11. ISED recognizes the broad range of industry personnel necessary to successfully implement the transition plan, including broadcasters, broadcast consultants and engineers, radiofrequency and structural engineers, equipment manufacturers and suppliers, and other support companies.

ISED engaged broadcasting equipment manufacturers, tower rigging companies, as well as structural engineering consultants to better understand their capacity, capabilities and plans for the transition. This information has been used to develop proposed objectives and methodology for the transition plan.

A12. In July and August, ISED engaged several Canadian firms that provide tower-related services. Based on these discussions, we understand that there are at least 22 tower crews in Canada. While all tower crews may not be readily available to work on high power, tall broadcast towers, the majority of broadcast structures in Canada are less than 100 metres high and are low power. We also understand that the skillset could be transferrable over time with experience gained during the transition.

Furthermore, tower crews from the U.S. and other countries may also be interested in working with Canadian broadcasters during the transition, which would further supplement the number of tower crews available to work on the transition in Canada.

A13. For stations that share a tower, there may be benefits in using the same tower crew already on site. It can help to efficiently streamline tower tasks associated with multi‑tenant sites, while avoiding multiple crew‑mobilization and demobilization and multiple rigging and de‑rigging of the tower. Through discussions with tower rigging companies, ISED was advised that significant time could be saved in cases where multiple stations on the same tower are modified at the same time.

A14. As per ISED's Decision on Repurposing the 600 MHz Band, regular power TV stations operating in the to‑be‑repurposed 600 MHz band will be permitted to continue using their current channels and modes of operation until the spectrum is required for the deployment of mobile broadband services. Notification will be issued when displacement is required as a result of mobile deployment. Stations located in urban areas will be granted a one‑year minimum notification period and those located in all other areas, a minimum of two years. This one‑year or two‑year displacement notification may overlap with the scheduled transition date, depending on timing (i.e. schedule and mobile service deployment).

The joint Canada‑U.S. transition plan and schedule has not yet been finalized. Part of Canada‑U.S. negotiations on the transition framework involves the relationship between Canadian TV stations and U.S. mobile service deployment.

A15. ISED, in collaboration with the FCC, will develop a joint transition plan and schedule, with defined dates for stations to transition to new channels and/or convert to digital. Furthermore, ISED has dedicated resources to help ensure that the administrative requirements associated with the transition do not impede its implementation.

A16. Due to the complexity of the transition process, temporary increases in permissible interference levels are required to address sequential dependencies between stations in the same or adjacent markets. The potential for temporary interference occurs when there is a mix of stations operating on their original channel and post‑repacked channel. A temporary additional increase in pairwise interference between stations of up to 2% is proposed during the transition. This would also apply to stations that are not changing channel.