Not surprisingly, when the model was used to see how much spectrum could be recovered by repacking existing full power stations, only 6-42 MHz of spectrum was found to be available for reallocation, depending on inclusion or exclusion of border restrictions. The Paper notes that the FCC staff and contractors have been developing a new Allotment Optimization Model (AOM) to achieve the NBP's goal of taking 120 MHz from the 294 MHz (240 Mhz) after removing three channels for land-mobile and television Channels 2 through 6 currently assigned for TV broadcasting. I'll highlight a few examples, but urge you to read the document and draw your own conclusions. The analysis glosses over data that refutes the National Broadband Plan's (NBP's) recommendation for taking away broadcast spectrum and makes unjustified assumptions to support them. Critical information is missing and conclusions are presented as fact when data doesn't support them. That is why upon critical reading I was so disappointed to find this attractively presented Paper to be biased, incomplete, and, in some ways, inaccurate. During the 40 years I've been involved with broadcasting, FCC reports were, with few exceptions, unbiased, accurate and complete. I have great respect for the engineers whose names are on the report. This week the FCC released a paper, Spectrum Analysis: Options for Broadcasting OBI Technical Paper No.
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