RTG, Verizon Wireless and Vulcan Wireless filed comments with the FCC yesterday (July 28th) opposing the application of CW Television Stations Inc. (“CW”) for a displacement construction permit to move Station K62FS (Port Townsend, WA) from Channel 62 to Channel 51.

As RTG, Verizon and Vulcan support an immediate application and licensing freeze for all Channel 51 broadcast operations, these parties request that CW’s application be amended to move Station K62FS to a lower channel. Absent such an amendment, CW’s application should be dismissed or denied.

The application is the latest example of the sharply escalated Channel 51 licensing activity that has occurred since Auction 73. These Channel 51 applications, including for low power translator stations, complicate interference issues and impede A Block network planning and design. A Block licensees cannot plan effectively for unknown future broadcast operations that either need to be protected or that they need to be protected from (nor can they garner the full and timely ecosystem support that is essential for equipment development), and having to accommodate such operations makes A Block mobile broadband deployments unfairly cost-prohibitive (ultimately to the detriment of consumers).

Granting authority for new Channel 51 operations disrupts the deployment landscape of Channel 51 stations, making the interference profile worse for A Block licensees and delaying the introduction of new wireless broadband services in the band.

To avoid further harm to A Block licensees, better serve television viewers, enable a greater range of wireless services to consumers, and promote the public interest, the FCC should dismiss or deny the Application unless it is amended to move Station K62FS to a lower channel.

Click here for a copy of the comments.