The FCC should take the idea of making...

is antithetical to the stated purposes of the” Spectrum Act, said NAB. To coordinate the repacking, the FCC should create “an expert group of outside stakeholders” to test the software when it’s finished. “This proactive engagement will allow the FCC to have the confidence that its software is ready for prime time and will tap into the resources of various industries that are committed to seeing a successful auction,” said NAB. The repacking solution also needs to take the borders with Canada and Mexico into consideration, NAB said. Without new agreements with those countries, it will be “nearly impossible” for the FCC to reclaim enough spectrum “within 250 miles of the Canadian border and 150 miles of the Mexican border” because of interference issues, NAB said. It also urged the commission to appoint an “independent, third-party administrator” to oversee the process of reimbursing broadcasters for costs from the repacking. The TV Broadcaster Relocation Fund should be treated as a budget for the repacking, NAB said. “It is nonsensical to suggest that Congress only sought to cover some unstated portion of non-participating broadcaster costs as opposed to making them whole,” said NAB. The FCC should also process channel substitution applications submitted before the freeze on such applications, protect stations’ translators in the auction, and make its “latest thinking” on the incentive auction band plan available for public comment, NAB said. The FCC should also create a solution that provides adequate spectrum for wireless microphone operation, NAB said. The association is exploring the possibility of giving wireless microphones access to the duplex gap, and examining “the viability of LTE/wireless microphone coexistence in the upper 600 MHz band,” the ex parte said.