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April 12, 2011
Dennis Wharton
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Testimony of Robert Good Before the House Subcommittee on Communications and Technology

WASHINGTON, DC -- Robert Good, chief engineer of WGAL-TV in Lancaster, Penn., is scheduled to testify this afternoon before the House Energy and Commerce Subcommittee on Communications and Technology in a hearing titled "Using Spectrum to Advance Public Safety, Promote Broadband, Create Jobs, and Reduce the Deficit."

Below is a transcript of his oral testimony as prepared for delivery. Click here for a copy of his written testimony.

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Good afternoon Chairman Walden, Ranking Member Eshoo, and Members of the Subcommittee.

My name is Bob Good, and I am the Assistant General Manager, Director of Operations, and Chief Engineer of WGAL-TV in Lancaster, Pennsylvania. I am testifying on behalf of Hearst Television Inc., which owns and operates 29 television stations across the country, including WGAL-TV.

Less than 2 years ago, during the DTV transition, billions were spent upgrading facilities, purchasing converter boxes for viewers, and educating viewers of the impending switch. In the process, the FCC repacked the television band and local broadcasters gave back 108 MHz of spectrum, freeing up space for public safety and new commercial wireless services. From over-the-air, HD signals to new multicast channels, broadcasters across the nation are providing a more diverse and richer viewing experience.

Free, over-the-air local broadcast television is not only the nation�s most watched and trusted platform for local news, virtually every local station, including mine, works hand-in-hand with first responders to provide public safety information in times of local emergencies.

Local broadcast television is relied upon by 99% of the American people. In fact, some 43 million Americans depend exclusively on free, over-the-air broadcasts as their only source of television. Many of those viewers are impoverished, elderly, live in rural areas, or are members of an ethnic minority. These are our viewers and your constituents, and it is essential that Congress not leave them behind in the consideration of spectrum reallocation.

I am an engineer and I�m here to offer an overview of WGAL�s DTV transition experience and a real world perspective on some of the technical issues that would accompany another repacking of existing broadcast spectrum.

The FCC's staff and the wireless industry propose to remove 20 of the current 37 channels in the UHF broadcast band. This would be a reduction of more than 50% of existing UHF broadcast channels. The consequences of that proposal, if implemented, would be staggering.

The reallocation of channels is not a simple matter of flipping a switch. The substitution of one channel in one market will create a domino effect across the entire country. One channel change in Chicago, for example, will require channel changes in Kalamazoo, which will require changes in Lansing in turn affecting Detroit and so on and so forth.

The Lancaster market is bounded by 5 other television markets, including both Philadelphia and D.C. After the repacking following the DTV transition, our station was initially authorized to transmit at a low power level to protect other stations from interference. That created significant gaps in our over-the-air coverage and many of our long-standing viewers lost WGAL. Even some cable systems, with their tall towers and high gain antennas, lost over-the-air access to our signal. That prevented them from retransmitting our station to their subscribers. Within days of the transition, we received thousands of viewer complaints�and we still do.

Today, we still have not reached a point where our station�s coverage replicates our pre-DTV service area. We are not sure, frankly, if it ever will. We have petitioned the FCC for several power increases, and we have plans to install 6 new translator stations at a collective cost of at least another $1.5 million. That�s on top of the $2.5 million we already spent on the DTV transition. Local viewers have also incurred additional costs by having to buy new home antennas to receive our VHF digital signal.

Unfortunately, this new repacking proposal has the potential to be more difficult. This time around any repacking process would start with fewer alternative channels to assign to stations and the likelihood of greater interference from more closely packed channels. Also, due to the FCC's white spaces decision, we now have to contend with thousands of new unlicensed devices that have been authorized to operate in television bands.

Additionally, during the DTV transition, we had the luxury of operating two channels simultaneously � one analog and one digital. This time, broadcasters would have to make a "flash cut" because additional channel capacity no longer exists. That means that viewers will not have adequate time to prepare for another repacking. The level of service disruption to your constituents could be unprecedented.

Broadcasters take their public stewardship commitment seriously, and we look forward to expanding and enhancing the important service our industry provides to you and your constituents. We will continue to work with the Committee to strike an appropriate balance in achieving the nation's overall communications policy goals.

Thank you. I will be happy to answer any questions you might have.

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