CTIA – The Wireless Association® Comments on Updated OET-69 Software - Incentive Auctions

Sep 4, 2026

Uploaded by Eden

CTIA – The Wireless Association® submits comments supporting the Federal Communications Commission’s efforts to update the OET Bulletin No. 69 (OET-69) software used to analyze coverage and interference for full-service digital and Class A television stations. CTIA argues the updated software will be critical to the incentive auction process and highlights improvements including user flexibility, faster computations, better interoperable outputs, and updated terrain and population databases. CTIA also encourages completion of the repacking algorithm for public review.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages23

Reading Time58 min

AccessFree to download

Introduction and Summary

CTIA supports efforts to update the OET-69 software

OET-69 software as a critical component of the incentive auction process

Improvements over past iterations

More accurate rendering of TV station coverage

The Commission can and should employ updated software in implementing the Spectrum Act

The Commission should still work toward providing the complete repacking algorithm for public comment

Conclusion

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of Office of Engineering and Technology Releasesand Seeks Comment on Updated OET-69 Software Expanding the Economic and Innovation Opportunities of Spectrum Through Incentive Auctions )) )) )) )) ) ET Docket No. 13-26 GN Docket No. 12-268 COMMENTS OF CTIA – THE WIRELESS ASSOCIATION® March 21, 2013 Michael F. Altschul Senior Vice President and General Counsel Christopher Guttman-McCabe Vice President, Regulatory Affairs Scott K. Bergmann Assistant Vice President, Regulatory Affairs Krista L. Witanowski Assistant Vice President, Regulatory Affairs CTIA – The Wireless Association® 1400 Sixteenth Street, NW Suite 600 Washington, DC 20036 (202) 785-0081 I. INTRODUCTION AND SUMMARY ....................................................................1 II. CTIA SUPPORTS EFFORTS TO UPDATE THE OET-69 SOFTWARE.............2 A. OET-69 Software Will Likely Be a Critical Component of the Incentive Auction Process...................................................................................................3 B. The New OET-69 Software Offers a Variety of Improvements Over Past Iterations..............................................................................................................5 C. Modifications To The OET-69 Software Will Result In A More Accurate Rendering Of TV Station Coverage.....................................................................9 1. Boston Example............................................................................................. 10 2. Chicago Example........................................................................................... 13 3. Washington DC Example..............................................................................15 III. THE COMMISSION CAN AND SHOULD EMPLOY UPDATED SOFTWARE IN IMPLEMENTING THE SPECTRUM ACT....................................................17 IV. THE COMMISSION SHOULD STILL WORK TOWARD PROVIDING THE COMPLETE REPACKING ALGORITHM FOR PUBLIC COMMENT............20 V. CONCLUSION......................................................................................................21 Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of Office of Engineering and Technology Releasesand Seeks Comment on Updated OET-69 Software Expanding the Economic and Innovation Opportunities of Spectrum Through Incentive Auctions )) )) )) )) ) ET Docket No. 13-26 GN Docket No. 12-268 COMMENTS OF CTIA – THE WIRELESS ASSOCIATION® I. INTRODUCTION AND SUMMARY CTIA – The Wireless Association® (“CTIA”)1 respectfully submits these comments in response to the Office of Engineering and Technology (“OET”) Public Notice seeking comment on the release of the updated OET Bulletin No. 69 (“OET-69”) software.2 This software provides analysis of coverage and interference of full-service digital and Class A television stations in accordance with OET-69, and will likely be an important tool in the Commission’s broadcast television incentive auction process. CTIA supports the Commission’s efforts to update elements of this software, and notes that the new software offers a variety of improvements over past iterations. The new OET-69 software allows for: (1) additional user flexibility; 1 CTIA – The Wireless Association® is the international organization of the wireless communications industry for both wireless carriers and manufacturers. Membership in the organization includes Commercial Mobile Radio Service (“CMRS”) providers and manufacturers, including cellular, Advanced Wireless Service, 700 MHz, broadband PCS, and ESMR, as well as providers and manufacturers of wireless data services and products. 2 Office of Engineering and Technology Releases and Seeks Comment on Updated OET-69 Software, Public Notice, DA 13-138 (Feb. 4, 2013) (“Public Notice”) . (2) faster compu

FAQs

What is the purpose of the updated OET-69 software discussed in the comments?

It provides analysis of coverage and interference for full-service digital and Class A television stations in accordance with OET-69, supporting the broadcast television incentive auction process.

What improvements does CTIA highlight for the new OET-69 software?

CTIA cites additional user flexibility, faster computations, improved outputs usable in other software, and updated terrain and population databases enabling more consistent and accurate calculations.

How does CTIA relate the software update to the Spectrum Act and repacking process?

CTIA states the updates support the Spectrum Act’s directive to preserve coverage areas and population served, and it encourages completing and releasing the repacking algorithm for public comment.

Sep 4, 2026

Uploaded by Eden