FCC: Reply Innovation in the Broadcast Television Bands: Allocations, Channel Sharing and Improvements to VHF

Media Alliance, National Organization for Women Foundation, Benton Foundation, the National Hispanic Media Coalition, and Campaign Legal Center (collectively, “Media Alliance et al.”), by their attorneys, the Institute for Public Representation, submit this reply comment to comments filed in the Federal Communications Commission’s (“FCC” or “Commission”) notice of proposed rulemaking in Innovation in the Broadcast Television Bands: Allocations, Channel Sharing and Improvements to VHF (the “Notice”). Media Alliance et al.’s reply emphasizes the need for the Commission to collect data to assess the impact of broadcast service loss. Additionally, the FCC should consider the impact channel sharing will have on its ownership rules and not foreclose opportunities for ownership by new entrants, including minorities and women.