The Advanced Television Broadcasting Alliance (“ATBA” hereby replies to initial comments submitted in response to the Notice of Proposed Rulemaking released June 16, 2015 (the “Vacant Channel Notice” or “NPRM”). The NPRM proposes to reserve auctionable spectrum and hold it for unlicensed use in perpetuity. In the process, it will eliminate existing broadcast service and preclude broadcasters from modifying or expanding coverage over time to adjust to shifting populations. See the entire document here –  ATBA Vacant Channel Reply Comments 4843-1013-4826 v.2