They can do all the planning they want (and they certainly should have it all figured out), but they won't get serious about broadcasting ATSC 3.0 until it is approved by the FCC for commercial use and tuners for ATSC 3.0 are sufficiently available to the general public.This isn't how I read the plan. Phase 1 markets will be scheduled for completion by July of 2018 (give or take). While some will undoubtedly file for waivers, I can't imagine that they'll be handed out without a fight.
What the NAB counters with doesn't change what the FCC has adopted and the fact that the FCC adopted the
plan suggests they weren't moved by the arguments.