In early December, the Federal Communications Commission released a Public Notice requesting public input specific data on the use of spectrum currently licensed to broadcast television stations. The FCC is seeking market-based mechanisms for television broadcasters to contribute to the broadband effort any spectrum in excess of that which they need to meet their public interest obligations and remain financially viable. This inquiry also seeks to understand what processes and incentives could ensure continuing spectral efficiency gains for broadcasters going forward.
The Telecommunications Industry Association (TIA) says the expansion of next-generation wireless broadband is vital to our nation's economic, healthcare, education, security, public safety, transportation, defense, and environmental priorities. For this reason, the FCC's examination of existing spectrum usage is crucial, given the recognized wireless broadband spectrum shortfall our nation faces as demand for terrestrial wireless broadband continues to dramatically increase. TIA urges the Commission to create a new, innovative, and technology-neutral spectrum band plan, and commends its focus on evaluating the relative public benefits of spectrum allocations for over-the-air broadcast television versus those of wireless broadband.
Certain that the demand for wireless broadband spectrum will outstrip supply, AT&T called on the federal government to determine whether additional spectrum, including that now used by TV stations, should be shifted to wireless broadband. In comments filed today at the Federal Communications Commission, the wireless giant says the need for additional wireless broadband spectrum has been thoroughly documented.
Microsoft and Dell filed joint comments urging the FCC to ensure that its consideration of reallocating broadcast spectrum promotes rather than retards its parallel efforts to improve broadband availability by advancing consumer access to unlicensed broadband technologies below 1 GHz. They say the National broadband Plan should recommend that the FCC: 1) ensure consumers have access to both licensed and unlicensed spectrum below 1 GHz for broadband services and 2) move forward quickly to give consumers unlicensed access to underutilized television band spectrum.
The Public Broadcasting Service (PBS), Corporation for Public Broadcasting (CPB), and Association of Public Television Stations urge the FCC to pursue a national broadband strategy that recognizes the enduring and complementary role of free, over-the-air digital public television in serving the educational, informational, and cultural needs of the public, including especially young children and their parents. Given that the public television community relies intensively on digital broadcasting and broadband to serve children, parents, teachers, and the broader public, the groups are concerned by proposals that would diminish access to broadcast services in the name of improving access to broadband services. PBS, CPB and APTS urge the FCC to pursue a national broadband strategy that advances access to, and adoption of, broadband and promotes the public's interest in noncommercial educational programming and services broadcast on a free, over-the-air basis by the Nation's public television stations.
In taking any action concerning repurposing of the current broadcast spectrum, the National Public Safety Telecommunications Council recommends that public safety, public service and enterprise use of the 470-512 MHz band allowed by the current rules and waivers granted by the FCC be fully protected. If the Commission decides to maintain DTV operations in the band, NPSTC urges the FCC to move forward and provide for additional flexibility for public safety operations in the 470-512 MHz band as recommended in the previously filed NPSTC Petition for Rulemaking. Should the Commission instead decide to repurpose the broadcast spectrum, NPSTC recommends expanding public safety, public service and enterprise use of the 470-512 MHz band throughout the country.
The National Religious Broadcasters says it thinks that spectrum reassignment might be illegal and will disproportionately impact Christian TV broadcasters.
The Benton Foundation, Office of Communication, Inc. of the United Church of Christ, Campaign Legal Center, Center for Rural Strategies, Public Knowledge, Media Access Project, Main Street Project, New America Foundation, and United States Conference of Catholic Bishops filed joint comments reminding the FCC that if it had completed its enhanced disclosure proceeding in less than the eight years it took to do so, it would have had accumulated actual facts regarding broadcasters' programming from broadcasters themselves, and from the public. That the Commission is seeking information in this proceeding about public interest programming indicates the value of and need for the systematic method for gathering information about such programming put forth in the enhanced disclosure decision. The Commission also should review the record created in its localism proceeding for useful information on public interest programming, and ensure that decisions made in this proceeding are consistent with decisions made in the localism proceeding. Future decisions on ownership rules are also interwoven with this. Many of the commenters have informed the Commission in other dockets of the disservice to community needs and interests already caused by past loosening of ownership limits; before making any further changes in ownership rules which will not be undone later, the Commission should evaluate the public interest obligation issue raised in its localism proceeding as well as this Inquiry.
Television broadcasting is one of the "twin pillars of the digital economy," complementing wireless broadband service as a means for distributing of mobile video, according to a study commissioned by the National Association of Broadcasters and the Association of Maximum Service Television. What's more, the 44-page study says, TV broadcasting is far more efficient at delivering mobile video. "Experts project that mobile video will dominate traffic over mobile broadband networks in the coming years, with up to two-thirds of broadband usage growth forecast to be from video," it says. "Broadcasting is the most spectrally efficient way to meet this need," it says. It can deliver "real-time video to a larger number of users in the same geographic areas and is superior to unicast solutions by orders of magnitude." Broadcasters led by NAB and MSTV are dead set against giving up any of their spectrum. The study the two trade groups commissioned, authored by electrical engineers James Krogmeier of and David Love, also argues that the FCC is looking the wrong way when it looks at broadcast spectrum to meet what it believes will be rapidly rising demand for and an eventual shortage of wireless broadband spectrum. TV uses just a "small fraction" (5.18 percent) of the spectrum between 225 MHz and 3700 MHz and the medium has already given up 140 MHz through its DTV transition and ENG microwave transitions, the study says. Meanwhile, it says, there is 750 MHz of non-broadcast spectrum in the 225-3700 MHz band currently available for licensed broadband use. "A substantial amount of [it]...is either currently unused or only beginning to be used by wireless operators."
J. H. Snider plans to address the claims of television broadcasters that lack any connection to the truth. His planned topics include:
1) Free TV is free.
2) Broadcast TV is efficient.
3) TV broadcasters are committed to TV broadcasting.
4) Broadcast TV is a technology leader.
5) The best way to save broadcast TV is to kill it.
6) TV broadcasters will sacrifice profits to protect consumer investment in broadcast TV equipment.
7) TV broadcasters object to FCC official Stuart Benjamin's arguments based on economic reasoning.
8) TV broadcasters provide close to $10 billion in public service announcements each year as public compensation for their spectrum.
9) TV broadcasters provide a meaningfully "local" service based on the information needs of a democracy.
10) TV broadcasters want to engage in a serious discussion about the future of the broadcast TV band.
The Consumer Electronics Association and CTIA -The Wireless Association say they know how to preserve over-the-air broadcasting, including high definition, while freeing up spectrum for wireless broadband. But it will take a radical remake of the current broadcasting system. In a filing at the Federal Communications Commission on spectrum reclamation, the pair said it would require re-engineering a system that now depends on full-power stations with interference protection that leaves too many channels unused. Instead, they say, the government could change the current high power-high tower system into a low-power network of multiple transmitters that would allow stations to operate close to each other and free up channels for other uses. The groups argue that could free up 100-180 MHz for mobile broadband, while leaving consumer equipment intact and allowing broadcasters to continue to use all of their 19.4 mbps data stream and 6 MHz channels. They also say broadcasters should not be asked to cover the cost of such a transition. Though they concede there would be some disruption as broadcasters went from one transmitter to a network of them, they add that would be balanced against the value of freeing spectrum for other uses.
