With an eye on the upcoming FCC Broadcaster Relocation Fund Workshop on June 25, 2012, the Advanced Television Broadcasting Alliance (Alliance) believes spectrum sharing in principle is good, but the intended plan of execution is faulty and will not work as intended.
“The FCC is developing plans for stations to share spectrum, as part of the overall pending spectrum auctions as authorized by Congress,” said Alliance spokesman, Lee Miller. “Spectrum sharing is something the Alliance believes is necessary, but the proposed implementation will not work.”
The Alliance, formerly the Coalition for Free TV and Broadband, says limited sharing has already taken place in the television industry through LMA’s (Local Marketing Agreements) and other legal sharing plans.
The Alliance is proposing the Broadcast Overlay Plan, which would permit stations, whether full power or low power, to share spectrum with wireless broadband providers through flexible use and alternative modulation schemes. This Plan, if adopted, would provide a quantum leap in the amount of usable spectrum for both broadcasters and the wireless industry and go a long way in meeting the future needs of wireless providers.
The Alliance, however, does not believe that sharing spectrum using existing modulation standards will work. Here are some examples:
- If two full power stations share their 6Mhz bandwidth and both opt for HD channels, there would be little or no spectrum left over for other SD channels and mobile.
- If both full power stations share a single channel, then both would be entitled to a continuation of must-carry rights on cable, which cable interests might find coercive.
- The financial incentive of sharing the proceeds of auctioning one of the channels might be totally inadequate compared to the potential revenues from continued operations of both channels.
- There is little incentive for a Class “A” station to share with another Class A or with a full power. Should they be granted “must-carry” status if they participate, beyond the current, restrictive, guidelines. The answer currently seems “No!”
- Many Class “A” stations depend on multiple channels to pay the bills by leasing time to ethnic, religious, or minority programming groups, and could not make it with one channel.
- LPTV has little protection under the auction authorization law. Even if the FCC permitted LPTV stations to share, the resulting, single programming channel would likely fail for the same reason Class A stations need multiple channels to survive.
- Channel sharing is the “kiss of death” for mobile television.
- ATSC 2.0, if adopted, would nearly double the bandwidth capacity of the spectrum, but there is little established base for H.264 capable receivers.
The Alliance believes in sharing, but sharing that is less regulated, offers greater flexibility, and opportunity to explore new modulation types such as LTE (compatible with current wireless technology) and/or OFDM (offering huge expansion of capacity).
We believe that Congress and the FCC should look for ways to help grow the Broadcast Industry, instead of writing its obituary. For instance:
- For the remaining half of the 6,600+ low-power translator stations who have yet to convert to digital, open up what remains ($24M) of the digital conversion fund so they can meet the 2015 deadline.
- Finish the FCC spectrum inventory and release the AOM report on how all of this is to work.
- Make it abundantly clear what the FCC’s intentions are toward LPTV. All evidence given thus far seems to indicate nothing but nefarious intentions.
- Give broadcasters the freedom to work with new technologies and to experiment with new partners such as wireless and explore new business models.
- Process the pending applications, issue the CP’s that are languishing on desks in Washington, so that the industry can grow and not shrink.
- Assure the broadcasters of America, that you have their best interests at heart and believe in a strong future for broadcasting and that you are not waging a war of attrition.
The Alliance believes in sharing, but in an open and free marketplace. That is the American way. Untie our hands, so we can help usher in a new era of freedom through the airwaves.
