Broadcasters have offered up arguments to the FCC for why the government should not be in a rush to reclaim their spectrum to feed the wireless beast, including that they remain the home of educational programming and news and emergency information.
Some spectrum reallocation proposals include a total reclamation from commercial, noncommercial and low-power license holders in exchange for some kind of continued mandatory cable/satellite carriage regime combined with a government subsidy for multichannel subscriptions.
In joint comments to the FCC, the National Association of Broadcasters and the Association For Maximum Service Television said the FCC should not simply focus on broadcast frequencies when it looks for wireless spectrum, but should look at those already allocated for wireless, including the 100 mHz broadcasters have already given up in the transition to digital.
That comes amidst a host of comments by tech and wireless companies on the need to look high and low, including in government bands as well as the broadcast band, for more spectrum to meet the need for speed as apps get more bandwidth-hungry and wireless broadband becomes a bigger factor in the broadband deployment equation.
According to a study submitted to the FCC by the Consumer Electronics Association (though not endorsed by it), broadcasters are sitting on $62 billion worth of spectrum that could be turned into $1 trillion in broadband benefits if it were reallocated to wireless broadband.
But broadcasters argue that their value is not simply a matter of dollars and cents. "In the broadcasting context, the 'total value' is not a strict financial measure," they argued, "but rather is one that encompasses the broader public policy objectives such as universal service, local journalism and public safety."
If there value were not more than spectrum deep they argue, and public interest value was not factored in, "the television broadcast service would have different technical and economic characteristics; among other points, it likely would not be free and available to all Americans, especially in more sparsely populated areas. Thus, as in the public safety context, to ignore the public policy goals underlying the television broadcast service would lead to spectrum management decisions that disserve the public interest."
In comments in three separate dockets--two wireless inquiries and the overall broadband deployment plan--NAB and MSTV pointed out that the government, TV, consumers and equipment companies just made a multi-billion dollar investment in the DTV transition. That included over $1.5 billion to make sure that a fraction of the audience that still relies on the over-the-air signal could still get that signal.
Responding to the FCC's identification of "prime" spectrum bands below 3.7 Ghz (where broadcasters reside), they said that any bias toward singling out that spectrum would not provide an "accurate assessment" of what is available. And that even if the government does focus on that spectrum, which has attractive propagation properties for wireless, there is already a lot of it available, most reclaimed from broadcasters in the digital switch including the re-auctioned lower 700 mHz band spectrum.
They said the priority should be to make more efficient use of the spectrum already allocated for wireless and that wireless should not be seen as a substitute for wireline broadband, which can deliver higher speeds.
And when the FCC is assessing the productivity and efficiency of spectrum, it should put a premium on the public service productivity of broadcasters, including "local journalism, universal service, availability of educational programming, and timely and reliable provision of emergency information."
Finally, they said, the commission should reject reallocation scenarios that "would strand substantial investments by consumers in receiving equipment, and/or leave consumers without access to service upon which they regularly rely."