The FCC's rejiggering of TV station spectrum allocations as part of its broadband spectrum reclamation plan could adversely affect a third or more of all TV stations, according to the prepared congressional testimony of the broadcasting representative on the first of what will be several hearings on the issue.
Robert Good of WGAL-TV Lancaster, Pa., who wears a lot of hats as assistant general manager, director of operations and chief engineer for the station, is representing broadcasters at the Tuesday (April 12) hearing on spectrum issues being held in the House Communications Subcommittee, which is headed by a former broadcaster, Greg Walden (R-Ore.).
Good plans to tell the legislators that they need to recognize that reallocation and repacking of spectrum would impose "significant financial costs" and result in "a material diminution of existing free, over-the-air television broadcast service." He says a second digital transition could create "unprecedented" viewer disruption, confusion and dissatisfaction."
His message will be one of cooperation, however, with one big caveat. "Broadcasters do not oppose voluntary incentive auctions and the reallocation of broadcast spectrum, if, in fact, the auction and reallocation of broadcast spectrum is truly ‘voluntary,'" he says.
But the big issue is whether repacking and "voluntary" are mutually exclusive. "For an auction process to be truly voluntary, it must be voluntary both for those stations that elect to participate in the auction and for those stations that elect to retain their licenses and continue delivering to their communities the full panoply of benefits of the digital transition," says Good. But if the repacking is required of any station that doesn't want it, and that repacking materially diminishes the service, that clearly fails the broadcasters' "voluntary" test.
Good also paints a grim picture of potential loss from the combination of reducing broadcasters footprint now that the commission has allowed unlicensed devices to share the broadcast band.
"Now that the FCC has opened up broadcast bands for use by so-called ‘white space' devices," he says, "local stations and your constituents must now be prepared to cope with potential interference from literally thousands of new unlicensed devices. Further reductions in channel spacing would inevitably result in increased television interference and a reduction in the use by your constituents of unlicensed devices in white spaces. And if interference results from repacking, our viewers and your constituents would lose access to the broadcast programming they currently enjoy -- the full extent of that loss has not yet been determined by the FCC."
He also says the FCC's channel-sharing proposal, which the FCC says would be voluntary, would result in even more signal loss and viewer dislocation.
"[T]he above technical concerns do not begin to capture the problems that would result if broadcasters are forced by the FCC to share channels, as some have suggested," he says. "The technical challenges and costs associated with that proposal would be even more complex, and would impose even greater costs on stations and it would result in a greater loss by your constituents of local television broadcast service."
Good argues that broadcasting is a robust service relied on by 99% of the country--delivered over cable and satellite and online as well as over-the-air. He points to his stations multicast channels, which he says are not "marginal" services.
He also talks about the promise of mobile DTV. To date, Hearst has used its multicast spectrum in two markets to deliver network programming -- CW and ABC--to markets that lacked those network affiliates.
But Good ultimately strikes a cooperative tone. "Our company, the NAB, and broadcasters across the nation are prepared, nevertheless, to work cooperatively with the Committee, with other Members, and with the Commission to strike an appropriate balance in achieving the nation's overall communications policy goals."
The FCC has said the reclamation process and incentive auctions--compensating broadcasters for the move--would be voluntary, but the definition of "voluntary" continues to be the key to the debate. Broadcasters fear that reclaiming their spectrum to sell to wireless broadband suppliers will leave them at a competitive disadvantage in a digital world where their efficient one-to-many delivery system should be seen as a value-added, not a roadblock.