The NAB and Association for Maximum Service Television filed comments with the FCC Dec. 22 rejecting calls for television broadcasters to give up some or all of their spectrum to accommodate future demand for wireless services and rebutting the presumption that the commission must choose between the two as it puts together its National Broadband Plan.
The filing delivers a counterpunch to those who have argued for reallocation of broadcast spectrum and takes direct aim at a report submitted to the commission Oct. 23, 2009, from The Brattle Group that estimated the value of the benefit consumers would enjoy from repurposed broadcast spectrum for wireless broadband service at more than $1 trillion.
According to the filing, the Brattle report suffers from several defects, including ignoring the social benefit of TV to the public and overlooking the costs and delays in reallocating spectrum, particularly when mobile DTV can immediately address the need for mobile video services.
Perhaps the biggest issue, however, is “a crucial fact of technology that has been assiduously ignored, as well as a pernicious myth that has been advanced in this proceeding,” the filing said. That fact is “the case for more broadband spectrum is based primarily on demand for mobile services,” the filing said. However, the point-to-multipoint architecture of broadcasting “is a far more efficient means” of delivering real-time, live video than the point-to-point architecture of wireless service, it said.
The myth “pervading this proceeding,” the filing said, is the notion that only households that exclusively receive over-the-air TV have a stake in OTA television and that pay TV subscribers would be unaffected if the commission were to reallocate broadcast spectrum. If the proposals to reduce or eliminate spectrum for TV broadcast service were to be acted upon, it “is inconceivable that … pay-TV subscribers would receive anywhere near the same amount, quality and diversity of local services-local journalism, local emergency information and alerts, and a variety of local voices-as they do now,” the filing said.
The filing pointed out:
• Tens of millions of pay-TV households have additional sets that rely exclusively on OTA broadcast service.
• The commission should assume that local broadcast content, such as local news and local emergency alerts, would continue to be available if there were no or marginalized OTA service.
• Free OTA lets consumers choose “to stop paying for expensive cable or DBS subscriptions.”
The filing also included a study sponsored by NAB and MSTV from two Purdue University engineering professors. In it, the authors James Krogmeier and David Love argue that future forecasts for wireless broadband spectrum needs based on the ITU spectrum model “are flawed, or at best, high suspect.”