Doug Lung /
12.03.2009 12:00AM
FCC Asks TV Broadcasters to Justify Spectrum
The FCC is looking for more spectrum for wireless broadband, and the spectrum currently used for TV broadcasting has emerged as a prime candidate. This week the commission gave broadcasters until Dec. 21 to justify the use of their existing spectrum.

In Public Notice (DA 09-2518): Data Sought on Uses of Spectrum [PDF] the FCC asked broadcasters to comment on "the impact to the economy if insufficient additional spectrum were made available for wireless broadband deployment, in terms of investments, jobs, consumer welfare, innovation and other indicators of global leadership."

Additionally it seeks comment on the impact to the country's economy and public welfare should off-air television coverage be cut to accommodate a repacking of stations as part of a spectrum recovery program.

Reducing coverage and repacking indicates the FCC may be considering reducing broadcast stations' coverage area to allow reuse of their channels at shorter distances. This could open up some additional channels, but from my experience, stations are already closely packed in some congested areas. In the northeast, for example, WCBS-TV in New York City and WFSB in Hartford share channel 33. WCAU in Philadelphia and WPXW-TV in the Washington D.C. suburb of Manassas, Va. share channel 34.

Under the heading "Potential Approaches to Increase Spectrum Availability and Efficiency" the Public Notice states, "There may be opportunities for broadcasters to share 6 MHz channels in a market without significantly disrupting the free over-the-air television service that consumers enjoy today."

The FCC recognizes this sharing would affect the "number and type [of] signals that each [station] can broadcast."

Some stations are transmitting two HDTV programs in the 19.39 Mbps available in one 6 MHz channel, but quality will suffer if the channels are transmitting material that's noisy, has a lot of action or is otherwise difficult to compress. While this sharing may be attractive to some stations, especially if they aren't broadcasting high definition, I'd hate to see it reduce the number of HDTV slots available for the variety of ethnic multicast channels available in markets such as Los Angeles, or the interesting and educational multicast programs available on many public TV stations.

Other suggestions to free up bandwidth for broadband include "greater collocation of transmission facilities closer to the center of densely populated areas;" improvements in MPEG-2 technology which would allow more programs in one 6 MHz channel; and spectrum efficiency gained by "deployment of next generation technologies over that currently achieved under the ATSC standard."

The FCC asks what would be required for broadcasters and consumers to transition to more advanced technologies, and how difficult would it be for them to make the transition, and also poses the question, "What would be the costs to replace off-air delivery to MVPDs and consumers with other means (fiber, microwave)?"

Receiver and antenna limitations influence channel allocations and power levels. The FCC recognized this and asks, "To what extent would establishing antenna and receiver standards facilitate spectral efficiency and improved reception in broadcasting?"

The FCC also requested comments on "What innovations in applications, services, or business models will create synergies between broadband and broadcast services, or other new value from currently licensed spectrum?"

One of the obvious innovations is mobile DTV. Streaming video and audio over the Internet individually to each viewer and listener requires a lot of bandwidth. The iPhone has had a significant impact on AT&T's network. Mobile DTV broadcasting has the advantage of using the same amount of bandwidth to reach thousands of viewers as one viewer requires streaming over the Internet.

The Public Notice challenges TV broadcasters to justify their use of the spectrum with questions such as "How do broadcasters use the capabilities of digital television today?" It seeks specific answers, including "data rate allocations to HD, SD, multicast streams, bandwidth leasing arrangements, etc. and the business rationale behind these choices."

The Commission also wants to know how broadcasters plan to use licensed spectrum in the future and how they should "evaluate the future economic value of off-air digital television and new capabilities to offer mobile DTV broadcasting."

It has been reported that Blair Levin, the person leading the search for more broadband spectrum, is talking not only to broadcasters but to their investors as well. It isn't surprising that the Public Notice asks, "How does the financial community in general view that future value?"

While the Public Notice makes it clear broadcasters have to justify the spectrum they have and suggest ways to improve efficiency in their use of it, the FCC also recognizes the value of broadcasting and asks for suggestions on how it can help broadcasters. For example, in reference to the migration of viewers from mass-market "appointment" viewing to more fragmented and time-shifted viewing, the FCC asked what it can do to help broadcasters "participate in this evolution?" This might be a reference to one suggestion that would give broadcasters bandwidth on wireless broadband channels.

In a proceeding that could have such a major impact on broadcasting in the United States and the relatively small in percentage—but large, in total number of off-air TV viewers—it's amazing the FCC is allowing only 19 days for comments.

Given the power and influence of the wireless companies that want this spectrum for their businesses, it is difficult to imagine broadcasters will make it through 2010 without some change in their channel allotments. While it will take some time to work out the details, the big question is whether these will be voluntary changes, such as broadcasters giving up spectrum for cable carriage rights, shared bandwidth on another channel and some financial compensation. Or would there be a ruling that essentially forced broadcasters off-air by some mechanism such as excessive spectrum fees in order to free up spectrum for the cell phone companies?

My worst fear is the FCC might allocate all of the UHF TV spectrum to the cell phone companies, requiring TV broadcasters to squeeze into channels 2-13, and limit broadcast content available to viewers by putting multiple stations on one channel when they run out of space in major markets such as New York, Washington D.C. and Los Angeles. Rural viewers, of course, would be out of luck due to interference zones between television markets when such a small number of channels were used. In any event, it seems likely that some, and perhaps many, broadcasters would have to move to another channel.

I'm hoping that unlike the original transition, which gave back 108 MHz of spectrum, broadcasters will not have to bear the entire cost of the channel changes needed to free up even more spectrum for auctioning to wireless providers.



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1.
Posted by: Brian Smith
Fri, 12-04-2009 - 9:58AM Report Comment
"My worst fear is the FCC might allocate all of the UHF TV spectrum to the cell phone companies, requiring TV broaders to squeeze into channels 2-13" That would certainly not be good. If a scenario like this were to occur, I would rather see it the other way around. Given the lack of stations that went back to their VHF channels, especially the lack of ones that kept their Low-V aloocations. Perhaps the FCC should first offer up the spectrum of channels 2-6 for these proposed "wireless broadband services". Why should the broaders who have occupied the spectrum for many years be the ones that have to suffer with those frequencies. Let the new-comers (wireless broadband industry) do some innovative work to try make that range of frequencies work for them.
2.
Posted by: Brian Smith
Fri, 12-04-2009 - 4:13PM Report Comment
Broad
3.
Posted by: Brian Smith
Fri, 12-04-2009 - 4:01PM Report Comment
broad broad broad
4.
Posted by: Brian Smith
Fri, 12-04-2009 - 4:01PM Report Comment
broad
5.
Posted by: Brian Smith
Mon, 12-07-2009 - 5:57PM Report Comment
This looks like another case of one size fits all to swash the entire country with a rushed together scheme that gets someone in high place a guaranteed future career position. In the major cities, this scheme of kicking the broadcasters out of the UHF spectrum (and maybe leaving them the VHF spectrum which the computer wifi folk do not want) will probably make some companies very rich. Out in the more rural stretches, where there is insufficient population density to provide the wifi at really affordable prices the providers and services will be much fewer with the excuse that the areas are not economically viable. DTV has barely been economically viable in many of the more rural areas, these are areas where the population are often less affluent. NTSC should have been left in place in some of these areas for the full power stations, guess we should be thankful that the repeaters were not yet touched. With Washington wisdom these areas will be treated the same as the major metropolitan areas and we can be certain there will be no "public service" clauses for the new spectrum occupants to consider, and no free EAS dissemination to any of the poorer classes will be mandated for either urban or rural areas as the wifi providers will demand to be able to recoup all their new investments as soon as possible.
6.
Posted by: Brian Smith
Tue, 12-08-2009 - 10:35AM Report Comment
Has the FCC already forgotten that this spectrum is already being shared with medical monitoring devices? Will any of the new wifi and cell phone services be required to provide notification and coordination with every medical care facility in the same manner as broadcasters have? This is in addition to the wireless microphones used by both broadcasters and non-broadcasters (churches, school plays, etc.) and remote camera pickups? How many pounds will fit in the 5-lb. bag? Definitely sounds likely that someone is looking forward to cushy wifi provider careers after they leave the commission. If they hurry we can create as much communications chaos as preceeded the sinking of the Titanic, maybe in time for its 100th anniversary!
7.
Posted by: Brian Smith
Fri, 12-04-2009 - 3:06PM Report Comment
It appears that the FCC is for sale and companies developing wireless gadgets have purchased them. And why not, they need to have more spectrum to rollout more new wireless gadgets so that they can focus on selling the product rather than making the previous device work. I love that they cloak all of this under the umbrella of jobs and global leadership when in reality it is just unbridled greed. Shame on a government "of the people by the people for the people" for throwing away an open and free service in favor of closed pay services. If this happens I would expect to see people dressed as Native Americans at Boston Harbor throwing their smart phones and wifi devices in the water.
8.
Posted by: Brian Smith
Fri, 12-04-2009 - 3:01PM Report Comment
Test broad
9.
Posted by: Brian Smith
Fri, 12-04-2009 - 2:09PM Report Comment
Not sure why my initial posting had the "er" removed, but it was there. Really, I wasn't using the term "broader."
10.
Posted by: Brian Smith
Fri, 12-04-2009 - 2:06PM Report Comment
Perhaps the question the FCC should be asking, and not of the broaders but of the end users, is what value does the viewer place on the broader’s use of the spectrum? Boise, Idaho has 5 "full-service" commercial stations and 1 PBS station, all running multiple program streams. Two of the full-service commercials are owned by the same company. Is the use those four companies are putting the spectrum to of any value to the average viewer? I suspect many would answer as I would, with a resounding NO. And bear in mind, I don't have any cable or DBS service. The only unique programming coming from these folks is local “news,” and while I appreciate the (ever shrinking) number of people that part of the various operations employs, I don't see the endless stream of feel good stories and sensational sweeps series as providing me any value, especially as I (and everyone else) is a part owner of that spectrum, a fact which too often seems lost to the broaders. Almost anything I might see from those broad operations I can legally watch on the internet through various means, some free and some at a cost to me. And while the FCC is at it, maybe they should take a good, long look at radio in the aftermath of consolidation. While I realize an alignment in that industry would in no way provide the sort of bandwidth the FCC is looking for, it would be a good idea to put the radio broaders under the same microscope in the interest of fairness. Is having four country radio stations, playing the exact same type of music, owned by the same company a good use of that spectrum?
11.
Posted by: Brian Smith
Mon, 12-07-2009 - 5:41PM Report Comment
There are many ways to view news like this: 1) A conspiracy to knock out broadcasters from the get-go by rushing in a system that was never truly tested in a big city market using real world conditions affecting average non-technical viewers prior to its adoption; 2) The power of lobbyist's payoffs. Since no one in Washington seems to understand anything technical and they just suppose that everything digital will magically work just fine regardless of how many simultaneous assignments are issued for the same spectrum; 3) a chance to start over career-wise and install/maintain multiple transmitter sites across the nation (which may also be rushed into service without first doing any homework to really work out details for a workable (ie successful) game plan, and to especially exclude all poorer classes of citizenry who would be unable to buy into any such services and continue to pay their rent and health care etc.; 4) an opportunity for all the pirate stations to really have a field day buying up obsoleted broadcast transmitters at a song and since they know the FCC does nothing to stop them anyway, they just go on the air in whatever portion of the spectrum they wish (with all of the legal broadcasters out of their way) and a fully installed receiver-equipped public; 5) an opportunity to start the next digital transition now, replacing MPEG2 with some more highly compressed system, replacing 8VSB with some system more immune to multipath, maybe dealing with some of the lip sync issues before selling the set-top converter boxes and new receivers. The consumer electronics manufacturers will drool with delight at the notion of selling another round of new boxes that they can plan to obsolete in another five years before they come up with some other scheme to hack away more spectrum. With sufficient compression we should be able to cram all of the existing broadcasters into the channels 2 through 5 and 7 through 13 spectrum by giving them each 1.25 MHz allo
12.
Posted by: Brian Smith
Sun, 12-06-2009 - 4:16PM Report Comment
Am I reading this correctly? After we all but beat the TV stations to death (financially) for a technology that won't pay for itself for who knows how long, only to make the stations change channels (and transmitters and antennas) and be forced to spend another zillion dollars (let alone engineering and legal costs) so that little Johnny and Muffy can text more and spend more useless time staring at their I-Phones? Oh boy, more ways for the public to be distracted by driving too. About time the stations grew a pair of big ones and tell the FCC to go take a long walk off of a short dock!
13.
Posted by: Brian Smith
Fri, 12-04-2009 - 6:25PM Report Comment
Perhaps if the broadc a s t e r s had been a little more concerned with giving something back to the "of the people" and a little less concerned with satisfying their own greed, we wouldn't be having this conversation. So the FCC is being paid off by Google, ATT, Verizon and Company? And that would be different than when they were owned by the NAB how, exactly?
14.
Posted by: Brian Smith
Fri, 12-11-2009 - 11:31AM Report Comment
No mention of compensating viewers for having to go buy ATSC when a proposal such as this could make it virtually impossible to successfully receive it. No mention of forcing the proposed new services provide any equivalent to "public service", sounds as if the FCC is now inhabited by folks who just think all monetary issues for consumers and broadcasters are inconsequential, that everyone in this country can or wants to buy pay per view services as if the streets were paved with gold. What do they bump off next when they still find there is not enough spectrum to do everything wireless with computers?




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