As expected, the National Association of Broadcasters (NAB) and the Association for Maximum Service Television (MSTV) disagree with the arguments that broadcasters are not using TV spectrum efficiently and that the spectrum would be better used for other purposes.
"Consistent with a consumer-focused approach to spectrum management, MSTV and NAB herein reject the notion put forth by a select few commenters affiliated with the commercial wireless industry—namely, that to achieve a world-class broadband ecosystem, one must curtail (or even eliminate) consumers' access to a free and robust over-the-air digital television service," the two associations said [PDF]
, in their reply comments to the "National Broadband Plan. "In fact, in today's blended digital-rich media environment, broadcasting and broadband are complementary services."
The organizations point out that Congress and the President have supported both broadcast TV and a national broadband plan.
They further note that "A small number of commenters, including CTIA, T-Mobile and Coleman Bazelon, suggest that the two goals embraced by Congress cannot or should not be pursued in parallel, and that one (local broadcasting) must be diminished to serve the other (broadband)."
NAB/MSTV stressed that these commenters have specifically requested that the Commission reallocate (in whole or in part) spectrum "that broadcasters already use efficiently to serve the public so that wireless carriers may provide ambiguously-defined services at some point in the future."
They conclude that "Such a tradeoff between two essential and complementary communications policy goals would not only be contrary to legislative intent, but it would be contrary to the public interest as well."
They organizations also reminded the FCC that most of the commenters have agreed with the NAB and MSTV in suggesting that the Commission look past "purely economic factors," and instead "put a premium on the public policy benefits of an existing spectrum use when determining the efficiency and value of that use."
They asserted that broadcasting is both a public service and public trust and that when assessing the role of off-air television, the FCC should be evaluating local broadcasting not only in economic terms (the enormous investment by broadcasters and consumers alike in switching over to digital transmissions), but should also think about "the core public interest goals that broadcasting serves."
The NAB/MSTV Reply Comments also look at the wireless carriers' use of their existing spectrum:
"In determining the efficiency of existing commercial wireless services, MSTV and NAB also encourage the Commission to look carefully at whether the spectrum already allocated and assigned to the commercial wireless licensees is being put to efficient and productive use. CTIA, Verizon, and Motorola argue that tower and cell citing issues, including modifications to existing radio sites, adding new sites, renegotiating leases with tower owners, the need for tower authorizations, and environmental and zoning requirements, present economic and practical problems to improving efficiency from existing spectrum bands. However, these same barriers would also hamper the commercial wireless carriers' build-out of reallocated spectrum, which would require the nationwide installation of new towers, transmitters, and receivers for the new spectrum frequencies. Consequently, there is no reason to reallocate hundreds of MHz of spectrum to commercial wireless carriers while significant swaths of the spectrum already available for wireless use remains underutilized. "
The two organizations concluded their remarks by asking the FCC to "reject proposals that would result in one important public policy goal, local broadcasting, being subordinated to another, broadband."
They stated further that the Commission "can, and should, pursue these two complementary goals in tandem to help ensure that the nation's spectrum resource is being used efficiently and effectively in the public interest."