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NAB2FCC: Don't Redesignate Full TV Band
11/20/2013

WASHINGTON — The broadcast lobby sent an Away Team to the Portals this week to urge regulators to resist the urge to open the entire broadcast TV band up for mobile wireless operations. This wholesale co-designation was first proffered in the 2010 Notice of Proposed Rulemaking pertaining to channel-sharing and improved VHF performance.

Rick Kaplan, Jane Mago and Bruce Franca of the National Association of Broadcasters—all former FCC staffers themselves—met with members of the FCC’s International Bureau and Office of Engineering and Technology. The NAB Away Team “addressed the International Bureau’s ongoing advocacy in domestic and international working groups for adding a mobile allocation across the entire current broadcast television band, regardless of the amount of spectrum recovered in the upcoming incentive auction,” an ex parte filing on the meeting stated.

They “reminded” Bureau staff that the co-designation was the subject of two open proceedings, including the channel-sharing and incentive auction dockets.

“Thus, not only has the commission taken no action on this issue, it has affirmatively raised the question and could decide in the near future that it would be improper (sic) to designate the entire broadcast televise band for broadcast and mobile services,” the filing stated “NAB urged the Bureau not to exceed its authority, and to maintain a neutral position on the question of allocations, until it receives further clarification from Chairman [Tom] Wheeler an the commissioners through the rulemaking process already under way.”

The team also said adding a mobile wireless designation to the entire TV band was unnecessary.

“There is simply no reason to add such an allocation beyond the spectrum that is repurpose din the auction,” the filing stated “ The broadcast band is already tightly packed, and will be more so post-auction, with full-power, low-power and Class A broadcasters, plus their translators, wireless microphones, public safety users and unlicensed devices in the unused white spaces. There is no room for commercial mobile services.

“The only apparent purpose of this proposed allocation, therefore, is to suggest that the commission has future plans to remove from the band those broadcasters remaining after the voluntary incentive auction. Even if that were the case—and NAB strongly objects to any further reduction in the ability of free, over-the-air broadcasters to compete—the commission could always add the mobile allocation at a later date  when any other portion of the band was repurposed.”

Also see... April 11, 2012, “NAB Asks FCC to Delay Spectrum Redesignation
“Giving co-primary priority to wireless services across the entire broadcast band is unprecedented on both a national and international level.”
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