The Association for Maximum Service Television (MSTV) and the National Association of Broadcasters (NAB) disagree with assertions that over-the-air TV broadcasting is an inefficient use of spectrum and not worth keeping. In their comments in response the National Broadband Plan Public Notice #6 they argue TV broadcasters have already made significant advances in spectrum efficiency. In one 6 MHz channel they can now provide multiple video programs and, with the ATSC Mobile DTV standard recently approved, offer mobile TV services. "Unlike many mobile services, each television station transmits over its entire spectrum allotment during all or virtually all of each day: there are not peaks and valleys in transmissions." In addition, Mobile DTV services will be provided over broadcasters’ existing spectrum assignments.
MSTV and NAB note, "efficiency gains in television broadcasting have been accompanied by a reduction in the total allocation of spectrum to broadcast television, most recently through reallocation of nearly 25 percent of spectrum allocated to broadcasting at the conclusion of the DTV transition. Today, television broadcasting uses approximately 60 percent of the spectrum that it used in the 1970s, yet has managed to provide a four-fold improvement in the audio and video quality of its service. With the conclusion of the DTV transition, broadcast television is the first wireless service ever to substantially reduce its spectrum use while providing additional services. Meanwhile, broadcasters have worked with Sprint Nextel to transition the Broadcast Auxiliary Service ("BAS") in the 2 GHz band to a narrower, digital band plan that is making available an additional 35 MHz of spectrum for new Advanced Wireless Services and MSS."
MSTV and NAB's estimate of costs to shut down over-the-air TV broadcasting is much higher than that in the CEA funded study. They note that in the DTV transition consumers invested tens of billions of dollars in digital receiving equipment, including digital-to-analog converter boxes. This investment would be stranded if over-the-air broadcasting was shut down. "Perhaps more importantly, consumers would lose access to the free local programming, news, weather, sports, emergency services, mobile DTV, and other programming and services previously delivered over the re-allocated spectrum."
MSTV and NAB argue that unlike many commercial wireless services, "in the television broadcast service licensees already operate under a host of regulations to ensure that their use of the spectrum is 'fully utilized to maximize its total value.'" Unlike the Bazelon study, which focused on economic value, MSTV explains "In the broadcasting context, the 'total value' is not a strict financial measure, but rather one that encompasses the broader policy objectives described above, such as universal service, local journalism and public safety."
In response to the question in the Public Notice asking about spectrum for both fix and mobile wireless backhaul, MSTV and NAB point out that "one way to improve broadband access in rural areas is through the use of 'white spaces' spectrum between television channels for fixed broadband access." "Because the broadcast bands are used less intensively in rural markets, with appropriate technical protections fixed broadband services can operate in this spectrum without undermining consumers' access to free, over-the-air television or new mobile DTV services."
Additional spectrum can be made available for broadband without taking away over-the-air TV. MSTV and NAB reference the 2004 National Science Foundation study showing less than 20 percent of the frequency bands below 3 GHz were used over the course of a business day. A chart in the filing shows exclusively licensed bands below 3.7 GHz that will "provide for significant, new wireless broadband deployment by commercial providers in the coming years. A total of 507 MHz is available in these bands."
The MSTV and NAB comments make a strong case for maintaining spectrum for TV broadcasting, but without public support for broadcasting will the argument for TV's value beyond spectrum auction or subscription dollars be sufficient to stop reallocation of TV broadcast spectrum?
