The NAB and Association for Maximum Service Television (MSTV) March 18 asked the FCC to “resolve holistically the numerous complex and interrelated issues” involved in spectrum relocation in comments filed in response to the FCC Notice of Proposed Rulemaking (NPRM) on broadcast TV band innovation.
While the NPRM sought comment on three distinct issues, coprimary spectrum allocation for TV broadcasters and mobile services, voluntary channel sharing and proposed improvements to VHF broadcasting, the NAB and MSTV urged the commission to set as its goal “a robust American communications ecosystem that facilitates growth and innovation in both wireless broadband and broadcasting.”
The broadcast groups suggested a roadmap forward that takes into account a range of issues:
- assessing the ability of technology breakthroughs to make the wireless industry’s use of existing spectrum more efficient;
- completing and seeking comment on the results of a spectrum use survey;
- looking at the trade-offs of shifting spectrum from TV to wireless broadband use and potential harm to consumers and competition;
- exploring other ways to expand broadband access; and
- considering and seeking comment on closely related issues before acting on the items addressed in the NPRM.
Regarding the specific issues open to comment, the filing urged the commission not to act on coprimary spectrum allocations without addressing various interrelated issues. For example, the filing raised the issue that reallocation could impact future spectrum usage innovation by broadcasters and the interference rights broadcasters would have vis-à-vis wireless operations.
Regarding channel sharing, the comments agreed with the commission that any channel sharing must be voluntary. The NAB and MSTV also pointed out that the parties involved any channel-sharing agreement would be in the best position to resolve the complex issues raised by sharing a channel.
The broadcast groups also told the commission that although its proposal to authorize power increases may in some cases help high-VHF stations overcome reception problems, it is less likely that doing so will help low-VHF stations.
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