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National Broadband Plan emphasizes wireless technology, subscription-based business models

The National Broadband Plan from the FCC has been released to the public, and within its 376 pages, it outlines a path to expand broadband access across America. The plan not only attempts to predict the proliferation of new technologies 10 years down the road, but it also looks to the past to find examples of improvements to technology that have fostered new markets and businesses that did not previously exist. Although the FCC is not actively participating in developing these technologies, it is trying to carve out spectrum space to make room for them.

Where will it come from?

The FCC has set a goal of opening up 300MHz of spectrum within five years and 500MHz within 10 years. The burning question for broadcasters is, where will this spectrum come from? Many people think of the airwaves as they do water: It’s everywhere, so how can it be limited? And when you look at a frequency chart, the broadcast TV bands really stand out.

The FCC plans to obtain spectrum from a number of sources, including the Wireless Communications Service Band, the Advanced Wireless Services Band, the Upper D Block of the 700MHz band, the Mobile Satellite Services Band and a large slice from the broadcast TV band. And this only covers the first 300MHz the FCC wants in the next five years.

What it’s for

Over the past 76 years of the FCC’s existence, the radio frequency spectrum has been fully allocated from 9kHz all the way up to 300GHz, which does not leave a lot of room for new technologies. What are these new technologies that the FCC is trying to make way for? In short, it’s “broadband,” that high-speed link from your DSL, cable or other ISP.

According to ATT, usage of the iPhone has caused a 5000 percent increase in the data traffic on its wireless network in just the past three years, and wireless providers are saying they each will need 40MHz-150MHz of new spectrum in the next few years. According to one study, this means a total of 1720MHz will be needed for wireless services by 2020.

What is this spectrum going to be used for? The FCC predicts a wired and wirelessly connected future America, and, indeed, in the past decade, there has been explosive growth in wireless devices and applications. But the FCC is looking beyond this and sees medical records and images being transferred from doctor to specialist; remote classrooms having guest speakers; and children being able to attend class from home. There is a world of things that a nationwide, high-speed wireless network can provide if we only give it enough spectrum space, according to the FCC.

How broadcast TV fits in

The largest slice of existing spectrum space the FCC wants to reallocate is in the broadcast TV band — 120MHz of spectrum in one large segment across the entire United States. Although not stated outright, the FCC talks about the need for spectrum that is open across the country, so devices and services will work wherever people are.

The FCC proposes several ways to obtain this 120MHz spectrum from broadcasters. The first is straightforward enough: update the rules for channel separation and distance for TV stations. This makes sense because technology has made great strides in the past several decades. Long-gone are the days of requiring UHF stations to be spaced every six channels because the early UHF tuners could not handle them being any closer, and bringing stations into closer channel groupings would help consolidate spectrum. (This would have been easier if it had been part of the DTV conversion, but it was not.)

The next idea from the FCC would have a very limited effect: two or more stations share a single channel. Instead of each station having a full 19.4Mb/s stream, it would be sliced up into small segments, and broadcasting would be sent back to the old days of a single program stream. It’s hard to believe that many broadcasters would opt for this, because it is effectively removes any possibility for expansion in the future, but another section of the plan suggests required channel sharing.

After those two suggestions, the FCC’s plan then proposes “lifeline” video service. Under this plan, if viewers meeting certain criteria lose their over-the-air broadcast stations, then they would be eligible for video service from a TV satellite provider to view local broadcast stations.

Then there’s the use of single- or multifrequency networks, either voluntarily or involuntarily, to lower the amount of interference between broadcasters, which would assist in consolidating all of the TV channels. The plan notes that this would work best if all stations in an area converted.

Another proposal is to auction off an “overlay” license, similar to the 2GHz band for ENG in which the buyer then had to negotiate with the current users and purchase new equipment for them to obtain the spectrum.

The last recommendation is to “take additional measures to increase efficiency of spectrum use in the broadcast TV bands.” If all else fails to garner the necessary spectrum, the plan calls for “spectrum fees,” which, in an effort to convince a station that its spectrum is more valuable to a broadband provider, would effectively make it too expensive to stay on the air. This plan places a high value on the price of the spectrum and not what final good it provides.

Broadcast TV spectrum

All the DTV channels combined account for only 294MHz, which is counting Channels 2 through 51, but the lower VHF channels do not work well for DTV, so that limits the number even more. The FCC is looking for 120MHz from the broadcast TV band, which would leave just 174MHz, or 29 channels, across the country. While this is an adequate number of channels for any one market, some would argue that this limiting of broadcast channels could be the beginning of the end of free, over-the-air broadcast TV.

It’s interesting to note how often the FCC mentions the value of the spectrum in dollar terms and not in terms of how it serves the community. The paper reports that currently the TV broadcast spectrum is valued at 11 cents to 15 cents per megahertz-pop; this is compared to $1.28 per megahertz-pop of the 700MHz band when it was auctioned.

According to the FCC plan, “The preference is to establish a voluntary, market-based mechanism to effect a reallocation, such as the incentive auctions,” which leaves broadcasters to wonder what will happen if not enough stations voluntarily give up their channels.

Even now, the FCC’s own broadband proposal is being used as an indication that free, over-the-air broadcasting is no longer relevant. According to the National Cable and Telecommunications Association, "With even the commission suggesting that broadcast spectrum should be put to better use, it is clear that broadcast television no longer serves an 'important' government interest to the extent that it used to"; this is contained within the association’s support of Cablevision’s must-carry challenge at the Supreme Court.

Within the FCC’s own plan, it cites the same must-carry challenge as an example of how broadcast TV’s value would be lowered if the court sides with Cablevision. The thinking seems to follow that a loss of must-carry would then prompt broadcasters to auction off their spectrum. This broadband proposal then goes on to say that the expansion of broadband availability would “outweigh” any impact on broadcast TV’s spectrum.

Of particular importance to broadcasters in the FCC’s plan is Chapter 5, “Spectrum,” and page 90, which lays out steps to be followed if viewers can no longer receive an over-the-air channel. You can view and download the entire plan here.

What it all means

While the goal of greater broadband access is noble, the plan to disrupt current over-the-air broadcasts and auction spectrum off for subscription-based businesses seems to be overshadowing the public’s need for a medium that has truly helped bring news and entertainment to the nation for more than 60 years.

While studies do show a higher percentage of the public viewing TV shows over the Internet, it has always been the TV that they turn on to see live events and news. As a comparison, the 2010 Super Bowl drew in almost 106 million viewers, while the most watched Internet event drew 27 million viewers (President Barack Obama’s inauguration speech).

Broadcasters have already found out what it really takes to acquire, edit, store and play out high-quality audio and video, and they have done a great deal with just 19.4Mb/s — providing anywhere from one HD to several SD programs — while most of today’s Internet companies are only dealing with very low-quality, low-bandwidth signals. It will take a restructuring of our nation’s entire data network infrastructure to accommodate the high bandwidth required to supply our nation’s future needs, but it should not be done at the expense of broadcasters and limiting the public’s access to one of the only non-subscription news and entertainment outlets.

Who Benefits?

Obviously, the broadband companies that charge subscribers monthly fees will gain the most from this plan. As for all the talk of emergency service providers gaining from it, that will take many more years. As an example, starting right after the 9/11 attacks, Congress approved the allocation of a frequency band for first responders to be able to communicate with each other. That was in 2002, and it still hasn’t happened, even though they already have their frequency band.

The FCC’s National Broadband Plan is admirable in many ways, but it lays out a wireless plan that could undermine a free service that millions of people depend on for news and entertainment with a future system with unknown public benefits.