Don’t Dump Broadcasters Into ‘The Gap’

The battle over whether or not there are enough protections in place for broadasters in the spectrum auction continues.
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The question of whether or not to participate in next year’s broadcast spectrum incentive auctions, and the battle over whether or not there are enough protections in place for broadcasteers, continues to vex our industry. Is it too much to ask for some guarantees? Or at least a bit more fairness on the part of the FCC?

At stake are those stations that could end up being relocated in the “duplex gap,” the portion of spectrum between wireless up- and downlinks. For those broadcasters that have to move channels after the repack, some of them may end up in this portion if the FCC can’t find a channel for them. When the commission made the proposal earlier this year, opposition was swift and fierce. And proof of the potential interference was outlined in the pages of TV Technology by veteran columnist Charlie Rhodes, formerly chief scientist with the ATSC Test Center and who now conducts his own research on interference. Rhodes outlined his concerns in his column, “Assessing Post Channel Repack Options,” and his warnings were summarized in comments filed by Sinclair Broadcasting in September.

“Using the commission’s recently adopted ISIX model [the FCC’s adopted interference model, based on Longley-Rice], Mr. Rhodes cautions that harmful interference will indeed occur and be far greater with the aggregation of ‘super blocks’—10 MHz wide assignments—by wireless carriers,” wrote Mark Aitken, vice president of Advanced Technology for Sinclair. “ISIX interference can arise from signals offset in frequency by more than 6 MHz. In fact, Mr. Rhodes notes that two Super Blocks of 10 MHz each may generate third-order distortion products spanning a significant 27 MHz. In short, broadcast and wireless broadband will demonstrably interfere with each other, and that will be exacerbated by placing broadcast channels in close proximity to wireless users in the duplex gap.”

The NAB, likewise, warned the FCC that placing stations in the gap will limit those stations’ ability to expand their service areas or take advantage of new innovations in broadcast technology. The association also decried the commission’s lack of fairness to stations that decide not to participate in the auctions, hinting that the commission’s latest notice on auction procedures could punish such stations by placing them in the duplex gap, which is also occupied by wireless carriers in other markets.

“For a long time, the FCC had been suggesting that broadcasters would be randomly selected to be placed into the wireless band, and it would not be based on whether, and to what extent, they participated in the auction,” wrote Patrick McFadden, vice president of spectrum policy for NAB in September. “Obviously it would be alarming if the FCC made judgments based on participation.”

“The recent Procedures Public Notice, however, could be read to suggest the FCC has decided that only non-participating stations will be placed in the wireless band, if the auction successfully closes at the initial clearing target,” McFadden said. “In addition, it appears that the only other stations that could be added to that list are broadcasters who participate but drop out in one stage, only to see the auction move on to another stage because it could not close. In other words, if the auction fails to close at that initial stage, the only additional stations that can be relocated to the wireless bands are stations that drop out because their asking price is too high. This doesn’t exactly sound ‘voluntary’ to most broadcasters.”

Despite the “moving target” aspect of the spectrum auctions and pressure from Congress to initiate them to satisfy budget revenue projections, the FCC needs to remember and hold fast to its central core mission: to protect spectrum and manage the airwaves to minimize interference, particularly post repack. Sinclair’s Mark Aitken again:

“Interference protection is the raison d’etre of the FCC,” he, said. “The laws of physics have not changed, and repacking broadcasters in bands reserved for mobile wireless broadband highlights the commission’s challenge.”

We couldn’t agree more. Add to that the results of a recent study by Digital Tech Consulting that predicted that the FCC’s 39-month window may not allow enough time for more than 400 stations to be relocated to new channels and it’s clear that the commission is not doing enough to ensure a methodical transition. Adopting more stringent rules to protect those stations that remain operating after the auction could go a long way in helping to improve their image in the eyes of our industry, and more importantly, protect a valuable public resource.