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The FCC should reject a proposal from CTIA-The Wireless Association to strip away 15MHz of 2GHz Broadcast Auxiliary Service spectrum from broadcasters and reallocate it for use by the wireless industry, according to comments filed Sept. 18 by NAB with the agency.

Further, the association said the time has come for the FCC to conduct an audit of how the wireless industry actually uses its “vast spectrum holdings” to determine how efficient it is and to what degree its spectrum is even being used.

In March, CTIA submitted a letter and white paper urging the FCC to reallocate the upper portion (2095MHz to 2110MHz) of the 2GHz Broadcast Auxiliary Service (BAS) band for wireless use.

As mandated by Congress in the Spectrum Act (the Middle Class Tax Relief and Job Creation Act of 2012), the FCC is directed to find and auction 15MHz of contiguous spectrum for mobile use.

According to NAB’s comments, CTIA’s proposal is “unnecessary, misguided and has the potential to significantly harm the American public.”

“Further, the current BAS allocation is essential to broadcasters’ ability to provide critical, real-time news and information and has already been reduced by 35MHz or almost 30 percent, while the U.S. wireless industry is currently flush with spectrum and poised to get more.”

The entire 2GHZ BAS band (2025MHz to 2110MHz) is heavily used for live ENG shots, studio-to-transmitter and inter-city fixed links and for Cable Antenna Relay Services. Since fall 2008, broadcasters have used fewer channels in the BAS allocation as the band was narrowed to accommodate rebanding undertaken by Sprint/Nextel.

In its comments, NAB said that rather than identifying 15MHz of contiguous spectrum for auction, the commission’s Notice of Proposed Rulemaking identifies 25MHz of contiguous spectrum (1755MHz to 1780MHz) that meets its obligation under the Spectrum Act.

NAB told the FCC that the CTIA proposal should be rejected for three reasons. First, it “ignores the value and existing congestion of the BAS band.” The association reminded the agency that its own Spectrum Dashboard says more than 10,000 licenses operate in the BAS band.

Second, if the FCC were to act on CTIA’s proposal it “for the first time since completion of the National Broadband Plan eliminate one active use in favor — and favoring — another,” the comments said.

“Especially in light of the NPRM’s proposal to license the 1755MHz-1780MHz band, CTIA’s brazen attempt to forcibly strip broadcasters of yet more spectrum should be rebuffed,” it said.

Third, the wireless industry in the United States already has “vast and vastly unused and likely underutilized spectrum resources,” NAB said in its comments.

NAB told the FCC that “the best and most logical way” to fulfill its obligation under the Spectrum Act is to stick with the NPRM proposal and auction the 25MHz between 1755MHz and 1780MHz.