[opendtv] Final Comments Filed in TV Broadcast Allocations Proceeding
- From: "Manfredi, Albert E" <albert.e.manfredi@xxxxxxxxxx>
- To: "opendtv@xxxxxxxxxxxxx" <opendtv@xxxxxxxxxxxxx>
- Date: Fri, 29 Apr 2011 16:15:58 -0500
Of course the CTIA would favor broadcasters giving up spectrum. No JUST because
this makes their two-way wireless network design just a tad simpler (but not
much, in fact), at the expense of broadcasting, but also because this limits
even more the amount of program diversity the OTA TV broadcasters can offer in
the future.
Clearly, both outcomes would benefit the CTIA members, the wireless telcos.
Whatever it takes, to drive more subscribers to their cell networks.
Once again, it is the FCC's responsibility, as the representative of the people
and not of the special interests, to figure these things out, to separate vague
and misleading half-truths from facts, and to rule accordingly.
Bert
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http://www.tvtechnology.com/article/119910
Final Comments Filed in TV Broadcast Allocations Proceeding
by Doug Lung, 04.28.2011.
April 25 was the last day to file reply comments to the Notice of Proposed
Rulemaking (FCC 10-196) regarding "Innovation in the Broadcast Television
Bands: Allocations, Channel Sharing and Improvements to VHF."
In reviewing the reply comments, I noticed some common themes in the filings.
Reply comments from the Consumer Electronics Association and CTIA - the
Wireless Association and other supporters of reallocation of spectrum from TV
broadcasting to wireless broadband focused on the growing use of wireless
broadband and the need for more spectrum. Some reply comments noted that
watching video online was one of the uses driving the need for more spectrum
for wireless broadband.
The reply comments, when they mentioned the need to continue to support local
TV broadcasting, did not address the real engineering problems inherent in
eliminating TV broadcasting above Channel 30 in the most populated areas. The
CTIA reply highlights comments from Ericsson's proposal to move TV broadcasting
to only 84 MHz of contiguous spectrum by converting TV from single transmitter
ATSC broadcasting to a dense cellular network using the LTE Multimedia
Broadcast/Multicast Service (MBMS) and OFDM.
Reply comments from broadcasters, including Local Television Broadcasters,
Named State Broadcasters Associations, CBS, and NAB and MSTV, focused on the
practical difficulties in taking 120 MHz of UHF TV spectrum under a voluntary
plan without reducing coverage (either by smaller service areas or increased
interference levels) and requiring that some stations move from UHF to VHF.
The broadcaster reply comments also focused on the one-to-many nature of
broadcasting, and questioned the wisdom of moving video programming delivery
from local broadcasters who have public interest obligations and who provide
service for free (advertiser supported) to a small number of nationwide
wireless operators that would likely charge for the service. Many pointed to
the introduction of Mobile DTV as a way to provide video programming not only
to the big screens in the home, but also to handheld receivers. Wireless
broadband was not viewed as the only way to get programming to small devices.
Most reply comments supporting broadcasters questioned whether there really was
a "spectrum crisis" that needed immediate action. A common theme was that any
spectrum reallocation plan must be truly voluntary.
Some of the reply comments focused on specific parts of the NPRM. Smartcomm
LLC, in its Reply Comments said that other comments in the proceeding reinforce
Smartcomm's position that the FCC should provide LPTV broadcasters with options
to either continuing their current operations, return spectrum for an incentive
auction, enter into spectrum sharing agreements with broadband providers, or to
give up their broadcast service in order to provide mobile broadband, either by
themselves or through partnerships with broadband providers.
The Reply Comments of the Walt Disney Company emphasized the efforts ABC-owned
VHF stations have made to overcome significant obstacles in providing reliable
broadcast service but stated that "additional power is required for these
stations to improve service to their former over-the-air analog viewing areas
in a meaningful manner."
Disney is concerned that if the FCC attempts to move more stations to VHF, this
will hinder the ability of existing VHF DTV stations to provide coverage.
Disney noted that "The Commission's proposal to increase the maximum effective
radiated power permissible for Zone I television stations, while helpful to a
degree, is of limited benefit due to the restrictions on interference to
adjacent and co-channel operations."
The Disney filing further noted that the FCC should avoid taking any action
that would enable a station which has been adequately serving its former analog
viewing coverage area to increase power or move to a VHF channel at the expense
of a station which has not been able to resolve "the VHF reception problems
suffered by its viewers."
Reply comments from the Consumer Electronics Association and RadioShack opposed
requirements that all TV antennas have to provide VHF reception and meet
certain standards, citing comments from others, including the NAB and other
broadcasters, in supporting this argument. Reply comments from the National
Cable & Telecommunications Association and Dish Network LLC expressed concern
that the channel sharing proposed in the NPRM could lead to "new" stations that
could demand carriage by multichannel video programming distributors (MVPDs).
Dish expressed concern that channel sharing could disqualify eligible satellite
TV subscribers from receiving distant network programming, noting, "Current law
would not, in fact, recognize a channel sharing arrangement as creating either
a 'primary stream' or a 'multicast stream' that would serve to disqualify duly
qualified unserved households in a given local market from receiving a distant
signal for a particular network, because neither stream would originate with
the original licensee for the relevant spectrum."
Sinclair Broadcast Group's Reply Comments deserve special mention, as they
highlight the development of Mobile DTV broadcasting and the disadvantages of
favoring wireless broadband carriers in the delivery of mobile television
content.
Sinclair stated, "In other contexts the FCC has attempted to break the
subscription carriers' stranglehold on the supply chain of mobile devices and
the services that can be accessed using those devices. The basic principle is
that consumers should be able to mix and match hardware, services and
applications without having to accept the wireless carriers' Hobson's choice:
'if you want to access my network, you take the devices and services I permit
or none at all.'"
Sinclair argued that the policy choice implicit in the NPRM "would inexorably
drive the fastest growing segment of mobile services into the hands of the
wireless carriers."
The company's comments stated that in theory it would be possible for anyone to
bid on reclaimed broadcast spectrum. However, in practice, the highest bids
would likely come from carriers having the deepest pockets and who would
"impose a substantial recurring price tag on access to mobile video services."
Sinclair said that if those carriers were to be allowed to control the spectrum
used for the fastest growing mobile service, then the FCC would be allowing
those companies to control yet another service, and that this would give them
"even more control over the market for mobile devices themselves."
Sinclair pointed to comments from Capitol Broadcasting Co. stating that a
broadcast architecture is the only way to meet demand for mobile video. It also
agreed with Capitol's comment that since a broadcast architecture will be
required to meet demand, there is no public policy rationale to take spectrum
already allocated for broadcasting and assign it to wireless providers who will
develop their own broadcast capability.
Sinclair pointed out that "The pace of innovation in services provided in the
television bands is limited by the FCC, not the licensees that occupy the
bands. Broadcast licensees, working with the ATSC and many of the same
technology suppliers that provide hardware and systems to mobile broadband
service providers, are aggressively pressing ahead with innovative new
technologies and services."
Sinclair further noted that "the fallacy of the NPRM is that it assumes
television broadcasting will remain static while wireless carriers charge ahead
with innovation."
The reply comments discussed above and others available from the FCC Search for
Filed Comments site (enter 10-235 in the "Proceeding" box) frame the issues the
FCC will have to address as it proceeds with implementation of the National
Broadband Plan's recommendations for reallocation of TV broadcast spectrum.
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