CEA, Broadcasters Square Off Over Future of TV Band

“Even in the bands below 3.7 GHz, over 500 MHz of spectrum has been made available in recent years for wireless broadband, but for the most part this spectrum has only begun to be put into productive use,” MSTV and the NAB said in a joint filing. They described 507 MHz made available in recent years for terrestrial and satellite service, including 700 MHz spectrum, the AWS-1, AWS-2 and AWS-3 bands and 2500-2690 MHz spectrum. They said wireless should have a role in the broadband plan but “should not be viewed as substitutes for wireline service.”

The broadcasters groups questioned whether carriers are making the best use of the spectrum they have. “Despite the gains that the commercial wireless industry has made in spectrum efficiency over the years, it is clear that additional and substantial gains are possible,” they said. “As the Public Notice explains, a 2004 study sponsored by the National Science Foundation found that less than 20 percent of the frequency bands below 3 GHz were in use over the course of a business day.” They also pointed to broadcast TV’s contributions to society. “In assessing the efficiency and productivity of a current use of spectrum, the Commission should put a premium on public policy goals that are served by that use,” the trade groups said. “For example, in addition to economic benefits, broadcast television serves core public interest goals such as local journalism, universal service, availability of educational programming, and timely and reliable provision of emergency information.”

The broadcasters’ positions were countered by the CEA, which is becoming more active at the FCC on wireless matters. “CEA submits that we face a looming spectrum crisis, threatening our national priorities and competitiveness,” the group said. “CEA urges the FCC to initiate immediate action to assess spectrum usage and determine how additional spectrum can be allocated for wireless broadband and other uses. … Unless significant amounts of new spectrum is allocated to wireless broadband, the next iPhone, the next YouTube, the next telemedicine applications won’t be developed in the United States. Broadband innovators will flock to other nations who are on the verge of allocating hundreds more megahertz of spectrum than is currently available here.”

A spectrum inventory should be “rigorous and thorough” and take into account “actual spectrum usage on a temporal and geographic basis, the population served, whether the services provided can be offered over less spectrum or perhaps in some cases over a wired infrastructure, and to what extent allocations are serving the public interest,” the CEA said. It proposed a blue-ribbon advisory committee on wireless broadband, which could be made up of diverse and respected leaders. The committee could recommend strategies for allocating more spectrum for wireless broadband, it said. “Many options should be explored, including the possible creation of incentives for incumbents to relinquish their spectrum or to operate more efficiently using less spectrum, thereby freeing up spectrum for other important uses.”

The CEA also submitted a paper by economist Coleman Bazelon that estimated the value for spectrum used for full-power TV broadcasts in the U.S. at $48 billion. Bazelon estimated that the cost of providing 10 million broadcast TV households with lifetime subscription video service would be only $9.3 billion.

The CTIA’s comments urged U.S. policymakers to identify and allocate significant additional spectrum, at least 800 MHz, for wireless broadband. The association has proposed the number, based on International Telecommunication Union estimates, previously. The CTIA encouraged the “Commission to clear spectrum that already has been allocated and auctioned for carrier use and to continue to promote the use of secondary markets to ensure that spectrum is put to its highest use.”

Verizon Wireless said demands for commercial spectrum will quadruple over the next 10 years. “We urge the Commission to act promptly to identify additional spectrum for future use, and to make every effort to identify spectrum that will best accommodate mobile broadband services and maximize the efficiency and cost effectiveness of mobile broadband networks,” the carrier said. Verizon pointed to estimates by others: “Cisco Systems, Inc., for example, has estimated that, globally, mobile data and Internet traffic will double every year through 2013, increasing 66x between 2008 and 2013. … Chetan Sharma Consulting estimates that mobile data traffic in the United States will increase at an even more rapid rate. It estimates that mobile data traffic will increase by a factor of 145x between 2008 and 2013, and by a factor of 300x by 2014.”

T-Mobile cited comments about a “spectrum gap” by FCC Chairman Julius Genachowski at the recent CTIA conference. “Today’s service, technology, and equipment options are dizzying -- and the capabilities and applications that will be available to wireless customers in five years will be even more advanced and data-driven,” the company said. “Every indication is that consumer demand for mobile broadband will continue to explode as customers demand access to the Internet, video, and other data-rich applications on smartphones, laptops, and netbook devices. But, as the FCC Chairman observed, the bandwidth needs of the new devices and applications are increasing far more rapidly than the spectrum available to support them.”

3G Americas pointed to the hundreds of MHz of spectrum set to come online in Europe. “In the United States, by contrast, only a limited amount of spectrum -- 50 MHz -- is in the ‘pipeline’ . . . allocated for commercial use and waiting to be assigned,” the group said. “Beyond this AWS-2, AWS-3 and D-block spectrum, no additional spectrum is actively being considered for allocation for licensed mobile broadband.” The wireless industry in the U.S. is at a crossroads, 3G Americas said. “Networks technologies must enable more efficient use of spectrum, but the Commission also must supply the spectrum needed for the industry to meet the needs of consumers.”

Qualcomm said just providing more spectrum won’t be enough. “As the Public Notice itself implies, the additional spectrum needs to come from bands below 3 GHz,” the company said. “Otherwise, the business case for using the newly allocated spectrum for mobile broadband will be poor. There is no viable business case for the use of spectrum above 3 GHz for mobile broadband because a network on such spectrum would require far too many base stations.” Qualcomm said new spectrum will be needed for mobile TV, mobile broadband, mobile banking and commerce, mobile healthcare, mobile education and satellite broadband. “New devices, new networks, new categories of devices, and new improvements to the user experience are all driving enormous growth in mobile broadband use, thereby creating the need for additional licensed spectrum,” the company said.

The American Petroleum Institute said the FCC must not forget the unique needs of energy companies. “API has made clear that the allocation of exclusive, private spectrum for Critical Infrastructure Industry broadband use is vital to the energy industry, particularly in light of the loss of spectrum CII has suffered over previous years as the Commission repurposed spectrum for commercial use,” the institute said. The Enterprise Wireless Alliance said other business needs must also be met. “This nation cannot return to robust economic health until the businesses that provide jobs for its citizens and that ensure the delivery of essential goods and services have the tools needed to compete successfully in a global economy,” the alliance said. “One of those tools increasingly will be secure, reliable, cost-effective broadband communications. As the Commission develops its National Broadband Plan, it must ensure that the Plan addresses not only the requirements of commercial wireless service providers for whom the FCC already has allocated over 430 MHz of spectrum, most of which is capable of supporting broadband applications, but also the more particularized needs of business enterprise users, needs that cannot in all cases be accommodated on either commercial or unlicensed broadband spectrum.”