CTIA, CEA Submit Proposal for Reallocating Broadcast Spectrum

Under the CTIA/CEA plan broadcasters would be shifted from the current “high power/high tower broadcast architecture” into “low power networks of distributed transmitters.” They said the goal is to reduce the “spectral separation between licensees.”

The proposed plan would require only a “rescan” of over-the-air TV stations by consumers, “a relatively simple, no-cost procedure and one that was required at the end of the DTV Transition in any event,” the filing said. Lower-power transmitters “should create a much smaller interference footprint around television transmitters and therefore should permit closer spacing between co-channel and adjacent channel television operations,” they said. They point out that single-frequency networks (SFN) like those proposed for TV broadcasts are already in use by the paging industry and by Sirius XM in its terrestrial repeater network.

“CTIA believes that there is an impending spectrum crisis that puts at risk the U.S. mobile broadband future,” CTIA said in an accompanying filing. “Significant additional amounts of spectrum must be identified and allocated between 400 MHz and 3 GHz for mobile broadband services.” CTIA did not offer additional insights on carrier spectrum demands, but again said, “based on demand calculations from the International Telecommunications Union,” that carriers will need at least 800 MHz for mobile wireless broadband use within the next six years.

The filing by CEA and CTIA is a departure from their position that TV stations shouldn’t keep using their entire 6 MHz at 19.4 Mbps, in that the groups propose using a similar amount of bandwidth but at lower power levels, said President David Donovan of the Association for Maximum Service Television. “We have to look very carefully at their proposal, because it is not at all clear that [it] will save any spectrum. In fact, it may be more inefficient.” Since TV stations use barely 5 percent of “the so-called beachfront spectrum,” it’s “just wrong to target broadcasters,” he said.

Gray Television President Robert Prather asked about the CEA and CTIA filing: “What’s the old saying about pigs getting slaughtered. Why don’t they just take us and put us out of business completely? That would be better for them. Why go halfway?” An NAB spokesman, asked about the CEA-CTIA filing, said his group will “review the comments submitted by all the parties interested in the FCC’s broadband proceeding.”

“The main thing we want to do is to get some proposals on the table to start the discussion,” said Brian Markwalter, CEA vice president for technology and standards, in an interview. “In this case there’s some engineering suggestions that are made that we welcome more scrutiny on. We think it makes business sense. … Instead of having a big tower with a really strong field stream close that just gets weaker as you go out to the edge of the coverage contour, you have more of a cellular architecture, which means you can put things closer together.” Markwalter said broadcasters would be able to keep their 6 MHz channels under the plan, keep their legacy equipment functional and broadcast the same 19.4 Mbps stream. “We hope it doesn’t become a completely political debate,” he said. “We think there’s some real business synergies in what’s being proposed.”

One FCC source Wednesday questioned how much weight the agency will give the filing. “It seems contrived,” the official said. “It’s hard to believe that these filings will be given a serious, hard look. It’s not really clear what the strategy is.”

“At this point, everything is on the table,” said a wireless industry attorney. “Whether the commission pursues this initiative going forward remains to be seen -- it could be a very slow, deliberate process.”

“I suspect this is too complicated,” said Public Knowledge Legal Director Harold Feld. “Nor does it create neat blocks of spectrum on a national basis suitable for auctioning. It also deprives broadcasters of their audience share by reducing the coverage area, without any compensating advantage to the broadcasters. Finally, it would eliminate the must-carry right, which is only available to full power broadcasters (and a very limited number of LPTVs) and which broadcasters would never give up.”

Jeff Silva, analyst at Medley Global Advisors, said the proposal likely faces an uphill climb and broadcasters will probably turn to Capitol Hill for support if necessary. “I'd be surprised if it got any traction immediately,” he said. “I think a lot of stuff is on the table. I'm not sure that taking from broadcasters the channels that they have is on the table. I'd be very surprised if that were put in play. I don’t think the broadcasters want to give that up.”

In other comments, T-Mobile launched a direct attack on broadcasters and their actual spectrum needs. “While broadcasters play a vital role in providing television services to a segment of the public, that segment is shrinking and broadcasters do not require the entire amount of spectrum they are allocated to meet projected needs,” the carrier said. T-Mobile also said the spectrum needs of carriers will continue to explode. “A single YouTube viewing consumes nearly 100 times as much bandwidth as a voice call,” it said. “Since T-Mobile began offering its G1 smart phone, customers of that device use 50 times the data of the average T-Mobile customer not operating on a smart phone device.”

“Despite the unsubstantiated claims by broadcasters, the need for additional mobile broadband spectrum has been thoroughly documented in multiple third party studies, many of which have already been made part of the public record,” AT&T said, pointing to studies by Cisco and the ITU that show the growing need carriers will have for spectrum. “When the Next Generation Mobile Networks Alliance reviewed the ITU data it estimated that up to 1 GHz of additional mobile broadband spectrum will need to be allocated in the near future to meet growing demand,” the carrier said. It said the 800 MHz figure “is actually quite conservative.”

Motorola urged the FCC to proceed with caution, but also said the time is ripe for a renewed look at the actual spectrum needs of broadcasters. Motorola warned that the repurposing of TV spectrum will be a “complicated and time consuming process.”

Qualcomm said its FLO TV network, which uses TV Channel 55 spectrum, “is proof positive that broadcast spectrum can be repurposed for far more efficient uses.” The technology allows up to 20 channels on the same 6 MHz channel bandwidth formerly used by one TV station, Qualcomm said: “FLO can deliver a wide variety of content on a one-to-many, live, subscription basis and also content to be stored in subscriber devices, including video on demand; books, magazines, and periodicals similar to today’s eReaders; and, constantly updated data streams with content such as social networks, news, weather, stock quotes, and more.”

“Over-the-air television bands offer a unique opportunity to provide access to spectrum that will not only help to boost geographic coverage of mobile broadband services, but can also offer scope for widespread international harmonization,” said the London-based GSM Association. “Such widespread international harmonization can have a dramatic effect on equipment costs (and technical performance), and hence be of direct benefit to consumers.”

The Public Interest Spectrum Coalition reiterated concerns that the FCC preserve the TV white spaces for unlicensed use, saying “the use of unlicensed devices in the broadcast spectrum could make more capacity available for broadband data in the short term, without requiring relocation of incumbent users.”

Broadcaster Study Doubts Spectrum Shortage

The U.S. has plenty of capacity for licensed broadband use, not an impending spectrum shortage as the wireless industry warns about, said the first study from broadcasters on the subject since the FCC began looking into the issue this year. Their research found that TV stations use only 5.2 percent of the spectrum from 225 MHz to 3.7 GHz.

There’s close to 750 MHz available in that band, said the NAB and MSTV. An ITU study cited by CTIA and others raising concerns about a looming 800 MHz shortfall is being misinterpreted, they said. Filings by broadcasters stressed that services including DTV, mobile video and a mobile content delivery system being developed by News Corp. are making full use of the airwaves allotted for TV. As expected (CD Dec 23 p2), no broadcaster produced an analysis to rebut one commissioned by the CEA that found TV spectrum would be worth more if it were used for wireless broadband.

Spectrum comparisons between the U.S. and other countries aren’t meaningful?because many of the others haven’t switched to DTV and so have many unassigned frequencies, said the MSTV and NAB study by two engineers. “In addition, a substantial amount of spectrum that has been identified for wireless broadband use in the United States is either currently unused or only beginning to be used by wireless operators.” The oft-cited ITU study used faulty assumptions and “did not fully consider future broadcast television, wired solutions, or emerging femtocell possibilities in apportioning demand for high-speed multimedia and video and, in addition, assumed a diminishing market share for wireless local area networking,” they added. “The same model that CTIA uses to show a shortfall of 800 MHz in 2015 indicates that in 2010 there is a shortfall of 300-500 MHz, which is a demonstrably false conclusion.”

News Corp. said its plan to introduce mobile content delivery services over the next two years will bring print and video news and other programming to devices that may include smartphones, e-readers, laptops and netbooks. “A ‘one-to-many’ broadcast network is far more efficient than the ‘one-to-one’ architecture of IP-based broadband services when it comes to delivering bandwidth-hogging popular content.” A group of 24 other broadcasting companies said the FCC should request the same information about spectrum use for wireless as it did from broadcasters about their use. “Congress will be troubled and disserved if the Commission submits a Broadband Report that fails to address such issues authoritatively,” said Allbritton, Gray, McGraw-Hill, Media General, Meredith Corp., Tribune and others.

Broadband and TV are complementary, said the Association of Public Television Stations, the Corporation for Public Broadcasting and the Public Broadcasting Service. Christian stations would be hurt by a spectrum reallotment, the National Religious Broadcasters said. “Such an allocation would ignore the legal and constitutional questions.” CTB Group, which is helping low-power stations develop broadband services, said there’s no need for regulations to repack radiowaves, because current rules allow new offerings of that kind.