Reply Comments filed in the FCC’s National Broadband Plan proceeding
February 18th, 2010Your Association joined with 46 other State Broadcasters Associations in strong support of the free, local, over-the-air television broadcast industry by filing Reply Comments in the FCC’s National Broadband Plan proceeding. The Reply Comments focus on the CTIA-CEA proposal to reclaim broadcast spectrum by transitioning U.S. television broadcasters in all markets to a “Single Frequency Network” architecture. Every station would retain a full 6 MHz, but would have to operate via a network of lower-power transmitters to cover an entire market. In our pleading, we made the following points:
- The CTIA-CEA proposal includes no supporting technical or financial data, so it is little more than speculation.
- Local broadcasters are small, local businesses compared to wireless providers and provide service free to consumers. Local broadcaster cannot build and operate the same kinds of high-cost networks that wireless carriers use.
- CTIA has argued that lack of available tower capacity and tower sites is one of the reasons they need more spectrum. Ironically, forcing broadcasters to compete for the same towers and sites wireless providers use could result less efficient use of wireless spectrum.
- CTIA and CEA have greatly underestimated the costs of the proposed transition and have not explained how broadcasters could pay the vastly higher operating costs.
- ATSC was not designed to be used in a Single Frequency Network architecture, and attempting to backward engineer this would add significant costs and degrade performance.
- A second transition would require major service interruptions in all markets, compromising the Emergency Alert System. Since the dates of these service interruptions would have to be publicized in advance, the transition would pose substantial public safety risks.
The State Associations support FCC efforts to initiate a constructive dialog about how regulatory changes can improve broadcasting service, and the CTIA-CEA Comments may deserve more consideration. However, the comments should be recognized for what they are: constructive in intent with a high level of speculation.
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