[opendtv] Doug Lung's reaction to FCC repurposing of TV bands ideas
- From: "Manfredi, Albert E" <albert.e.manfredi@xxxxxxxxxx>
- To: "opendtv@xxxxxxxxxxxxx" <opendtv@xxxxxxxxxxxxx>
- Date: Thu, 2 Dec 2010 16:23:16 -0600
Among his other points, Doug says:
"While the notice discussed channel sharing in great detail, it didn't discuss
spectrum repacking or answer any of the four items I was looking for in the
FCC's spectrum plan."
If you look at the paragraph I copied in my previous post on the subject:
"To facilitate repurposing of a portion of the U/V Bands in a later action, we
are proposing in this Notice to add allocations for fixed and mobile services
in the U/V Bands (excluding channel 37) for non-Federal use, to be co-primary
with that for broadcast services."
... and you consider the fact that the FCC seems particularly concerned about
controlling TV interference to Ch 37 and to Ch 52 and above, I have to conclude
that the FCC is not planning to repack. Instead, coexist.
Bert
---------------------------------
http://www.tvtechnology.com/article/110212
Proposed FCC Rules Give Fixed and Mobile Services Co-primary Status in all TV
Bands
by Doug Lung, 12.02.2010.
At Tuesday's Open Commission meeting, the FCC adopted its "Innovation in the
Broadcast Television Bands: Allocations, Channel Sharing and Improvements to
VHF" NPRM (FCC 10-196). While the notice discussed channel sharing in great
detail, it didn't discuss spectrum repacking or answer any of the four items I
was looking for in the FCC's spectrum plan.
Stations sharing a channel would have the same restrictions, rights and
responsibilities for their broadcasts as if each station had its own channel.
This includes responsibility for children's programming and carriage rights on
cable and satellite. LPTV and Class A stations would also be able to share a
channel.
There is a statement in the NPRM that is a little strange: "In allowing
stations to share channels, we note that in some instances changes in the
operation of television stations could raise the possibility of interference to
radioastronomy operations on channel 37 or to services operating on frequencies
immediately above channel 51. It is our intent that any channel or other
facilities changes that might be requested as part of sharing agreements not
result in increased interference to radioastronomy operations on channel 37 or
to operations of other services above channel 51." (Page 6, Paragraph 15).
At the present time, stations operating on channels 36, 38 and 51 have the same
emission mask and ERP limits as UHF stations on other channels. To be in
compliance with the ATSC standard, stations have to transmit 19.39 Mbps whether
they are carrying one program or 10. Sharing a channel would not have any
impact on the interference to channel 37 or channel 51, so does this indicate
the FCC may propose tighter restrictions on ERP and out-of-channel emissions on
stations that share channels 36, 38 and 51 than stations the operate on these
channels now? That's the only logical conclusion as I can't believe the authors
of this section thought the emissions from a channel shared by two stations
using one 19.39 Mbps stream would be any different from the same channel used
by one station. On a more positive note, does this emphasis on these channels
indicate the FCC may be considering something less than eliminating
broadcasting from a contiguous block of spectrum, say the 120 MHz from channel
31 to channel 51? This could potentially allow use of some broadcast spectrum
for wireless broadband with waiting the year it would take to install the new
broadcast antennas, transmitters, RF systems and perhaps towers necessary to
move TV stations off their current channels.
One indication the FCC is keeping their options open is that the proposed
change to Section 2.106 "Table of Frequency Allocations" adds fixed and mobile
services to all five TV bands - 54-72 MHz, 76-88 MHz, 174-216 MHz, 470-608 MHz,
and 614-698 MHz.
While the NPRM doesn't specifically say stations will have to move to VHF
channels, a significant part of the NPRM is devoted to the topic of making VHF
spectrum more desirable. FCC rules would be modified to allow increased power
for VHF stations provided they protect other stations from interference or
negotiate an interference agreement. Specifically, the FCC would increase the
nominal maximum allowed ERP for low-VHF stations in Zone 1 to 40 kW and
high-VHF stations in Zone 1 to 120 kW, for a height above average terrain
(HAAT) of 305 meters. As is the case now, maximum allowed ERP is reduced at
HAAT above 305 meters. The FCC encouraged VHF stations to use more power in the
vertical polarization (elliptical or circular polarization).
The other proposal to make VHF more desirable is to extend all channel receiver
rules to include indoor antennas by requiring all indoor antennas meet the
ANSI/CEA-2032-A "Indoor TV Receiving Antenna Performance Standard" as measured
using the procedures in ANSI/CEA-744-B. The FCC did not see any practical way
to reduce the noise from electrical and electronic equipment at VHF
frequencies, so it isn't clear that simply making indoor antennas more
efficient at VHF will solve indoor VHF reception problems.
Commissioner Robert McDowell recognized this, saying, "I also will review with
great interest the submissions we receive on the topic of potential technical
improvements for digital broadcasting on VHF channels. As one of the two
remaining veteran commissioners of the digital television transition, I have
not forgotten the difficult and unanticipated challenges that we and
broadcasters on those channels faced at the time of the analog shut-off. Both
industry and FCC engineers scrambled throughout the spring and summer of 2009
to try to overcome interference and other reception problems associated with
VHF channels. What had been prime real estate in the days of analog
broadcasting sometimes became a rough neighborhood in the new digital era.
Before the Commission takes action that might lead to more broadcasters moving
back into those channels, I will want to fully understand the ramifications of
such a decision."
Commissioner Mignon Clyburn expressed concern about the impact on broadcasters,
saying, "But I cannot stress enough that we must pay careful attention to those
who are most vulnerable to the loss of broadcast television. We learned during
the DTV transition that a large number of Americans, such as seniors and the
very poor continue to rely on broadcast TV to stay informed. Those communities
that heavily depend on broadcast programming should not have to sacrifice those
benefits in order for our Nation to attain wireless broadband services."
Commissioner Meredith Baker had some of the most interesting and innovative
comments on the future of broadcast TV, saying, "In the future, there needs to
be a fulsome discussion on additional innovative proposals to address sharing
of broadband and broadcast in the TV bands, including the possibility of a
broadcast transition from MPEG-2 to MPEG-4, the adoption of a more cellularized
broadcast system, or a transition from ATSC to OFDM technologies. These are by
no means the only potential approaches and may have their own weaknesses and
strengths. And in all fairness, we also should ask additional questions about
the future applicability of public interest obligations on broadcast licensees.
If the TV bands are to shift towards a more flexible spectrum model, it is only
right to ask whether those use restrictions should also be revisited."
The proposed rules are in Appendix A of the NPRM. Comments on the rules will be
due 45 days after the NPRM is published in the Federal Register. There is an
additional 30 days allowed for reply comments.
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