[opendtv] Four Items to Watch in the FCC's TV Spectrum Plan

  • From: "Manfredi, Albert E" <albert.e.manfredi@xxxxxxxxxx>
  • To: "opendtv@xxxxxxxxxxxxx" <opendtv@xxxxxxxxxxxxx>
  • Date: Fri, 12 Nov 2010 16:48:57 -0600

"Will the Obama administration be able get the Republican House of 
Representatives to agree to it?"

Good question.

This whole "one size fits all" attempt at increasing wireless broadband 
spectrum is wrongheaded, IMO, and I hope the new Congress will figure it out. 
Joe Barton did hint at some changes afoot, but who knows. I've never been able 
to figure out the party affilitation of OTA TV policies.

Where the TV spectrum is most heavily used is exactly where the low frequencies 
of the TV bands are least optimal for two-way wireless. Conversely, in areas 
where there's plenty of unused TV spectrum is where large cells, for cellular 
two-way, do make sense.

So it seems so obvious that this new attempt at wholesale spectrum-grab by the 
FCC has to be stopped, in favor of a market by market assessment and regulation 
tailored to each market. And it doesn't even seem difficult to achieve this!

Furthermore, in those markets where population densities are low and plenty of 
open TV channels exist, I'll bet you'll find that TV is already using the lower 
frequencies. Which would reduce any need for TV spectrum repacking.

Bert

------------------------------------
http://www.tvtechnology.com/article/109198

Four Items to Watch in the FCC's TV Spectrum Plan
by Doug Lung, 11.11.2010.

One of the items on the agenda for the Nov. 30 FCC Open Meeting includes a 
notice of proposed rulemaking seeking comments on rules that would facilitate 
the most efficient use of the UHF and VHF TV bands.

The commission says that the proposals are "an important step toward the 
agency's spectrum goals as outlined in the National Broadband Plan," and they 
would eliminate several obstacles to establishment of mobile broadband service 
in spectrum currently reserved for TV broadcasters. This usage would be made 
possible through "innovations such as channel sharing and generating increased 
value within the VHF band."

I've previously discussed the National Broadband Plan (NBP) and its 
recommendation that 120 MHz-almost half of the usable TV spectrum-be 
reallocated from broadcast television service (and white space devices) to 
wireless broadband. The FCC and the Obama administration have said repeatedly 
that any relinquishment of spectrum, either through channel sharing or giving 
up off-air broadcasting completely, would be voluntary. However, there are four 
things that should be looked for in the Nov. 30th NPRM, in order to understand 
the real impact of the proposed rules on TV broadcasting.

* Will stations that voluntarily decide not to give up their spectrum be able 
to stay on their existing channels? For example, WRC-TV, the NBC O&O in 
Washington DC, is unlikely to give up its spectrum or share a channel, as it's 
already broadcasting HD, two multicast channels, and Mobile DTV, thus fully 
occupying the Channel 48 allocation it was given. The CBS O&O in Los Angeles is 
on Channel 43. The wireless companies want contiguous spectrum. If the FCC 
follows the same plan as when reallocating channels 70-83 for cellular and SMR 
and, just last year, channels 52-69, stations in the upper UHF spectrum have 
reason to worry. This leads to the next question....

* If the FCC reallocates a contiguous block of spectrum starting at Channel 
51-and working down-what happens to the stations on the upper UHF channels? One 
hint is the agenda note about making VHF spectrum more valuable for 
broadcasting. Unfortunately, for Mobile DTV (perhaps the most promising and 
highest value use of spectrum for broadcasting), VHF doesn't work very well. 
Even the high-band VHF channels have problems getting a signal to handheld 
devices due to a huge disadvantage in antenna efficiency. Granting a 10 dB 
boost in effective radiated power will help, but is unlikely to fully offset 
the loss in antenna efficiency and the high level of electrical noise at VHF. 
Further, generating this much power at VHF will be difficult due to the size of 
the transmitting antenna. A VHF antenna with the same gain as a UHF antenna 
would need to be about four times larger. In most cases, this is not physically 
possible. Will a UHF station with excellent coverage be forced to take a VHF 
channel with little indoor-and practically no-handheld DTV coverage?

* Who pays? Repacking spectrum means moving stations to different channels and 
possibly different sites. For most stations, changing channels will mean 
installing at least one new transmission facility in order to avoid 
interrupting programming. In the event there isn't sufficient space on an 
existing tower, both an interim and a final facility would need to be 
constructed. Costs are likely to be close to, or even exceeding, $2 million per 
station. Will the wireless companies pay for these moves or will broadcasters 
be forced to pay the cost themselves in order to voluntarily retain their 
spectrum?

* What happens if there isn't enough TV spectrum for both the broadcasters who 
don't voluntarily give up their spectrum and the 120 MHz the FCC wants to give 
to the wireless companies? Will the Commission accept less than 120 MHz in 
those markets where there isn't enough spectrum, even if all the stations share 
channels? Will stations have to compete for the few remaining channels? Who 
gets stuck on VHF? What happens to the losers?

Remember that the Nov. 30 document will be a Notice of Proposed Rulemaking, not 
the final law. Congress must pass a law allowing the FCC to carry out its 
"incentive auction" plan.

Will the Obama administration be able get the Republican House of 
Representatives to agree to it?

The NBP implies a 2013 date for freeing up this spectrum. I would be surprised 
if Congressional approval is received and final rules issued before the end of 
2011. Considering the amount of time it took the FCC and broadcasters to 
complete the DTV transition-which involved adding a new service rather than 
moving an existing one-two years for such a drastic change seems unrealistic 
unless broadcasters who want to retain their spectrum are able to do so on 
their existing channels. If the wireless companies and other NBP proponents 
want fast access to TV spectrum-as I see it-they will have to accept the 
reality that the spectrum they receive may not be contiguous. Some of it might 
even be below 300 MHz.
 
 
----------------------------------------------------------------------
You can UNSUBSCRIBE from the OpenDTV list in two ways:

- Using the UNSUBSCRIBE command in your user configuration settings at 
FreeLists.org 

- By sending a message to: opendtv-request@xxxxxxxxxxxxx with the word 
unsubscribe in the subject line.

Other related posts:

  • » [opendtv] Four Items to Watch in the FCC's TV Spectrum Plan - Manfredi, Albert E