NAB, MSTV Find Fault With CEA/CTIA Spectrum Plan

Broadcasters filed comments with the Federal Communications Commission promising "full and constructive participation" in the agency's National Broadband Plan. While offering support for several aspects of submissions filed by the Department of Justice and the National Telecommunications and Information Administration, the broadcast groups described a low-power proposal proffered by CTIA-The Wireless Association and the Consumer Electronics Association, while constructive, was impractical.

The broadcasters' comments came as part of a joint filing submitted by the National Association of Broadcasters and the Association for Maximum Service Television (MSTV). NAB and MSTV expressed appreciation for CTIA and CEA's "constructive" efforts, but concluded that their proposal to transition over-the-air digital television to a low-power distributed transmission system (DTS) technology would result in coverage loss and interference. "Coverage gaps are the unavoidable consequence of trying to use a fill-in technology such as DTS as an across-the-board substitute" for the current deliver system of over-the-air DTV, the broadcast groups explained. Moreover, the CTIA/CEA proposal drastically underestimates the cost burden associated with such a transition, while overestimating the spectrum yield, NAB and MSTV said. The costs of implementing DTS "would be orders of magnitude higher than the estimates provided by CTIA/CEA," broadcasters concluded.

Local Television Broadcasters said before meaningfully considering a reallocation of broadcast spectrum, the Commission should take the following six steps to build a solid foundation upon which proper spectrum policy framework can be constructed. 1. Complete a spectrum inventory and identify available spectrum; 2. Investigate spectrum shortage claims, and the nexus between spectrum and consumer broadband demand; 3. Investigate alternatives to reallocating spectrum to the wireless industry; 4. Investigate increasing reliance on over-the-air television; 5. Investigate adverse consequences of coercive reallocation schemes; and 6. Complete the DTV Transition for rural America. "The highest-valued use for spectrum will not come from government assessments or government interventions." Only competition and regulatory flexibility will advance the adoption of wireless broadband and the offering of fairly-priced wireless services.