WASHINGTON -- Broadcasters filed comments late yesterday with the Federal Communications Commission (FCC) 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 (DOJ) and the National Telecommunications and Information Administration (NTIA), the broadcast groups concluded that a low-power proposal proffered by CTIA-The Wireless Association and the Consumer Electronics Association (CEA), while constructive, was impractical.
The broadcasters' comments came as part of a joint filing submitted by the National Association of Broadcasters (NAB) 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. Additionally, the CTIA/CEA proposal "could not and would not make available significant amounts of contiguous spectrum in the congested areas where the wireless industry claims the greatest spectrum shortfalls" even if transmission spacing requirements were substantially reduced, NAB and MSTV stated.
NAB and MSTV noted agreement with several aspects of the submissions filed by the DOJ and NTIA. The broadcast groups endorsed the DOJ's call for greater use of secondary markets in spectrum and NTIA's urging of a spectrum inventory analysis. NAB and MSTV "agree that a comprehensive inventory of present and future spectrum availability and usage is necessary," the groups said. While noting that neither the DOJ nor NTIA called for the reallocation of broadcast TV spectrum, NAB and MSTV called "particularly problematic" the agencies' assumption that a lack of spectrum is the key impediment to increased competition in broadband.
"[T]here is no necessary nexus between allocating additional spectrum and increased broadband deployment and use. Many countries with higher broadband usage rates than the United States have less spectrum allocated for broadband purposes," NAB and MSTV said.
Regarding the agencies' prediction of increased demand for mobility, technical speed and HD video, NAB and MSTV noted that mobile digital TV, offered by local TV broadcasters, provides consumers with "real-time, high-quality video on-the-go."
"Point-to-multipoint broadcasting is simply a more efficient way to deliver mass-audience video content to the public than wireless point-to-point technology, and it is more immediately deployable," NAB and MSTV said.
The 19-page filing can be read in PDF format here.
The National Association of Broadcasters is the premier advocacy association for America's broadcasters. NAB advances radio and television interests in legislative, regulatory and public affairs. Through advocacy, education and innovation, NAB enables broadcasters to best serve their communities, strengthen their businesses and seize new opportunities in the digital age. Learn more at www.nab.org.