Expanding and strengthening broadcasting and broadband together should be the driving goal of the Federal Communications Commission (FCC), according to a recent filing from NAB and the Association for Maximum Service Television (MSTV). In joint reply comments filed on April 25 in response an FCC Notice of Proposed Rulemaking (Notice) designed to lay the groundwork for a possible incentive auction of some broadcast spectrum, NAB and MSTV reiterated earlier calls for a holistic approach to spectrum management, and to broadcast spectrum reallocations in particular. The Notice proposes new channel sharing rules that would allow two or more broadcasters to share a 6 MHz channel, and asks for comment on how to improve VHF reception in the digital age. NAB and MSTV contend that these questions cannot be handled in isolation of other larger questions like how a shift from free broadcast to paid wireless broadband could impact consumers.

The NAB/MSTV comments also counter as erroneous several of the arguments and claims made in filings by wireless companies and their Washington representatives, including the argument that the broadcast industry is not innovating and that cellurization of broadcasting would improve efficiency. Attached to NAB/MSTV comments is a new study from former FCC official Uzoma Onyeije – Solving the Capacity Crunch: Options for Enhancing Data Capacity on Wireless Networks – that questions the claim made in the National Broadband Plan that the United States is facing a "spectrum crisis." The study shows how new technologies and innovations can solve capacity issues on wireless networks without a radical reallocation of broadcast spectrum.