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Comments
Filed in Incentive Auctions and Part 74 Wireless Microphones Proceedings
On January 25,
2013, comments were due on two important FCC proceedings that will
significantly impact the future of broadcasting.
Incentive
Auctions. NAB submitted comments in response to the FCC's
Notice of Proposed Rulemaking on Expanding the Innovative
Opportunities of Spectrum Through Incentive Auctions in Docket
No. 12-268. This proceeding implements the Middle Class Tax Relief
and Job Creation Act of 2012 (Spectrum Act) in which Congress gave
the FCC authority to conduct an incentive auction of broadcast television
spectrum. The incentive auction has three parts: 1) a "reverse
auction" in which broadcast television licensees submit bids
to voluntarily relinquish spectrum in exchange for payments; 2)
a reorganization or "repacking" of the broadcast spectrum
to free up a portion of the UHF band for wireless broadband; and,
3) a "forward auction" in which wireless carriers will
purchase spectrum.
NAB comments are intended to ensure that FCC abides by the broadcaster
protections contained in the Spectrum Act. A summary of NAB's major
points are:
- Implementing a first
of its kind incentive auction is a daunting task and rather than
creating artificial timetables the FCC should strive to get the
auction right as opposed to done.
- The Spectrum Act requires
international coordination prior to conducting an auction and
the FCC should coordinate with Canada and Mexico as soon as possible
to permit repacking as well as the introduction of new wireless
services.
- FCC should expeditiously
release the software it intends to use in any repacking so that
it may be tested by all interested parties and to verify its accuracy.
- NAB points out that
the FCC's proposed lead proposal with regard to a band plan is
fatally flawed technically and overlooks or ignores significant
engineering problems such as having high powered broadcast operations
in the duplex gap will result in interference to both broadcasting
and wireless operations.
- FCC must update its
key goals to better reflect Congressional intent and protect viewers.
For example, key goals should include protecting the many millions
of over-the-air television viewers and minimizing the number of
stations that have to change channels in any repacking.
- The repacking process
must be simple, transparent and robust. The FCC must discuss in
detail and release any repacking model and software.
- Besides making any
software available, the Spectrum Act requires that the FCC make
all reasonable efforts during repacking such that broadcasters
are not harmed and that stations retain the same coverage and
same population. In this regard, NAB supports adopting the FCC's
Option 2 proposal provided the amount of new interference to any
station is capped at 1% and every effort is made to not add any
new interference to stations that are currently experiencing 10%
or more interference within their service areas.
- Construction permits
and station modifications necessitated by the DTV transition should
be fully protected.
- NAB noted that the
FCC's lead proposal for a band plan that placed high power television
stations in the duplex gap between wireless up and downlinks was
fatally flawed and would result in interference to both broadcasting
and broadband operations; and that the variable aspect of the
band plan (having different spectrum amounts in different locations)
is unworkable. NAB notes the variable approach would result in
interference and would require large protection zones to prevent
interference making the plan spectrally inefficient.
- NAB stated
that a band plan with nationwide contiguous spectrum blocks for
both wireless and broadcasting is the simplest, most flexible
and most beneficial approach for broadcasters, wireless providers
and, most importantly, American consumers.
- FCC must maintain
two dedicated channels for wireless microphones and allow licensed
Part 74 operations to operate on any new unlicensed spectrum with
protection from White Space devices.
- Finally, the FCC must
ensure that broadcasters are reimbursed for all reasonable costs
in a timely, uniform and equitable manner.
A copy of NAB's comments
can be found at http://apps.fcc.gov/ecfs/document/view?id=7022111954.
Reply comments in this proceeding are due March 12, 2013.
Wireless Microphones. The second item concerns the
use of wireless microphones and other Part 74 operations and affects
both TV and radio broadcasters.
NAB submitted these comments in response to an FCC Public Notice
in which the Commission's Wireless Telecommunications Bureau and
Office of Engineering and Technology seek to update and refresh
the record in the "Wireless Microphone Proceeding."
See Public Notice, WT Docket Nos. 08-166 and 08-167 and
ET Docket No. 10-24, DA 12-1570 (Oct. 5, 2012).
In the Public Notice, the Commission asked about expanding the
eligibility for licensing wireless microphone users under Part
74; whether it should eliminate the two "safe harbor"
channels established in the TV White Space rule making; and whether
to require a transition to digital wireless microphones.
Eligibility. In its comments, NAB noted and gave examples
of the important functions Part 74 equipment plays in the production
of broadcast programing and electronic news gathering (ENG). NAB
supported a limited expansion of Part 74 licensed wireless microphone
eligibility for four limited categories of users: theaters, live
music producers, government bodies, and houses of worship; subject
to restricting unlicensed wireless microphones in the television
band. NAB noted that these four categories were proposed in its
earlier filing.
Safe Harbor Channels. NAB supported maintaining the two
safe harbor channels. It noted that these channels were established
to ensure an interference-free home (from TV White Space devices)
so that unscheduled wireless microphone operations such as those
used in ENG can be accommodated. NAB noted that with the proposed
repacking and reduction of available TV spectrum as a result of
Incentive Auctions these two channels will become even more important.
If the safe harbor channels are reduced, NAB stated that the TVWS
protections must be improved to protect ENG and other unscheduled
events.
Digital Microphones. NAB stated that a decision to transition
to digital microphones is premature and there is not enough real
world experience with these devices. NAB notes that besides the
number of microphones that can operate in a TV channel, other
factors such as communication range, audio quality, roboustness
to interference, latency and signal degradation need to be taken
into account. NAB also noted that many broadcasters recently undertook
major investments in new equipment due to the involuntary transition
of vacating channels 52-69. NAB agreed that it is important to
explore this issue but that a transition is premature.
A copy of NAB's comments can be found at http://apps.fcc.gov/ecfs/document/view?id=7022112095.
Reply comments are due March 12, 2013.
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