TV Spectrum Sharing Envisioned by FCC Seen Doable
A TV spectrum paper by FCC broadband staffers released Monday to little fanfare drew mixed reviews from broadcast lawyers who closely read it and engineers just beginning to parse it. Consumer electronics and wireless groups, seeking spectrum repurposed from broadcasting to wireless broadband, praised the paper, which is at http://xrl.us/bhor2p. The 60-page paper was posted Monday on the website of the National Broadband Plan but no news release accompanied it, so lawyers and engineers still were studying it Tuesday.
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By showing how stations could voluntarily share the 19.4 Mbps data stream each 6 MHz licensee can transmit, the paper “represents the start of the process -- not the conclusion,” Chief Julius Knapp of the Office of Engineering & Technology wrote in an accompanying blog at http://xrl.us/bhor3b. “It is entirely possible, and perhaps even likely, that the best ideas on how to repurpose TV broadcast spectrum are yet to be developed or put forward. We invite readers to comment on the technical paper through this blog and to participate in forthcoming rulemaking proceedings.”
HD broadcasts need 6-17 Mbps and standard definition broadcasts need 1.5-6 Mbps, the paper said, citing earlier comments on a broadband staff public notice. That means “up to six stations that do not broadcast in HD may choose to share a channel in a given market following a voluntary, incentive auction,” the paper said. It estimated the value of terrestrial TV at $8.9 billion to $12.2 billion, or 11-15 cents per megahertz-pop. That compares to the $1.28 paid on that basis, on average, in the 2008 700 MHz auction, the document said. That’s an “estimated ten-fold disparity in economic value between spectrum used for mobile broadband and spectrum used for” over-the-air broadcasting, it continued.
Those figures don’t seem to account for “the uniqueness of broadcasting,” and the comparison isn’t an “apples to apples” one, said industry lawyer Lauren Lynch Flick of Pillsbury Winthrop. The paper doesn’t attempt to quantify the “ability to reach large groups of people all at once” and “they're discounting efficiency by saying broadcasters can’t use all the channels, so that equates to an inefficiency discount in the value of the spectrum in the way they're doing the math,” she said. By not discussing spectrum fees or license renewals, the paper “seemed to take some efforts to change the tone with regard to broadcasters, but the outcome is the same,” Lynch Flick added. “This is only a slice of what they're thinking, so you can’t extrapolate too much from it."
Packing 6 SD signals into 6 MHz could work, but may not leave enough room to account for higher bitrates with complicated programming like sports and cartoons with lots of action, said engineer Timothy Sawyer of Mullaney Engineering. “They're talking about average programming, not peak demand. So where’s the overhead?” From what President Donald Everist of the Cohen, Dippell and Everist engineering firm has heard, such packing is possible, he said. “It’s going to be a function of the equipment, and that’s where as far as I know the equipment is not sufficiently tested” to know if it could handle two HD stations or six SD broadcasters on the spectrum now used by one broadcaster, he said. “It’s going to be a challenge,” he added, laughing.
CTIA backs “recent activity at the” FCC to continue investigating how to maximize the use of the broadcast spectrum, including the paper and an upcoming engineering event, the group said Tuesday. “This paper and forum are very positive steps toward making the Commission’s goals of finding” 500 MHz within 10 years possible, it said. CEA called the paper “important” and said it “makes a compelling factual case for all stakeholders to embrace the voluntary auction of underused broadcast television spectrum to address our nation’s looming mobile broadband crisis.” The group is “heartened by the new analysis unveiled in this paper that TV stations choosing to share their existing spectrum could ‘continue to broadcast in HD while sharing a channel,’ an important fact given prior statements by some corporate entities that such frequency sharing was not technically feasible,” it said.
The NAB is reviewing the paper, a spokesman said. It “looks forward to working constructively with the FCC on fact-based findings, mindful of the importance and enduring values of free and local television to the American people,” he added. An official at the Association for Maximum Service Television didn’t reply to messages seeking comment. Lawyer Peter Tannenwald of Fletcher Heald, representing multi-frequency network (MFN) technology developer CTB Group, was happy the report saw the importance of those networks, he said. “The effort to repack or reallocate TV spectrum may be premature until MFN technology is better developed. The FCC should be take care not to rush into action that may work at cross-purposes to the best solution to the problem.”