While stating they want to be part of the solution, the broadcast industry filed comments with the FCC last week expressing doubt about the feasibility of a plan posed by the CTIA-The Wireless Association and the Consumer Electronics Association (CEA) to use a low-power distributed transmission system (DTS) to provide nationwide access to broadband service.
The NAB and the Association for Maximum Service Television (MSTV) said they find the CTIA plan “impractical” and also called the FCC’s assumption that a lack of spectrum is the key impediment to increased competition in broadband “particularly problematic.”
“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 delivery system of over-the-air DTV, the broadcast groups wrote in their filing.
They said the CTIA/CEA proposal “drastically underestimates the cost burden associated with such a transition, while overestimating the spectrum yield,” and that the costs of implementing a DTS “would be orders of magnitude higher than the estimates provided by CTIA/CEA.” “The proposal would not make available significant amounts of contiguous spectrum in the congested areas where the wireless industry claims the greatest spectrum shortfalls,” they said, even if transmission spacing requirements were substantially reduced.
The NAB and MSTV said they do agree with several aspects of separate submissions filed by the Department of Justice (DOJ) and the National Telecommunications and Information Administration (NTIA), including the DOJ’s call for greater use of secondary markets in spectrum and the NTIA’s call for a spectrum inventory analysis.
NAB and MSTV said that they “agree that a comprehensive inventory of present and future spectrum availability and usage is necessary.” 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.
