Working Toward an Effective Band Plan

Today AT&T, the National Association of Broadcasters and Verizon jointly posted the following blog:

The TV broadcast spectrum incentive auction proceeding raises some of the most difficult engineering challenges the FCC has ever faced.  One thing is clear:  a successful auction must start with an effective band plan.  A band plan must seek to mitigate interference challenges to the greatest extent possible while offering blocks of spectrum best suited for deployment by U.S. wireless carriers.  Otherwise, it will drive down the value of the spectrum and likely undermine the auction’s success.

With that in mind, broadcasters, wireless carriers and equipment manufacturers have spent an enormous amount of time, energy and expense reviewing and commenting on the optimal framework for the 600 MHz band.  Hundreds of pages of comments have been filed, two industry consensus letters have been submitted and the FCC just recently convened a day-long workshop to discuss this issue.  The result is growing consensus for adoption of a “down from 51” framework that seeks to maximize paired allocations and build guard bands only to meet engineering necessity.  This approach reflects the best collective engineering judgment of the companies most affected by the auction, including those that will spend billions of dollars to purchase 600 MHz licenses at auction and billions more to develop and deploy the spectrum in U.S. wireless networks.

Despite these significant advances, on Chairman Julius Genachowski’s last day, a Public Notice was released seeking comment on two alternative band plan frameworks, one reversing the uplink and downlink allocations and one featuring time division duplex (TDD).  The first has absolutely no support in the record and the second adopts a technological approach contrary to the one proposed by the majority of U.S. carriers.  A fair reading of the Public Notice suggests that the FCC feels the consensus approach constrains its ability to adjust the band plan to meet market-by-market variations.  We believe, however, that this notice will consume resources better spent on dealing with other critical and as-yet-unanswered questions in this proceeding, such as how co-channel interference concerns could undermine the variability of any band plan and how the FCC plans to conduct an effective re-packing.

Each of us of course will respond to the notice, but we don’t anticipate any fundamental shift in positions we’ve already taken in the record.  In the meantime, we are concerned about the apparent disconnect between the FCC and the various industries that will be critically affected by this auction.  Nothing about this auction will be easy, and, if we are to succeed, we must all work together to find solutions best designed to respond to broadcast industry concerns while meeting wireless industry requirements.

Local Broadcasters: ‘Communicating Superstorm Sandy’

NAB is proud to present the second installment in a powerful video series demonstrating the vital role that local radio and television broadcasters serve as “first informers” in times of emergency.  This film, entitled “Communicating Superstorm Sandy,” documents the rapid response and lifeline support provided by local broadcasters when Hurricane Sandy ravaged the East Coast last fall.

Featuring dramatic storm footage and in-depth interviews with station staff, the mini-documentary charts the storm’s path from Washington, Baltimore, Philadelphia and New Jersey to New York and includes testimonials such as these:

“By harnessing our listeners and our own resources, we’re able to be that calm voice in a crisis.”  Jim Farley, VP News and Programming, WTOP, Washington, DC

“A local television station is out in the elements.  Our reporters, our anchors – they’re there to tell the true story – to keep the public informed.” Dan Joerres, president/general manager, WBAL-TV 11, Baltimore, MD

“In the immediate aftermath of the storm my way to communicate to the folks in my state was through the broadcasters…” New Jersey Governor Chris Christie

“We got so many phone calls from people that were saying that the only thing they had was their little transistor radio…That was their only connection to the outside world.” Sharon Dastur, program director, Z100 WHTZ-FM, New York, NY

“Yes, local news is the first line of defense.  I think it’s still the best conveyance method there is.”  Brian Williams, anchor/managing editor, NBC Nightly News

Many thanks to the film’s producers: Media Arts Professor Scott Hodgson from the University of Oklahoma and Chandra Clark, Ph.D. professor of telecommunications and film at the University of Alabama. Working with the Broadcast Education Association, Scott and Chandra, along with their students, compiled extensive footage and conducted more than 30 interviews for a video account of broadcasters’ heroic efforts in covering this horrific storm.

“Communicating Superstorm Sandy” follows an earlier video produced by the same team documenting broadcasters’ life-saving coverage of the devastating tornadoes that swept through Alabama and Missouri in April 2011.

In conjunction with this project, the following videos were also created to provide more in-depth content of individual communities and states affected by Hurricane Sandy and the critical role played by broadcasters:

Baltimore, MD

Belmar, NJ

New York, NY

Ortley Beach, NJ

Philadelphia, PA

Trenton, NJ

Washington, DC

Broadcasting as an engine for local economies

The following column was published in the May 21, 2012 edition of Politico.

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Congress has been consumed in recent years with contentious debate on how best to preserve and enhance free and local broadcasting — the original wireless technology — while making available airwaves that can also be used to alleviate the much-hyped ”spectrum crunch” for wireless broadband providers.

We think lawmakers struck the right balance with legislation signed into law earlier this year that provides incentives for television stations that voluntarily choose to go out of business, but which acknowledges the enduring and indispensable role that local broadcasting plays in the fabric of American society.

Lawmakers have good reason to want a healthy broadcast industry. Broadcast TV stations provide over 186 thousand jobs on an annual basis, which directly generates over $30 billion in gross domestic product. The ripple effect of TV broadcasting on the economy is even greater, with 1.54 million jobs and $716.43 billion in annual GDP attributed to the local television business.

Those who dismiss the value of local television – or who would like to see broadcasting’s role in society diminished — seem clearly motivated by a desire to replace a free service available to all with a fee service available to some.

Despite some of the criticism from broadcasting’s biggest critics, the facts are these:

– The number of broadcast-only TV households is actually growing, not declining. A Knowledge Networks study last year found more than 17 million households representing 45.6 million consumers receive television exclusively through over-the-air (OTA) broadcast signals; that’s up from 42 million OTA viewers just the previous year.

– The OTA-reliant population includes one out of four Asian-American and Spanish-speaking households and 17% of African-American homes. Pay TV “cord-cutting” is also a growing trend for younger viewers, and today one out of five adults age 18-34 is broadcast-only.

– Broadcast channels continue to attract the most television viewers, with over 95 of the top 100 rated primetime programs each week appearing on a broadcast network. Marquee events like the Super Bowl, Final Four, World Series, Academy Awards and the Kentucky Derby are all on broadcast TV, and available free to every American.

– When there’s an emergency weather situation, it is the local broadcaster that will be the source for information that often makes the difference between life and death. During the killer tornadoes that struck Joplin, MO and Tuscaloosa, AL last year, citizens and public officials credited local TV weather forecasters with saving scores of lives.

A thriving broadcast TV industry can be partly attributed to new services ushered in by the analog-to-digital transition. Over-the-air HD channels provide a higher-quality viewing experience than is delivered through cable. New multicast channels have also expanded choices on the television dial, often catering foreign-language or other niche programming to previously underserved communities. For instance, Bounce TV, led by Martin Luther King III and former U.N. Ambassador Andrew Young, launched recently as the first over-the-air broadcast TV network for African-Americans.

Broadcast services can also play a role in helping cellphone providers meet the increasing demand for video on their mobile devices. Broadcasters throughout the country are rolling out mobile DTV to provide on-the-go viewers with access to live and local programming anytime, anywhere on their smartphones, laptops and even the backseats of cars. Since mobile DTV is delivered to mobile devices using broadcasting’s ‘one-to-everyone’ architecture, data-hogging video would be kept off of mobile broadband’s inefficient ‘one-to-one’ infrastructure, freeing up space for less data-intensive services like text messaging and phone calls.

During last August’s earthquake in the D.C. region, cellphone networks experienced widespread congestion, delayed service and tens of thousands of dropped calls. Some of this congestion was caused by consumers using their phones to go online to find local news about the earthquake, oftentimes on local TV stations’ website. With mobile DTV, Americans can stay off mobile broadband networks for information and instead receive continuous, lifesaving information from their local broadcaster during times of emergency.

Complementing broadband with broadcast should not be the only approach to making spectrum usage more efficient. For months, NAB has called on the FCC to heed the calls of lawmakers such as Sens. Kay Bailey Hutchison, John Kerry, Olympia Snowe and Mark Warner to conduct a comprehensive spectrum inventory. This inventory should not just identify services set aside on the spectrum dashboard, but rather uncover what companies and government agencies hold spectrum and what they plan to do with it.

NAB has pointed out numerous instances in which telecom companies have purchased spectrum licenses but announced no plans to deploy it, raising questions about the pervasiveness of spectrum warehousing. Our calls were echoed only a few weeks ago by AT&T’s lobbyist. “Spectrum is in the hands of entities which either are sitting on it or not using it,” he told Politico. Even when spectrum is in the hands of those saying they need it the most, there are doubts that it’s being put to the best use. A recent study by Citigroup, the largest financial services network in the world, found only 192 MHz of the 538 MHz held by wireless carriers is in use.

Getting more spectrum into the hands of wireless carriers may not even be the best solution to alleviate mobile broadband congestion. According to an article in The New York Times, Martin Cooper, the inventor of the cellphone, believes technologies like wi-fi and smart antennas would make better use of the network. “Every two and a half years, every spectrum crisis has gotten solved, and that’s going to keep happening,” Cooper said. “We already know today what the solutions are for the next 50 years.”

Broadcasters stand ready and willing to work with policymakers to expand wireless broadband and address the other pressing issues facing the telecom industry. However, all stakeholders should reject glib and shortsighted solutions that might put in jeopardy the future of free and local TV. Broadcasting’s best days lay ahead as both an engine of local economies and as an integral part of tomorrow’s technological world.

Radio-enabled cellphones: A voluntary approach to public safety

Once again, some of our friends in Washington are misrepresenting NAB’s position regarding equipping and enabling FM chips in cellphones. To be clear, NAB supports the VOLUNTARY adoption of radio receivers in mobile devices. Doing so would allow wireless subscribers to access emergency information during a crisis, and on a device many always keep at arm’s reach.

Coming off one of the worst years on record for natural disasters, broadcasters believe the time is now for a reasonable and factual discussion on the merits of radio-enabled cellphones. Policymakers such as members of the Congressional Black Caucus and former FCC Commissioner Michael Copps agree on the need for an honest discussion on the issue. After all, when a storm is approaching, or a flood is rising, or an evacuation is ordered, shouldn’t we put aside special interest politics and do what’s best in the public interest?

We have seen wireless carriers express opposition to radio-enabled cellphones by arguing the text message-based alert system established by the WARN Act is sufficient during an emergency. That claim rings hollow when the fact remains that these same carriers have had six years to implement this technology, and it’s still not deployed! George W. Bush was barely into his second term when this cellphone carrier promise was made? Why are the carriers dragging their feet?

A text-based system may be capable of alerting cellphone users to approaching danger, but messages restrained by the WARN Act’s 90-character limit cannot possibly keep up with a rapidly changing situation. As NAB has previously pointed out, a 90-character message may only direct you to another source of information for breaking news and timely updates.

Shouldn’t Americans have readily available access to a service that can provide up-to-the-second information when lives are at stake? Radio can and does provide that type of service, and it’s time for all cellphone carriers to voluntarily make it available to their customers.

Time and again, local radio stations have proven themselves capable of providing a continuous flow of timely information during emergencies. In advance of Hurricane Irene’s approach, FEMA Administrator Craig Fugate went so far as to say “local broadcasters…are going to have the most detailed information about what’s happening in your community.” Even if the power goes out or one can’t reach a traditional radio in time, having access to that information through a cellphone can give people a chance to stay out of harm’s way.

Once immediate danger has passed, radio-enabled cellphones can still help a community in its rescue, rebuilding and recovery efforts. Following the devastating tornado outbreaks in Missouri and Alabama last year, local radio stations became a community forum and a lifeline for survivors. People called into the stations searching for missing loved ones. Those capable of lending a hand offered their service through broadcast airwaves. Families that lost everything learned how to go about putting their lives back together.

Unfortunately, many were not able to access these critical communications if they did not have a battery-powered or car radio. Radio-enabled cellphones would put this time-sensitive information in the hands of many more people.

Radio receivers also allow broadcasting to relieve strain felt by wireless networks when data demands go up before, during and after an emergency. Rather than strain a congested network, users could access local radio stations on their phones and find the critical information they are seeking. For all their clamoring for more spectrum for mobile broadband, it’s unfathomable that wireless carriers would oppose a service that could free up airwaves to meet higher-than-normal demand.

Despite the benefits of radio chips and the overwhelming evidence the public would support the service, many wireless carriers claim there is no consumer demand for radio receivers. Apparently they never got the memo from smartphone manufacturer RIM, which recently announced it is equipping two of its newest BlackBerry models with FM radio capabilities. According to Inside Radio, Arun Kumar, RIM’s senior product software manager for multimedia, said the company made the decision because, “A lot of customers have been asking for FM for a while, so we took that to heart. We basically just listened.”

It is time for more wireless carriers to listen as well. Broadcasters take seriously our role as ‘first informers,’ and we are committed to working with wireless carriers to expand the availability of broadcast radio service in mobile phones.

Broadcasters: America’s ‘First Informers’

Every day across America, local radio and television broadcasters serve communities in extraordinary ways: raising millions of dollars for charity, rescuing kidnapped children with AMBER Alerts, and creating awareness about important health and safety issues through public affairs programming.

Regardless of individual broadcasters’ level of commitment to public service, there is no role stations embrace more seriously than that of “first informer.” Indeed, during times of crisis, no technology can replicate broadcasting’s reliability in reaching mass audiences. It is also during these times when an ethos prevails among broadcasters — an ethos that compels stations to go “the extra mile” for the safety and well-being of viewers and listeners.

2011 was no exception. The year included devastating tornadoes, a rare East Coast earthquake, wildfires, Hurricane Irene and other severe storms and flooding. Through it all, local radio and television stations were a reliable lifeline, preempting regular programing with news coverage and life-saving information.

When Hurricane Irene was creating dangerous conditions along the East Coast, local TV and radio combined boots on the ground reporting with social media updates to keep viewers informed on the storm. FEMA Administrator Craig Fugate recognized this role when he told Americans to turn to their local TV and radio stations for information about the impending storm and to receive important updates from first responders.

In April, Alabama and Missouri were devastated by the worst tornado outbreak in 40 years. In the span of a few hours, entire neighborhoods were destroyed and hundreds of lives lost. Thousands were left homeless. Radio and television broadcasters were instrumental in saving lives with tornado warnings and emergency and disaster relief information. They also played a critical role in the recovery and rebuilding of communities in the aftermath of the storms.

These feats of courage, dedication and generosity demonstrated by local broadcasters are captured in this short film produced by talented media arts professor, Scott Hodgson, and his students at the University of Oklahoma, along with Chandra Clark, professor of telecommunications and film at The University of Alabama. Working with the Broadcast Education Association, Scott and Chandra compiled stunning footage for a video account of broadcasters’ response to these horrific tornadoes.

CTIA Diminishes Broadcast Diversity. Really?

Sometimes statements get made inside the Beltway that are so shockingly arrogant that one has to step back and ask: Really?

That moment came after yesterday’s NAB news conference to highlight the launch of The Future of TV Coalition — a coalition formed to promote the use of digital television spectrum to help spur program diversity on free, over-the-air television. The event featured former United Nations Ambassador and Atlanta Mayor Andrew Young, who has co-founded with Martin Luther King III, a majority-owned African-American broadcast network – targeting African-American viewers – called Bounce TV.

Bounce — which is now available to half of all America and 65 percent of African-American homes — will be launching on Channel 9 in Washington, D.C. by Jan. 1. It is just one example of the creative ways that broadcasters are using digital TV spectrum to serve diverse audiences. Also at the news conference was Carmen DiRienzo of Vme Media, a network devoted to serving Hispanic TV viewers with quality programming on public TV, and representatives of companies that are using DTV-2 “multicast” channels to deliver multi-cultural and multi-lingual programming to the melting pot of viewers that are today’s America.

The members of the coalition, who reach African-American, Hispanic, Asian-American, senior, rural, young and new Americans, believe that it’s critical that they reach their audiences using authentic voices from the communities they represent. And digital broadcasting is the vehicle to do just that.

For example, many of the multicasting channels in the top 25 U.S. markets are foreign language. In Los Angeles, there are 48 DTV2 channels, and 18 are foreign language offerings, broadcasting in Spanish, Chinese, Armenian, Korean, and Vietnamese. In Washington, D.C., foreign-language and ethnic channels include broadcasts in Russian, French, Japanese, Spanish, Arabic and Chinese.

But apparently CTIA – The Wireless Association has a problem with that.

After the NAB news conference, CTIA released a statement that reads: “When you have to form a coalition to talk about your future, perhaps it suggests you don’t have one.”

Ponder that for a moment.

The successful DTV transition paved the way for a new generation of broadcasters to innovate and serve a new, diverse generation of viewers. And participants in yesterday’s NAB event clearly demonstrated that the future of TV is one where young Americans have the opportunity to have a seat at the table. This is an America where traditionally underserved communities have opportunity to invest, innovate, and expand their voices and reach within their own communities. These networks and programs will reach a new pool of viewers, advertisers, investors – and ultimately will create more economic opportunity and jobs across the U.S.

It’s regrettable that CTIA – on the heels of the dedication of the Martin Luther King, Jr. memorial – would presume to diminish the importance of start-up networks designed to serve previously underserved audiences.

NAB sees Bounce as the embodiment of the bright future of television, and we will continue to support the creation and growth of broadcast businesses that serve minority viewers.

What’s the Best Use of Broadcast Airwaves?

The following column was published in the July 14, 2011 edition of Missouri News Horizon.

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As the debate rages in Washington, DC over auctioning free and local broadcast television airwaves for fee-based wireless broadband applications, one of the questions being pondered is, “What’s the highest and best use of this valuable resource?”

The answer is: “It depends whom you ask.”

If you queried the citizens of Alabama, many would respond: “For emergency weather warnings, because it was local TV weather forecasters who saved our lives.”

Ask those who rely exclusively on broadcasting as their only source for television, and they might answer: “For free TV, because it is the best bargain anywhere. I watch news, public affairs programming and the best, most popular entertainment, and it doesn’t cost me a dime.”
Those in the growing pay-TV “cord-cutting” movement might say: “To supplement my online TV viewing with live sports and free TV, and to end an unpleasant relationship with my subscription-TV provider.”

America’s growing immigrant population — being served by an exploding number of foreign-language channels — might answer: “For news about my culture and heritage, and programming tailored to my family and me.”

Simply put, broadcast television has something for everyone.

Even in pay-TV households, over 90 of the top 100 primetime programs each week are on a broadcast channel.

Interested in sports? Last time I checked, there were apps for that, including the NFL, NCAA football and basketball, and marquee events like the Super Bowl, Final Four, World Series, the Masters and the Kentucky Derby — all exclusively on broadcast television.

And when there’s breaking news, an Amber alert child that needs to be rescued, or a weather emergency, Americans tune to local broadcasting for information that can be the difference between life and death.

Those of us in broadcasting are somewhat bemused by the notion that local television is “yesterday’s technology.” Never mind the explosive growth in TV antenna sales, the roaring broadcast advertising market, or that poll after poll shows Americans rely on local television as their No. 1 source for news. Never mind that as a “one-to-everyone” delivery system, broadcasting is far more efficient at delivering video than are the “one-to-one” cell phone and Internet service providers. The “broadcasting is dead” crowd has made up its mind, and, by golly, facts are not going to stand in the way.

What is perhaps most disappointing in this debate is the dismissive treatment of those Americans exclusively reliant on free TV. Nationally, that number grew four million from last year to 46 million viewers – 15% of the television-watching population – and will continue growing as consumers cut the pay-TV cord and reject costly monthly subscriptions.

New research found that about one out of four Asian-American and Spanish-speaking households and 17% of African-American homes rely solely on over-the-air broadcasting. One out of five adults age 18-34 is broadcast-only. Milwaukee, Boise, El Paso and South Bend are just a few of the cities where OTA penetration ranges from 20% to 32%. Are those people not important? Should their TV viewing suffer to accommodate faster app downloads in Manhattan?

Just two years ago, broadcasters transitioned to digital and high-definition, which offers limitless opportunity for local stations to reinvent their business model and better serve viewers. Broadcasters are rolling out mobile DTV to provide on-the-go viewers with access to live and local programming anytime, anywhere on their smartphones, laptops and even the backseats of cars.

To be clear: broadcasters are ready and willing to work with all interested parties in expanding wireless broadband. However, it is important for policymakers to reject shortsighted solutions, and to recognize that local economies are reliant on broadcasters and local advertising as an engine for economic growth. We must recognize that broadband and broadcast are not mutually exclusive, and that both broadcasting and broadband are needed to address the nation’s growing communications needs. The promise of digital television should not be sacrificed on the altar of a national broadband plan seemingly premised on a belief that fee-based national broadband services are more valuable to society than free and local broadcasting.

In the final analysis, the question should be asked: What part of free and local television do broadcasting critics not like?

Vast? Yes. Wasteland? Not a chance.

Fifty years ago this week, former FCC Chairman Newton Minow addressed broadcasters at the NAB Show and declared that television was a vast wasteland failing to serve the public interest. While the merits of his argument were debatable then, those that would make a similar case about the current state of broadcast television would be embarking on a fool’s errand. Today, broadcast stations play an integral role in local communities and fulfill their commitment to the public by offering programming that educates, enlightens, and entertains.

While the TV landscape has changed dramatically since half a century ago with the rise of cable, satellite, the Internet and alternative viewing platforms, broadcasting remains remarkably resilient as the number-one source of entertainment and news for all television viewers. Week after week, over 90 of the top 100 most-watched primetime programs are found on broadcast stations. These programs include brilliant and smartly-written comedies like “The Simpsons,” “Modern Family” and “30 Rock” that match the best satire that TV has ever offered, along with compelling dramas like “The Good Wife” and “Friday Night Lights.” Complementing scripted fare are weekly programs like “American Idol,” “The Amazing Race” and “Dancing with the Stars” that consistently draw mass audiences that dwarf the viewership of cable network fare.

In February, Super Bowl XLV became the most-watched program in the U.S. of all time, drawing a U.S. TV audience of 111 million. Last week, so many viewers were watching the royal wedding on television that Internet traffic was down 10 percent for the day.

Indeed, broadcast TV serves as a window to the world, despite the growth of 24-hour news channels and social networks. When news happens at home and abroad, chances are that broadcasters will be covering it. Just last week, Pew Research found that by more than a 3-to-1 margin, Americans learned of Osama bin Laden’s death from a broadcast outlet rather than an Internet news or social networking site. In addition, over 70% of the 57.9 million people who watched President Obama’s address to the nation Sunday night were tuned to broadcast stations. Those numbers fall in line with other evidence that Americans’ depend on broadcasting over cable news during significant national events, such as presidential inaugurations and State of the Union speeches.

Local television news is consistently rated by a vast majority of Americans as their No. 1 source for news. Broadcasters take seriously our role in educating the public during campaign season, providing free airtime offers and debate coverage that often is re-broadcast on cable news outlets like CNN and C-SPAN.

The important work broadcasters perform covering significant news is not just confined to a handful of occasions throughout the year – local and national broadcasters provide consistent coverage of important issues on a daily basis. Network evening news commands an audience of more than 20 million viewers each and every night. Television is a showcase for the power of investigative journalism such as “60 Minutes,” which averaged 13.2 million viewers per week during 2009-2010. Programs such as “Dateline NBC” and “Nightline” are also consistent showcases for quality journalism, and few would question the week-in and week-out excellence of “Meet the Press,” “This Week” and “Face the Nation.”

At the local level, broadcasters invest heavily in news-gathering so they may provide insight for residents about the issues that affect them. Local broadcasters are also reliable and credible in a crisis, embracing the roles of first informer when disaster strikes. Cases in point are AMBER Alerts, a program voluntarily launched byDallas broadcasters in the mid-1990s following the brutal abduction and murder of a young Texas girl. Hundreds of kidnapped children have been rescued by broadcasters via AMBER Alerts. Those who suggest TV is a ‘vast wasteland’ should ask themselves: How do you put a price tag on saving the life of a kidnapped child?

Or ask citizens in the South whether they view broadcasting as a wasteland in light of the heroic coverage of devastating tornadoes two weeks ago. Countless people in Alabama and elsewhere survived the tornadoes thanks to the up-to-the-second information broadcasters were able to provide. The legacy of the local broadcaster is this: to provide credible and continuous lifesaving information  that no other medium can match. And when the crisis is over, broadcasters are there to lead the recovery from the devastation. 

In his speech a half-century ago, Chairman Minow said, “I believe that the public interest is made up of many interests. There are many people in this great country and you must serve all of us.” While broadcasters have always aimed most of their programming at a wide swatch of the American public, the analog-to-digital transition opened new doors for broadcasters to cater to previously underserved communities. In addition to allowing broadcasters to offer hyper-local programming, secondary digital channels can be aimed at specific groups, including minority populations that rely on the channels to stay connected to their community.

At of the end of 2010, the percentage of commercial multicasting stations had increased to 71%, or 849 of the 1,196 full-power commercial stations, doubling the options for viewers with 1,240 additional digital channels. Many of the channels feature foreign-language programming, especially in major metropolitan areas with large populations of immigrants. In New York alone, 13 of the 28 secondary digital channels are foreign-language. In Los Angeles, of the 48 multicast channels, 18 are foreign language programming, airing programs in Spanish, Chinese, Armenian, Korean, and Vietnamese. Right here in Washington, D.C., nine of the 20 multicast stations are foreign-language and ethnic channels, including broadcasts in Russian, French, Japanese, Spanish, Arabic and Chinese. And just last week, Bounce TV, the nation’s first over-the-air broadcast TV network designed exclusively for African-American audiences, announced that it will launch in the fall on Raycom’s secondary multicast channels in 26 markets.

Fifty years ago, UHF broadcasting, pay TV entertainment, and satellites capable of beaming local programming to the other side of the world were in their infant stages, merely glimpses into television’s future. In his speech, Chairman Minow pledged FCC support for these burgeoning services, promising “that they shall be explored fully, for they are part of broadcasting’s New Frontier.”

Today, broadcasting again heads into a New Frontier thanks to the analog-to-digital transition. The transition freed up spectrum that enabled broadcasters to adopt innovative services such as multicasting, 3D programming and mobile DTV, which will change the ways viewers access local news, weather, entertainment, and emergency lifeline information. As options are explored to reallocate some of broadcasters’ spectrum for broadband use, policymakers must recognize the enduring value of a free and local television service that is the envy of the world. Policymakers should stand behind broadcasters’ efforts to revolutionize this service and reject policies that sacrifice the promises of the DTV age.

Television is a ubiquitous medium. Along with free and local radio, there is probably no other technological commodity found in more homes than TV. It has the ability to bring communities together for a single event, to educate people about local and global issues, to serve as an emergency lifeline during critical situations, and to galvanize residents behind an important cause. 

From Bangor to Boise to Birmingham, free and local television has been there through triumph and tragedy, from miraculous moon landings to shocking Space Shuttle explosions, from September 11 to presidential inaugurations, from catastrophic tornadoes to courageous mine rescues. Even in this frenzied world of Facebook and Twitter, broadcasting provides a communal gathering place for celebrating the human spirit. Our best days are still ahead.

You Don’t Have to Be Einstein to Understand Broadcasters Are Efficiently Using Spectrum

A bad combination last night — catching up on reading the latest in the broadcast spectrum debate followed by a book on the life and sayings of Albert Einstein.  Fell asleep, and dreamed of walking the tree-lined streets of Princeton with the Great Professor, discussing spectrum policy.  It went something like this:

Me: It’s frustrating — we’re getting the facts out there about television broadcasters being extremely efficient spectrum users but the message just isn’t sinking in.  Almost every other day somebody criticizes broadcasters for “squatting” on spectrum. It’s unsubstantiated rhetoric from the uninformed, but the future of broadcasting is at stake.

Einstein: “I never think about the future — it comes soon enough.”

Me: Well, the future may be coming pretty fast now for serious consideration of broadcast spectrum reallocation. The selling job for how simple it would be to reallocate spectrum from television broadcasting to mobile broadband ignores a lot of important details, but a lot of people are buying into it.

Einstein: “Everything should be made as simple as possible, but no simpler.”

Me: Exactly.  Here’s an example of an argument about the inefficiency of broadcasting that is just way too simple to be true.  The argument goes like this: Broadcasters have 294 MHz of spectrum available in Washington DC — 49 channels between channel 2 and channel 51 — and…

Einstein: But there are 50 channels between channel 2 and channel 51.

Me: Sorry, I shouldn’t have over-simplified.  Channel 37 doesn’t count — it’s reserved for radio astronomy.  Anyway, we have to deal with these armchair analysts who will argue that there are 49 broadcast channels available in Washington DC but there are only about a dozen or so television stations, so the rest of the spectrum is being wasted.

Einstein: Oh, I see what you mean.  So they ignore the fact that stations that operate on the same channel have to be a certain minimum distance apart so they won’t interfere with each other. And in congested areas, like the East Coast, the distance between cities is such that you just can’t re-use the same channels in nearby cities, so the total number of channels needed is a lot more than the number of stations in a given city.

Me: You catch on quick.  And that’s true for operating on adjacent channels too, since television receivers don’t have the ability to perfectly filter out station signals in nearby cities that use adjacent channels, although you can use adjacent channels for stations in the same city.  But that means, for example, you can’t use the same channels or adjacent channels in Baltimore and Washington DC, since they’re only about 40 miles apart.  And if you add a third city close by, and a fourth, those 49 television channels don’t really go very far, not when you’re dealing with the over 1700 stations in the country.  So this attempt at a common sense theory that broadcasting could get by with far fewer channels without reducing the number of stations or reducing the service areas of those stations just doesn’t fit the facts.

Einstein: “If the facts don’t fit the theory, change the facts.”

Me: That’s about the size of it.

Einstein: The adjacent channel angle is interesting.  How close adjacent channel stations can be to each other would be determined by the relative ability of receivers to reject those unwanted adjacent channel signals, no?  Are the interference rejection characteristics of the receiver population well known and reliable?

Me: Not to a great degree of certainty.  Funny you should mention receiver characteristics though.  The FCC has never adopted mandated receiver standards for wireless services.  But an official at the National Telecommunications and Information Administration (NTIA), which oversees government use of spectrum, just sent a letter to the FCC telling them that when designing new wireless services that will share the use of spectrum with other services, “one of the key steps in any analysis is identifying the interference protection criteria (IPC) of the incumbent receivers.” They also said “the FCC should seek comment on how the IPC values should be specified for incumbent receivers, and the specific IPC values to be used.”

Current and former technical FCC officials also talked about the need for receiver standards recently and noted that the topic of receiver standards is one that will be addressed, and recommendations made, by the FCC Technological Advisory Council — hey, I’m a member of that group. The second public meeting of the Technological Advisory Council is on Wednesday of this week.

In addition, NAB President and CEO Gordon Smith just sent a letter to key Congressional leaders pointing out that the FCC is starting to take notice that knowledge of receiver performance for rejecting interfering signals is critical to making the most efficient use of spectrum in designing wireless services.  Frankly, all this newfound interest in exploring obligations for receiver manufacturers to meet performance standards for the sake of efficient spectrum planning is a rather refreshing new approach.

Einstein: “We cannot solve our problems with the same thinking we used when we created them.”

Me: I’m not sure whether you’re being cynical or ironic, but I certainly agree with the sentiment. And I’m sure you’ll appreciate that it’s really hard not to be cynical about politicians and regulators insisting that a broadcast spectrum re-allocation process will be all-voluntary for broadcasters.  Participating in incentive auctions, assuming that Congress authorizes them, might be voluntary actions.  But to clear the significant nationwide spectrum swath desired by the mobile broadband providers, broadcast stations will need to be re-packed, or re-located, into a smaller band of spectrum, and voluntary is not the word to describe that wide-scale operation of forcing stations to change channels.

Re-packing the television channels to create cleared spectrum for mobile broadband without harming the incumbent broadcast service, if it’s possible at all, is a computationally intense math problem for really fast computers.  The FCC is developing this capability but all they’ve produced so far was released last June and showed really poor results — only one 6 MHz channel could be cleared nationwide by re-packing the existing broadcasters.  We’ve been waiting to see more refined results, or at least a detailed description of the Allotment Optimization Model’s algorithm for re-packing, but nothing has been made available so far.  If the computer model has something significant to offer, that would be a basis for further quantitative analysis.  Otherwise, this is more of a political debate.

Einstein: “Politics is for the present but an equation is for eternity.”

Me: That boils it down to the essentials. By the way, did you really say “Everything should be made as simple as possible, but no simpler?”

Einstein: Well, it’s certainly been attributed to me by a lot of people.  What I really said was:

“It can scarcely be denied that the supreme goal of all theory is to make the irreducible basic elements as simple and as few as possible without having to surrender the adequate representation of a single datum of experience.”

But it essentially means the same thing, if you reduce the words to being as simple as possible, but no simpler.

Me: That’s definitely irony, right?  Well, it was nice chatting with you today, even though it’s just a dream. I am infinitely indebted to you for your time and your insight about spectrum policy.

Einstein: “Only two things are infinite; the universe and human stupidity, and I’m not sure about the former.”

Me: I’m not touching that one.

Verbatim Quotes are Stubborn Things

It’s been said by cynics that the only real gaffe committed inside the Beltway is when someone actually tells the truth. That’s why we’ve gotten a chuckle out of the overheated protestations from our friends in the wireless industry after NAB submitted evidence from two top telecommunications industry executives suggesting that “Heck yes, we’re warehousing spectrum. So what?”

Let’s review the bidding: Dish Network CEO Charlie Ergen recently told investment analysts that his company made a speculative investment in spectrum because spectrum “has value, ‘just as an asset.’”

That’s not new verbiage from Mr. Ergen. Indeed, on a November 2010 earnings call, the Dish CEO said that his company bought spectrum 700 MHz from broadcasters “as a building block…a pretty good inflation hedge, and they’re not making any more of that spectrum. If we’re not able to strategically do something with that spectrum, there’s probably other people who are able to do that.”

According to the must read publication Communications Daily, Mr. Ergen elaborated on his investment: “I think one of the better things we did was that we resisted the temptation to go out and try to build it out and spend more money on the buildout for it without really knowing where we want to go…. I don’t know whether our timing’s right or not on 700MHz. At some point, that will be a valuable spectrum to somebody. And if we can figure out a way to use it, that’s good. If we can’t then somebody else will own it,” said Ergen.

Dish Network apparently isn’t alone in its desire to squat on valuable airwaves. Communications Daily reported on Jan. 28 that Time Warner Cable has no plans to deploy recently acquired spectrum. Paraphrasing recent remarks on an analyst call from Time Warner Cable Chief Operating Officer Rob Marcus, respected Communications Daily reporter Josh Wein wrote that the company “has no plans to sell, lease or use its AWS spectrum licenses. … The recent AT&T acquisition of Qualcomm’s MediaFLO spectrum bodes well for the value of the cable operator’s spectrum holdings.”

So there you have it: two massive telecom companies candidly admitting that they are in the business of sitting on valuable spectrum.

When NAB pointed out these obviously newsworthy and noteworthy comments, spin doctors at both Time Warner Cable and Dish Network circled the wagons. Predictably, this strategy of denial was embraced by other telecom companies and trade associations who are apoplectic over the possibility of a serious unbiased spectrum inventory. God forbid there would be a serious and thorough review of whether companies that were given or bought spectrum are actually following through on timetables and promises to deploy it. After all, that would not fit into their neat little “spectrum crisis” tale that they’re foisting on Congress.

The tap dancing of the telecom giants and their enablers brings to mind a famous scene in “The Wizard of Oz” where Toto pulls back the curtain and exposes the fact that Oz has — in fact — no magical powers.

In the movie, Dororthy and the Scarecrow were asked to “Pay no attention to the man behind the curtain” — just like America is expected to pay no attention to verbatim spectrum hoarding admissions from Time Warner Cable and Dish Network.