Broadcasters to Hill: Repacking, Sharing Could Hurt Hundreds of Stations, Millions of Consumers

Broadcaster to tell Congress viewer disruption could be 'unprecedented'
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The FCC's rejiggering of TV station spectrum
allocations as part of its broadband spectrum reclamation plan could adversely
affect a third or more of all TV stations, according to the prepared
congressional testimony of the broadcasting representative on the first of what
will be several hearings on the issue.

Robert Good of WGAL-TV Lancaster, Pa., who wears a lot of
hats as assistant GM, director of operations and chief engineer for the
station, is representing broadcasters at the Tuesday (April 12) hearing on
spectrum issues being held in the House Communications Subcommittee, which is
headed by a former broadcaster, Greg Walden (R-Ore.).

Good plans to tell the legislators that they need to
recognize that reallocation and repacking of spectrum would impose
"significant financial costs" and result in "a material
diminution of existing free, over-the-air television broadcast service."
He says a second digital transition could create "unprecedented"
viewer disruption, confusion and dissatisfaction."

His message will be one of cooperation, however, with one
big caveat. "Broadcasters do not oppose voluntary incentive auctions and
the reallocation of broadcast spectrum, if, in fact, the auction and
reallocation of broadcast spectrum is truly ‘voluntary,'" he says.

But the big issue is whether repacking and
"voluntary" are mutually exclusive. "For an auction process to
be truly voluntary, it must be voluntary both for those stations that elect to
participate in the auction and for those stations that elect to retain their
licenses and continue delivering to their communities the full panoply of
benefits of the digital transition," says Good. But if the repacking is
required of any station that doesn't want it, and that repacking materially
diminishes the service, that clearly fails the broadcasters'
"voluntary" test.

Good also paints a grim picture of potential loss from the
combination of reducing broadcasters footprint now that the commission has
allowed unlicensed devices to share the broadcast band.

"Now that the FCC has opened up broadcast bands for use
by so-called ‘white space' devices," he says, "local stations and
your constituents must now be prepared to cope with potential interference from
literally thousands of new unlicensed devices. Further reductions in channel
spacing would inevitably result in increased television interference and a
reduction in the use by your constituents of unlicensed devices in white
spaces. And if interference results from repacking, our viewers and your
constituents would lose access to the broadcast programming they currently
enjoy -- the full extent of that loss has not yet been determined by the

He also says the FCC's channel-sharing proposal, which the
FCC says would be voluntary, would result in even more signal loss and viewer

"[T]he above technical concerns do not begin to capture
the problems that would result if broadcasters are forced by the FCC to share
channels, as some have suggested," he says. "The technical challenges
and costs associated with that proposal would be even more complex, and would
impose even greater costs on stations and it would result in a greater loss by
your constituents of local television broadcast service."

Good argues that broadcasting is a robust service
relied on by 99% of the country--delivered over cable and satellite and online
as well as over-the-air. He points to his stations multicast channels, which he
says are not "marginal" services.

He also talks about the promise of mobile DTV. To date,
Hearst has used its multicast spectrum in two markets to deliver network
programming -- CW and ABC--to markets that lacked those network

But Good ultimately strikes a cooperative tone. "Our
company, the NAB, and broadcasters across the nation are prepared,
nevertheless, to work cooperatively with the Committee, with other Members, and
with the Commission to strike an appropriate balance in achieving the nation's
overall communications policy goals."

The FCC has said the reclamation process and incentive
auctions--compensating broadcasters for the move--would be voluntary, but the
definition of "voluntary" continues to be the key to the debate. Broadcasters
fear that reclaiming their spectrum to sell to wireless broadband suppliers
will leave them at a competitive disadvantage in a digital world where their
efficient one-to-many delivery system should be seen as a value-added, not a