The National Association of Broadcasters has told the FCC that its proposal to reserve a channel for unlicensed, so-called 'white spaces," devices in the TV band after the incentive auction will thwart innovation and harm LPTV's and translators.
The FCC is proposing that in any TV market where there is an available channel after the post incentive auction repack, it should go to unlicensed, which means that more licensed LPTV's and translators, which are not protected in the repack, could be sent packing or shuttered.
In reply comments on the proposal filed with the FCC Oct. 30 (the deadline), NAB said the addition of unlicensed 'white space" channels is speculative at best, while the costs to important local service provided by LPTV's--including religious programming and programming to diverse audiences--and translators are very real.
"Despite the passage of more than five years since the adoption of the current framework for white spaces operation, there are only approximately 600 white spaces devices actually in operation today across the entire country," NAB told the commission. "It is unclear what value, if any, many of these devices are actually providing."
It points out that some of the promised "Super Wi-Fi" hotspots the FCC touted in setting aside unlicensed spectrum don't even qualify as broadband under the FCC's speed definitions. "[A]fter five years, the best the white spaces industry can do is deploy rickety Internet service in a few areas with fewer than 600 customers," NAB said.
NAB says that if T-Mobile is so fond of unlicensed spectrum, the FCC should open channels in the wireless band, rather than the broadcast band.
NAB said the vacant channel proposal would just be handing spectrum to Google and Microsoft, both of which favor the unlicensed channel reservation, and that the FCC can't do so without harming broadcasters.
NAB said it is a false notion that the vacant channel proposal has no victims, calling it an unprecedented spectrum handout.
"If Google and Microsoft wish to structure their business models around access to spectrum, they should not count on the government to provide them with an expansive testing ground with no discernable public interest benefit; rather, they should participate in the incentive auction the FCC is using to create this new neighborhood in the first instance."
The innovation the NAB said the proposal could stifle is the ATSC 3.0 transmission standard, whose rollout it says could be severely hampered by taking another channel away from broadcasters in already compressed spectrum space.
To check out more of NAB's arguments, go here (http://www.nab.org/documents/newsRoom/pdfs/103015_Vacant_Channel_Replies...).