Noncoms to FCC: Hands Off Our Broadband

Broadcasters argue for on-air and broadband elements

over-the-air television away from a community undermines the promise of
universal service to that community." That was the message from
noncommercial broadcasters to the FCC, which sought comment on what the impact of reclaiming spectrum
from broadcasters for wireless
broadband would be.

Comments were
due Monday night.

of a household's financial resources or geographic location,it can receive
a unique and robust noncommercial service, including children's educational
programming. The free, over-the-air broadcast platform - with its unparalleled reach at no cost to consumers
- is uniquely able to deliver on this promise," said PBS, CPB
and the Association of
Public Television stations.  Noncoms
argue they need both the on-air and broadband elements to fulfill their

broadband service is one of the guiding principles behind the FCC's
investigation into reclaiming broadcast spectrum. Commission Chairman Julius
Genachowski has said that wireless broadband will be a big part of that equation, and wireless
companies say they need lots more spectrum. Broadcast spectrum is particularly
attractive because of its signal-propagation characteristics.

broadcasters have been making the same argument about their service, saying
over-the-air needs to be part of the media ecosystem.

In its filing,
Hearst pointed out that it had spent $120 million to convert its 35 stations to
digital. "Broadcasters must be given the opportunity to develop business
and technological models for the
bandwidth available in each station's 6 MHz channel," Hearst argues.
"And the fact that the real beginning of digital broadcasting has taken
place in the worst economic environment since the Great Depression should not be held against
broadcasters who, despite all of the heat-but little light- cast upon the
retransmission consent process, offer free local news, free local emergency information, and free local political
coverage based primarily upon the single revenue stream generated from
advertisers seeking to communicate with potential customers."

The FCC also
asked how the broadcast spectrum is currently being used to serve the public
interest. PBS and company said that 85% of member stations are broadcasting an
HD channel and 82% have at least
two standard-definition channels.

separately, Ohio State University weighed in in defense of its spectrum. The
school's WOSU said it is using its maximum spectrum allocation at all times,
saying it "has no excess (i.e. unused) channel capacity that it could "share" with other

"We urge
the Commission to find that our use of our television broadcast channel
efficient and productive, and abundantly serves the public interest," WOSU
GM Tom Rieland told the commission. "Our over-the-air transmission capabilities must be
protected in any effort that the Commission might undertake to allocate more
spectrum for wireless broadband systems."