Opinion: National Broadband Plan Recommendation 5.8.5 is Not in the Public Interest
I've received several e-mails in recent days regarding the FCC's National Broadband Plan (NBP) and its impact on free digital television broadcasting. Rather than answering many individual e-mails, I will simply make an overall post about the subject, in which I will respond to the various points made in the document.
First of all, as someone who lives in a rural area of Virginia, I am fully supportive of efforts to provide rural broadband, so long as it is done properly. I am a firm believer that we must run fiber optic cables to every home in the same way we ran electricity and telephone cables to every home. Though the chances of this are slim, it is the only way to ensure that Internet connected services, which become more and more important every day, are available to all. If I have only 4 Mbps available to me by 2020, as suggested in the NBP, that means effectively that HD video delivered by the Internet will not be available to me or to others in rural areas. Fiber optic cabling would prevent such inequality in connection speeds.
Now, on to the plan and its impact on over the air (OTA) television.
Recommendation 5.8.5: The FCC should initiate a rule-making proceeding to reallocate 120 megahertz from the broadcast television (TV) bands, including:
- Update rules on TV service areas and distance separations and revise the Table of Allotments to ensure the most efficient allotment of six-megahertz channel assignments as a starting point.
- Establish a licensing framework to permit two or more stations to share a six-megahertz channel.
- Determine rules for auctions of broadcast spectrum reclaimed through repacking and voluntary channel sharing.
- Explore alternatives—including changes in broadcast technical architecture, an overlay license auction or more extensive channel sharing—in the event the preceding recommendations do not yield a significant amount of spectrum.
- Take additional measures to increase efficiency of spectrum use in the broadcast TV bands.
These points are rather scary to read, as they essentially call for the decimation of over the air broadcasting. Reading further into this recommendation, we find that the FCC has decided this plan of action based simply on auction results. Simply put, people charging a subscription fee will pay more than those offering a free service based on advertising. Also, the sky is blue, and water is wet.
What auction revenue does not tell us is the value of the service being provided, nor the efficiency. Examining the efficiency, we find that broadcast television is the most efficient method for providing local emergency information and local news. If a local newscast is watched by 50,000 viewers, dividing 50,000 by the 6 MHz channel results in 120 Hz per person. Not megahertz, not kilohertz, but hertz. If that newscast has only 10,000 viewers, the result is 600 Hz per person. Even dialup internet access gets 4 kHz to play with and I suspect most readers know how sluggish dialup is.
Further, live events that many people are watching at once should be handled using broadcast. The Super Bowl and other live sporting events, in addition to live news coverage, new episodes of TV programs, all of these things are clearly things that a lot of people will want to watch all at the same time, and the best way to do this is through free, over the air broadcasting.
The FCC is very quick to dismiss Mobile DTV even though it has yet to get off the ground. Many stations that have expressed interest in testing the technology are still waiting to receive the gear, while some stations which were not on the initial list have begun ATSC-M/H transmissions. The standard was only finalized at the end of last year, and it takes time for receivers to be designed and manufactured and to appear on the market. For the FCC to dismiss it out of hand is exceptionally short-sighted; in comparison to the slow starts many other popular technologies today got, Mobile DTV is moving at light speed. Mobile DTV must be given a chance to fail or succeed in the marketplace before the FCC makes rash decisions on its viability as a service.
As far as value is concerned, in a way, broadcast television is becoming what HF communications and ham radio are: Not terribly important when the world is going swimmingly, but dependable and reliable when disaster strikes. In disaster situations like September 11, cell phone networks were overloaded, and if data networks were prevalent, they also would have been locked up. Broadcast TV, on its dedicated spectrum, was able to provide continuing coverage to the millions of people wanting to see it. If forced to depend on streaming video over packet switched networks, information would have been scarce due to overloaded servers and switches. In addition, broadcast TV stations have invested heavily in generators and redundant equipment in order to be able to provide these services even in the worst of circumstances. The same cannot be said for providers of Internet infrastructure.
There's also the question of how accurate the OTA usage statistics are. Now, I encourage others to correct me if I'm wrong, but I have been under the impression that if any one TV in a household is connected to cable or satellite, then the whole household is considered to not be using OTA. This means that any other TVs in the household dependent solely on OTA television are not counted. If my impression is correct, then what are the correct statistics for the number of OTA users? How many people would actually be harmed by the reduction or elimination of OTA choices? These things should be taken into account as well. More than 34 million converter box coupons were redeemed for only 12.6 million OTA households. I suspect this number also neglects homes with satellite TV which also make use of OTA reception for HD local channels.
It's pretty clear to me that broadcast serves an important purpose and is much more valuable in ways measured without dollar signs attached. With that said, some would then argue that the NBP is not calling for a complete dismantling of broadcast television (yet), and that it is wasteful. The question then becomes, "does broadcast need all the spectrum it has?" While I would argue that the answer to that is probably no, I also do not think that the NBP number of 120 MHz is a workable number, particularly in where the bandwidth is coming from. There are a number of broadcasters who are airing infomercials or would otherwise probably like to get out of the business and would accept some type of a buyout, which would shrink the number of broadcasters and make a smaller spectrum workable. On the contrary, I know many LPTV owners who are more interested in the art of broadcasting than the money involved, and I feel like they would reject a buyout.
One of the key goals is nothing more than "fix VHF." While I'm sure nobody would be opposed to making VHF work, the sad fact is that it's now too late. The transition is done, people have their antennas and converter boxes, and are not going to be willing to change things out again. If completely not allowed to keep all of the existing channels on both VHF and UHF, I would say to give up on VHF and take away that spectrum instead. In fact, I would argue that the best solution in that case would be to eliminate channels 2-21 rather than 31-51. Channels 2-6 have been largely abandoned by broadcasters, and channels 7-13 are proving themselves poor choices for reception as well. Both of these bands would be good for fixed wireless services into rural and mountainous areas where line of sight becomes a problem and outdoor antennas would be expected. Selected channels on 14-20 are already reserved in several major cities including New York and Los Angeles, and thus would be usable for wireless using narrower bandwidth applications.
As far as licensing multiple stations on a single transmitter is concerned, the bandwidth simply is not there. While some stations have successfully pulled off two HD services on a single channel (the NBP used the word "spectacular" which is not a word I would choose), nothing else then fits on the channel. New encoders would be required for many stations, 1080i would have to go away as a transmission standard due to its higher bandwidth usage, and what of stations that are already making full use of bandwidth? Stations with HD, one or more SD, and/or Mobile DTV? Stations with many subchannels targeting minority audiences? If the FCC had required that all the converter boxes produced for the transition would receive MPEG-4, we could transition everyone to MPEG-4 for video with relatively little discomfort and save a lot of bandwidth, but we're unfortunately three years too late to do that now.
I actually fully agree with the FCC on the subject of channel repacking, but someone has to pay for it, and it should not be the TV stations who literally just got finished rechanneling. If the FCC would like to pay for all that work to be done, more power to them. It would reduce interference and hopefully make reception easier. However, if the FCC also chooses to redefine coverage areas, then this plan could be an awful mistake. Stations are already way too close together in many places, and trying to pack them even closer would be a huge failure.
The NBP makes note of DTS and comments on it, but correctly notes that it does not work well yet and is very expensive. I do not believe the FCC would strongly push this unless some major advances in transmission technology took place and costs came way down, so I will not expend any energy discussing it.
While the NBP touches on a number of other points, I feel there is only one more that would be exceptionally important. Levying spectrum fees on users who offer a free service is fundamentally unfair and serves only to attempt to drive broadcasters out of business. This is the most damning part of the NBP, as it shows exactly what the FCC ultimately wants--an end to broadcast television. Once again, money proves to be more important than the public interest, as the poor who cannot afford subscription television services and the rural viewer who depends on OTA due to lack of availability of subscription services are again left in the cold while the wealthier people in big cities and the corporations serving them reap additional benefits. As broadband will make no difference to a poor person who cannot afford a computer, and will not be available to the rural users; both groups will lose video services as well as local news and emergency information they provide. And everyone will lose out as the super reliable broadcast infrastructure is replaced with much less dependable broadband infrastructure.
It is obvious to me where the current FCC's loyalties lie. The NBP says little about promoting competition between wireline carriers like cable and telephone companies, but lots about auctioning off as much spectrum as possible to the big telecom companies while slowly killing off broadcast TV. Much like the rest of our government, the FCC is run by lawyers rather than by experts and by money and politics rather than good sense. One can only hope that between people in Congress like Representatives Boucher and Dingell and Senator Snowe who understand the value and importance of free OTA television and the push of the broadcast industry to encourage citizens to make their opinions known, that the FCC will back off from this course of action and look instead to other areas to find spectrum and otherwise increase broadband penetration.