Unfortunately, both actions add to the ever increasing list of examples of back and forth, he said/she said between these groups. The NAB has been playing catch-up ever since the CEA put forth its October 2009 report titled, “The Need for Additional Spectrum for Wireless Broadband: The Economic Benefits and Costs of Reallocations” by Coleman Bazelon. That report became the foundation for the public side of the FCC’s call for additional broadband spectrum. These megasize associations have been butting heads for years. But this issue has ratcheted the intensity to critical on the seriousness scale.
The most recent example of this to-and-fro is the NAB’s filing dated Jan. 27. The filing was in response to a Dec. 22, 2009, white paper from the CTIA/CEA. The white paper proposes that broadcasters transition from single large towers/high-power operation to multiple tower/low-power SNF operation.
The CEA/CTIA report states: “With this approach, initial estimates indicate that 100MHz-180MHz of spectrum may be freed for mobile broadband use across the country. The value of the new spectrum made available through such efficiency gains could range from approximately $35 billion and $70 billion. Notably, this concept would leave consumer equipment intact and preserves the entire 19.4Mb/s digital data stream currently available to full-power television stations.”
Naturally, the NAB refutes the CEA/CTIA claim. Section one of the NAB’s response says, “While well-intentioned, the CEA/CTIA proposal is infeasible and will not free up significant spectrum.”
Perhaps the most important facts set forth in the NAB’s response were the cost factors. The CEA/CTIA white paper claimed a transition cost to broadcasters would range from $1.37 billion to $1.83 billion. However, the NAB noted that the white paper’s analysis assumed that only one transmitter, encoder and related set of equipment is needed at an SFN tower site. In fact, each market and each station would require its own set of equipment. Factoring in this simple change, the conversion cost increases to a range from $11.7 billion to $15.7 billion.
We shouldn’t get too excited about the claims and counterclaims. Much of the studies and papers being presented to the FCC are for show. It’s noise. These expensive filings would confuse even the most impartial observer and perhaps even be unhelpful in making an intelligent decision. The result of all this noise is to give cover to the FCC, allow it to claim it asked for industry input and for the politicians to measure the relative strength of the two opponents. The FCC is taking the political temperature so it’ll know where and how much to cut.
Here’s an “HDTV Update” story for background:
Proposed DTS approach is impractical, costly, says NAB/MSTV in FCC filing
A proposal from the wireless industry’s CTIA trade group and the Consumer Electronics Association to transition broadcasters from their big stick and high-power transmitters to multiple, low-power synchronized transmitters and antennas in a distributed transmission system (DTS) received two thumbs down in reply comments filed with the Federal Communications Commission (FCC) last week by the NAB and the Association for Maximum Service Television.
The CEA and CTIA offered the proposal as a way to free up contiguous spectrum that could be used to meet their forecasted future demand for wireless broadband service. Currently, a special FCC task force is working to create a National Broadband Plan due in Congress next month.
However, the MSTV and NAB said in reply comments filed Jan. 27 that transitioning from today’s digital television transmission infrastructure to one based on DTS single frequency network transmitters would create service loss to viewers resulting from coverage gaps and interference.
As envisioned by the CTIA and CEA, DTS offers a way to free up between 100MHz and 180MHz of contiguous spectrum by reducing the co- and adjacent-channel DTV space needed to prevent over-the-air TV transmission interference. However, requiring local broadcasters to transition to a distributed transmission system would be infeasible, costly, create service coverage gaps and interference, the NAB/MSTV filing said.
While building a case against the DTS proposal, the broadcast groups did commend CTIA/CEA for recognizing that consumer investment in DTV should be protected, stating broadcasters’ 6MHz channel allotment should be preserved and acknowledging broadcasters should not bear the cost of any transition to reallocate spectrum for the wireless industry.
Still, NAB and MSTV found the core of the CEA/CTIA proposal unacceptable. “Replacing the current system with DTS would trigger heavy service losses to the American public,” the filing said. Explaining to the commission that the 8-VSB modulation method chosen for digital television service in the United States was selected for its “ability to efficiently cover large service areas,” the filing quoted the CEA/CTIA proposal, which acknowledged it “was not designed with an SFN (single frequency network) architecture in mind.”
Theoretically, “a carefully engineered (DTS) system” with properly synchronized signals transmitted using the correct amplitude relative to one another could reduce interference, the filing said. However, real-world signal variations and tower siting problems would make an ideal DTS implementation unattainable. “DTS cannot be implemented to ‘cellularize’ DTV nationwide,” but rather is appropriate to fill in coverage gaps created by unique terrain, buildings and other circumstances, the filing said.
The CTIA/CEA proposal also dramatically underestimated the cost of implementing local DTS infrastructures on a national basis, the filing said. The DTS proposal puts the cost at between $1.37 billion to $1.83 billion. However, CTIA/CEA failed to take into account the fact that there are multiple stations in each broadcast market, each of which would require multiple transmitters, encoders and other equipment. A more realistic estimate taking all local broadcasters into account pegs the price tag for implementing DTS at between $11.7billion and $15.7 billion.
The NAB/MSTV filing also endorsed a call from the Department of Justice for greater use of secondary markets in spectrum and a National Telecommunications Information Administration (NTIA) request for a spectrum inventory analysis in submissions to the commission.
However, the broadcast groups said the agencies’ assumption that a shortage of spectrum will impede increased broadband competition was "particularly problematic."
Never wanting to waste a crisis, Phil Bellaria, director, Scenario Planning, Omnibus Broadband Initiative, offered his viewpoint Feb. 1 on the FCC’s broadband blog. It was titled “iPad: Heavy traffic ahead.”
Bellaria claims that Apple’s new iPad “has set off a new round of reports of networks overburdened by a data flow they were not built to handle. These problems are reminiscent of the congestion dialup users experienced following AOL’s 1996 decision to allow unlimited Internet use. For months, users had trouble connecting, and once they did connect, they experienced frequent service outages. The FCC even held hearings on the problem.
The congestion problem circa 1996-1997 revealed an intense latent demand for Internet access. Similarly, wireless network congestion today reveals intense demand for wireless broadband. Widespread use of smartphones, 3G-enabled netbooks and now, perhaps, the iPad and its competitors demonstrate that wireless broadband will be a hugely important part of the broadband ecosystem as we move ahead.
Could someone tell me how the iPad, which won’t be available for sale until March, caused “networks [to be] overburdened by data flow?”
We do more than a fair bit of monitoring the blogosphere, the Internet, newspapers, news agencies and other sources, and not one staff member reported finding any stories of “networks overburdened by data flow” caused by Apple’s announcement — nope; not one.
Philosopher Williams James once said, “There's nothing so absurd that if you repeat it often enough, people will believe it.”
That must be the FCC’s plan. Repeat often, “There’s a broadband shortage, there’s a broadband shortage.” Pretty soon, people will believe it.