The paper is divided into five chapters. Each focuses on one aspect of the reclamation process.
In the first chapter, the FCC restates its plan to take back broadcast spectrum using previously released data. The primary claim is that TV spectrum is highly undervalued compared with its value when used for mobile broadband. Other factors the agency claims in favor of its plans include the TV industry’s “… challenging long-term trends,” OTA reception declines of 31 percent and a decline in “overall industry employment.”
A new reason the paper says that broadcasters should cooperate is the potential loss of “must carry.” Says the report, “Cable operators have argued that the facts underlying the Supreme Court’s 1997 ruling have changed. A successful legal challenge to the must-carry regime would negatively impact the stations that continue to rely on must-carry rights. With the loss of guaranteed MVPD carriage, these stations would either need to negotiate and potentially pay for carriage or lose roughly 81-85 percent of their viewership.”
Under possible scenarios, the plan predicts that station collocation will not be a sufficient solution. Using New York as an example, the report says that even locating all 12 New York City stations to the Empire State Building “… would not recover meaningful amounts of spectrum.”
Sharing and 720p
If nothing else, one point in chapter three is certain to light the fire of controversy. Says the report, “Generally, 1080i streams are more bit rate-intensive than 720p streams … but 1080i streams do not necessarily provide a better picture quality.”
A significant portion of the report focuses on channel sharing. The report says that in order to clear 60MHz-120MHz of contiguous spectrum, “2-12 percent of stations would need to share channels voluntarily, 18-41 percent would receive channel reassignments, and stations would on average experience a net gain in service area of 0.0=0.4 percent."
A key aspect of channel sharing is the reduction in station bandwidth. The report offers plenty of documentation to back up its contention that sharing is the way to go, especially as it relates to HD programming.
Using measurements made on Washington, D.C., stations, the FCC says, “... all things being equal, the stations that transmit 1080i video use 1.2Mb/s more capacity than stations that transmit 720p video.” Of course, any channel sharing would impact how much bandwidth a station could use for HD. The report claims “stations could potentially pair in ways that minimize the coincident of high-movement HD programming.”
The FCC suggests also that a move to requiring MPEG-4 receivers may be in the offing: “Setting this dual functionality as a standard or including the ability to upgrade decoding capability without purchasing a new television may facilitate a transition over time to more efficient compression technologies.”
Multicast is a bust
In an effort to tamp down any desire for multicast spectrum, the report says that the technology is pretty much a bust. Only 1400 multicast channels are on the air, and many are simply running 24/7 weather channels, or to use the FCC’s words “programming that has little investment.”
Only 79 stations reported making money from multicast, totaling $2.1 million. Eighty-five percent of that came from three stations in Houston and Los Angeles, all of which transmit ethnic content. The remaining 76 stations averaged only $3900 in multicast revenue.
It is my opinion, and it’s true
While the paper is offered as technical information, it is clearly designed to support the agency’s one-sided thought process. Says the commission, “This fact-based, data-driven approach is important.”
Broadcast engineers and station managers should read this report. While it is only 57 pages long, much of the content is footnotes and exhibits, which can be ignored.
An FCC blog post by Julius Knapp, deputy chief Office of Engineering and Technology, calls the paper “… the start of the process — not the conclusion. ...It is entirely possible, and perhaps even likely, that the best ideas on how to repurpose TV broadcast spectrum are yet to be developed or put forward.”
Simply claiming a paper is, “fact-based" and “data-driven,” doesn’t make the contents scientific — or even entirely true. The paper does represent another in a growing number of FCC stakes in the ground all pointing to finished reclamation by 2015.
Of course, Knapp’s entire soliloquy presumes there is an actual need to reclaim TV broadcast spectrum.