Broadcasters face a daunting problem. They never paid for their spectrum, and television programming is now viewed by most Americans on pay or Internet services. The spectrum they use is now more valuable than ever as the government addresses a tightening need for mobile bandwidth.
The NAB and the Association for Maximum Service Television, addressing the spectrum shortage, challenged the assertion of FCC chairman Julius Genachowski and others that there is a severe shortage of spectrum available for wireless broadband.
"A significant amount of exclusively licensed spectrum has been repurposed in anticipation of the spectrum needs of the commercial wireless industry," the broadcasters said. "Owing to a host of variables, these bands have only begun to be put to use."
The broadcasters also said the wireless broadband providers could do a better job of using the spectrum they now have more efficiently. They "can add capacity for broadband by improving the technology, architecture and system design currently deployed over their legacy spectrum bands," the broadcast lobbyists argued.
The commission, they continued, should not simply focus on broadcast frequencies when it looks for wireless spectrum. Instead, they should look at spectrum already allocated for wireless, including the 100MHz broadcasters have already given up in the transition to digital.
The broadcasters said they just made a multibillion dollar investment in the DTV transition that includes more than $1.5 billion to make sure that a fraction of the audience that still relies on the over-the-air signal could still get that signal.
The FCC should put a premium on the public service productivity of broadcasters, including “local journalism, universal service, availability of educational programming, and timely and reliable provision of emergency information,” the broadcasters argued.
Also, the FCC should reject reallocation scenarios that "would strand substantial investments by consumers in receiving equipment, and/or leave consumers without access to service upon which they regularly rely."
The Association of Public Television Stations, the Corporation for Public Broadcasting and the Public Broadcasting Service, noncommercial sector of broadcasting, filed joint comments that made some of the same points as the commercial broadcasters.