A recent QUALCOMM presentation to the commission “drastically underestimates” the interference 700MHz entrants, such as its own MediaFLO service, would cause to free, over-the-air television, according to a Jan. 12 letter to the FCC from Association for Maximum Service Television president David Donovan.
While an estimate of interference presented by QUALCOMM Dec. 16, 2005, envisions 22 TV stations being harmed, in the letter Donovan said the true number of viewers who would experience interference to their broadcast television reception would be 122,000 in one market from just MediaFLO. Multiple 700MHz entrants operating nationally operating under “lax interference standards advocated by QUALCOMM” would likely cause interference to millions of over-the-air TV viewers.
Donovan also pointed out several other areas where QUALCOMM had understated the impact on terrestrial broadcasting, including:
- A lack of consideration of the impact of interference caused by all 700MHz providers. According to Donovan, QUALCOMM’s sought after increase in interference to co- and adjacent channels by 2 percent does not simply encompass MediaFLO but all 700MHz entrants.
- Disregard for cable and satellite households. QUALCOMM’s analysis of the number of households affected by interference from its MediaFLO system does not take cable and satellite households into account, many of which use second TVs for over-the-air broadcast reception.
- Use of irrelevant audience share data. To minimize the number of viewers impacted by potential interference, QUALCOMM uses ratings to downplay the audience size that could be affected. “An affected household’s past viewership pattern should not preclude its future access to local, over-the-air television services….”
- No evaluation of where the 700MHz transmitter will be located and its consequential interference to broadcast television reception. Donovan pointed to Los Angeles’ Hispanic population as an example. Forty-five and half percent of the 1.7 million Hispanic viewers in Los Angeles rely exclusively on over-the-air television. Therefore, placing a 700MHz transmitter in a largely Hispanic neighborhood the number of viewers affected by interference would be much higher than if it were placed elsewhere.
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