The NAB and Broadband Spectrum

This report is designed to prove that the FCC is wrong to try to gain additional spectrum. The bottom line is that the NAB, with this report as “evidence,” is trying to protect the TV channels that could easily be cleared, and cleared quickly, to make more wireless broadband spectrum available.

The National Association of Broadcasters (NAB), which represents the interests of the television networks and others, is one of the most powerful lobbying groups in Washington, DC. During every election, it contributes to many of the campaigns for its favorite Representatives and Senators, and it spends a lot of time on the “Hill” pushing the broadcasters’ agenda. TV stations didn’t pay a penny for their spectrum and have already lost the 700-MHz band to commercial wireless broadband services (Channels 53 to 69). Now the broadcasters face another squeeze as the FCC tries to free up more spectrum for wireless broadband usage.

A week or so ago, the NAB issued a report by an “independent” third party (Onyeiju Consulting, LLC from Arlington, VA) which, in its executive summary, stated, “Many wireless carriers and their trade associations argue that the FCC must make hundreds of megahertz of spectrum available for wireless broadband in order to keep pace with customers’ growing mobile data demands. But this is not so. Capacity problems can be addressed in numerous ways that do not involve spectrum. So while additional spectrum is a tool that can help relieve congestion on mobile networks, the current rush to reallocate is not necessary.”

It goes on to say that prior to worrying about reallocation of spectrum for broadband services, the following can be used to address capacity concerns:

• “Deploying innovative network technology upgrades that will promote spectral efficiency;
• Establishing pricing and other fair-use policies to lessen network congestion;
• Migrating voice traffic to Internet Protocol;
• Leveraging consumer infrastructure such as femtocells and Wi-Fi;
• Investing in infrastructure to enhance capacity through the deployment of Multi-Antenna Signal Processing (smart antennas), picocells, modernizing network architecture, Distributed Antenna Systems, upgraded backhaul, sectorization and cell splitting;
• Prioritizing latency sensitive data packets;
• Employing caching;
• Utilizing channel bonding; and
• Encouraging the development of bandwidth sensitive applications and devices.”

The report continues in this vein but is very short on facts. The authors do not address, nor do they acknowledge the FCC’s own OBI broadband capacity report that shows a shortfall of spectrum of 95 MHz of broadband spectrum by 2012 and about 250 MHz by 2014. This report is designed to prove that the FCC is wrong to try to gain additional spectrum. The bottom line is that the NAB, with this report as “evidence,” is trying to protect the TV channels that could easily be cleared, and cleared quickly, to make more wireless broadband spectrum available.

TV channels are 6 MHz of spectrum each and the lowest frequency that would be usable for mobile broadband is about 500 MHz. It turns out that TV channels 20 (506 to 512 MHz) through channel 51 (692 to 698 MHz) are a good fit. This would free up another 192 MHz of prime spectrum for wireless broadband services. Analog TV needed 6 MHz of spectrum for each channel and no two adjacent channels could be active in the same area because of the potential for interference between the two channels since receivers in most TV sets are not good enough to prevent interference from an adjacent channel.

HD TV does need all 6 MHz of spectrum per channel and over-the-air HD TV does not work well on TV channels below channel 7 because of multipath and other noise, but that still leaves TV channels 8 through 19. Today, less than 20% of the U.S. population uses over-the-air TV as their only form of TV reception while 35-40% are using it as a supplement to pay-tv services. Add to that the fact that many TV stations are no longer making much if any profit, and that there is room for all TV stations within a city to operate within the 8 to 19 channel range, and it is easy to see why the FCC and others are looking at the spectrum between channels 20 and 51 for additional broadband spectrum. This spectrum is ideal for broadband services and even though the broadcasters did not buy it at auction, they don’t want to lose it.

The FCC has proposed, and some in Congress agree, that these auctions could be classified as incentive auctions with a portion of the proceeds going back to the TV stations that voluntarily move to a lower channel. The problem I see with this is that all of the spectrum must be cleared on a nationwide basis in order to make it available. If some stations did not voluntarily agree to move, they would have to be forced to do so. I am also opposed to paying the broadcasters to give up spectrum they never paid for in the first place, although I think that it would be fair to help them with relocation costs.

There are some advantages for TV broadcasters to move to lower channels: The lower you go in the TV spectrum, the better your coverage is and many of these stations would be able to reduce their power (and thus their electric bills) by moving to lower spectrum so they would enjoy either better coverage with the same power or the same coverage with reduced costs. In either event, it is a win for the TV broadcasters, a win for commercial wireless broadband customers, and a win for the network operators that are trying to provide more bandwidth to meet increasing demand for broadband services.

How much is this spectrum worth at auction? The upper 700 MHz of spectrum (TV channels 60 through 67) produced a total income to the Feds of more than $19 billion so if you do the math, each TV channel is worth $2.38 billion. Since broadband spectrum must be paired, each 6X6 MHz chunk of spectrum would bring in $4.76 billion. Therefore, the total auction proceeds would be at least $73.78 billion, and since the spectrum is more valuable than even the 700-MHz spectrum, chances are that the total income from the auctions would exceed $80 billion. This is a sizeable amount, but to put it in perspective, the U.S. debt is growing at the rate of $4.2 billion per day so this auction would pay off the national debt for 19 days!

More importantly, it would provide more needed spectrum, more jobs, perhaps more network competition, and additional money flowing into the wireless sector as these systems are built out. TV broadcasters would still have enough channels and the U.S. Treasury would gain $80 billion. Business and consumer customers would have more broadband spectrum to use so data rates over all the networks could be better maintained. It sure seems like a win for everyone to me.

Even if $12 billion of the proceeds went to fund the Public Safety broadband nationwide network that is being proposed, the total gross for the U.S. Treasury would still be $68 billion and Public Safety would finally be able to build out a nationwide broadband network and provide nationwide interoperability for the first time ever. An investment in the Public Safety network that did not impact the Treasury would go a long way toward helping our first responders.

The players are lining up on both sides of the field and the NAB will probably enlist some more big guns on its side. On the other side is the FCC, most of Congress and the administration, network operators, the consumer and business population of the country, and others who understand that having more bandwidth is critical to providing better wireless broadband services. However, before the game ends there will be a lot of action in the middle of the field and lots of posturing and positioning from both sides. Time is a critical factor here. If we are to identify and make available more broadband spectrum it has to be done sooner, rather than later. From the day it is identified to the day it is auctioned will be a year or more, then the TV stations will have to be relocated and that will consume at least another year, and then it will take network operators one to three years to build out these systems. So even if we started work on the auctions today, this spectrum would not be available for use until 2015 or 2016, well beyond the FCC’s projected spectrum shortfall for broadband services. If it takes two years to decide to auction the spectrum and craft the laws to accomplish all of this, it will be 2017 or 2018 before the spectrum is really available.

In the Meantime

While we are waiting and watching for how all this plays out, the FCC already has some spectrum in the bank that it can release for auctions. There is the AWS-2 spectrum, which, if paired properly, could add another 20-30 MHz of available spectrum and then in some parts of the United States there is some PCS (1900-MHz spectrum), which was either turned back into the FCC or the FCC took back because the auction winner did not meet build-out requirements. The NTIA (the organization in charge of all federally held spectrum) has some spectrum it could free up quickly. Quickly, in this case means the spectrum could make its way into the market in three or four years and would help bridge the gap between growing demand for bandwidth. Then the TV channel spectrum would become available.

The FCC and the NTIA will have to work together to help “find” more broadband spectrum. I hope they don’t spend a lot of time looking below 500 MHz because, as noted above, spectrum below 500 MHz is not well suited for mobile broadband services. The antennas, filters, and duplexers needed below 500 MHz are too big and battery life will be an issue. Perhaps some broadband usage can be made of lower spectrum for fixed broadband usage, but the real choices for mobile broadband spectrum are from 500 MHz up to about 3.5 GHz, and even that is a stretch. The number of cells required at 500 MHz versus 3.5 GHz is about a 1:15 ratio. For every one at 500 MHz, you would need fifteen at 3.5 GHz.

Within that range of spectrum, the TV stations now occupy 192 MHz, more is already allocated to broadband and cellular services, there are land mobile radio operators, first responders, GPS, satellites, microwave systems, government services, and many others. But it is all we have to work with at the moment so we need to be creative in where we look for spectrum and where incumbents can be relocated. The easiest of all of these is the spectrum occupied by the TV stations since they can be located to lower in the spectrum and in each city we are only talking about a handful of TV transmitters. Moving them down in frequency will not require more than having to purchase a new transmitter and antenna. Consumers will not need new TV sets, cable and satellite companies that take their signals off the air and convert them to satellite or cable systems can simply change the receivers they are using, and it is a clean, fairly inexpensive proposition.

When the AWS-1 band was reclaimed by combining military and microwave bands, the cost of relocation was paid for by the winning bidders. Costs were high, but only because there were many microwave users in the 2-GHz portion of the spectrum. However it, too, did not mean moving any consumers or users or having them purchase new equipment on a different portion of the spectrum. We are running out of areas such as those and other relocations could cost a lot more, which is yet another reason the TV spectrum is such a good choice.

The NAB is strong and powerful in DC, but logic is on the side of those who understand that we will need more broadband spectrum soon, and that the existing TV spectrum is the best choice over the short haul. I am not at all sure that even the NAB with all of its clout will be able to fend off those that want this spectrum for their own and those that have the power to have it reallocated. The FCC’s incentive auction plan, where the TV stations share in the proceeds, makes little sense to me since the TV stations did not pay for the spectrum in the first place, but if that is what it takes, then I can live with it.

We cannot make more spectrum, we cannot grow it or do anything but use it more efficiently. One might argue that giving a consumer better and higher-speed connections so they can watch a streaming video almost no matter where they are is not as important as providing the services TV stations provide, but I would argue that a lot of TV content is simply on the same level as the YouTube videos people watch. I think the NAB will lose this battle; the question in my mind is not if but when. The longer the NAB can hold onto these channels, the longer it will take for us to begin to address our broadband spectrum issues.

Andrew M. Seybold