Spectrum Sharing: Good Idea; Bad Plan

With an eye on the upcoming FCC Broadcaster Relocation Fund Workshop on June 25, 2012, the Advanced Television Broadcasting Alliance (Alliance) believes spectrum sharing in principle is good, but the intended plan of execution is faulty and will not work as intended.

“The FCC is developing plans for stations to share spectrum, as part of the overall pending spectrum auctions as authorized by Congress,” said Alliance spokesman, Lee Miller. “Spectrum sharing is something the Alliance believes is necessary, but the proposed implementation will not work.”

The Alliance, formerly the Coalition for Free TV and Broadband, says limited sharing has already taken place in the television industry through LMA’s (Local Marketing Agreements) and other legal sharing plans.

The Alliance is proposing the Broadcast Overlay Plan, which would permit stations, whether full power or low power, to share spectrum with wireless broadband providers through flexible use and alternative modulation schemes. This Plan, if adopted, would provide a quantum leap in the amount of usable spectrum for both broadcasters and the wireless industry and go a long way in meeting the future needs of wireless providers.

The Alliance, however, does not believe that sharing spectrum using existing modulation standards will work. Here are some examples:

  • If two full power stations share their 6Mhz bandwidth and both opt for HD channels, there would be little or no spectrum left over for other SD channels and mobile.
  • If both full power stations share a single channel, then both would be entitled to a continuation of must-carry rights on cable, which cable interests might find coercive.
  • The financial incentive of sharing the proceeds of auctioning one of the channels might be totally inadequate compared to the potential revenues from continued operations of both channels.
  • There is little incentive for a Class “A” station to share with another Class A or with a full power. Should they be granted “must-carry” status if they participate, beyond the current, restrictive, guidelines. The answer currently seems “No!”
  • Many Class “A” stations depend on multiple channels to pay the bills by leasing time to ethnic, religious, or minority programming groups, and could not make it with one channel.
  • LPTV has little protection under the auction authorization law. Even if the FCC permitted LPTV stations to share, the resulting, single programming channel would likely fail for the same reason Class A stations need multiple channels to survive.
  • Channel sharing is the “kiss of death” for mobile television.
  • ATSC 2.0, if adopted, would nearly double the bandwidth capacity of the spectrum, but there is little established base for H.264 capable receivers.

The Alliance believes in sharing, but sharing that is less regulated, offers greater flexibility, and opportunity to explore new modulation types such as LTE (compatible with current wireless technology) and/or OFDM (offering huge expansion of capacity).

We believe that Congress and the FCC should look for ways to help grow the Broadcast Industry, instead of writing its obituary. For instance:

  • For the remaining half of the 6,600+ low-power translator stations who have yet to convert to digital, open up what remains ($24M) of the digital conversion fund so they can meet the 2015 deadline.
  • Finish the FCC spectrum inventory and release the AOM report on how all of this is to work.
  • Make it abundantly clear what the FCC’s intentions are toward LPTV. All evidence given thus far seems to indicate nothing but nefarious intentions.
  • Give broadcasters the freedom to work with new technologies and to experiment with new partners such as wireless and explore new business models.
  • Process the pending applications, issue the CP’s that are languishing on desks in Washington, so that the industry can grow and not shrink.
  • Assure the broadcasters of America, that you have their best interests at heart and believe in a strong future for broadcasting and that you are not waging a war of attrition.

The Alliance believes in sharing, but in an open and free marketplace. That is the American way. Untie our hands, so we can help usher in a new era of freedom through the airwaves.


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Dear Fellow LPTV Broadcaster and Industry Leaders,

The auction has ended and most of us are still here.  While it was not only our hope but the hope of many others that the auction would not take place . . . it did, but it did not have the devastating effect that it might have had. 

The world after the auction looks different and amazingly so has a very bright future!

What does that future look like?  Not only the amazing possibilities of ATSC 3.0 but the landscape of a nation of people who are increasingly cutting their cable cords and looking for free, over the air, broadcasting content.

That’s why it’s more important than ever that you join the Advanced Television Broadcast Alliance.  Our board of directors have a combined 500+ years of experience which beginning with your membership we are going to start making more available to our members on an increasing basis.

Soon as an ATBA member, you will be eligible to start tapping into not only this brain trust through unique services available only to our members but regular news updates regarding our collective broadcast future.  We are exploring new ways to tap into information from Washington as well as important updates that will benefit you right there where you live.

The need for the ATBA has increased with the new opportunities that are becoming available for those of us who still know that the future of LPTV, Class A and Translators is bright!  Are you selling your station to local sponsors?  Are you maximizing your spectrum to the advantage that you truly can?  Are you struggling with FCC rules and regulations that you either don’t understand or can’t get explained?

The ATBA is developing a database of information to help you find the answers you need! 

In addition we are still working with the true decision makers in Washington.  Your ATBA has earned the respect and the ear of the true movers and shakers that continue to shape our collective broadcasting future.

So what can you do to get involved and begin to take advantage of these, and many other, benefits?  Join the ATBA today!  Your membership benefits will include:

  1. Members only access to hundreds of years of LPTV experience through our new “Brain Trust”
  2. Early entry to our annual NAB LPTV evening event with access to our special event guest(s)
  3. Exclusive digital content regarding real world information you need to know
  4. Eligibility for recognition for your hard work through our ATBA LPTV Awards
  5. Access to equipment manufacturers with discounts available especially for ATBA members!

To be honest you can’t afford not to be a member of the ATBA! 

We’re making it affordable because it’s a win – win!  When you join, you’re going to receive more than just the benefits listed above but also you’ll be aligning with hundreds of others who, like yourself, have a vested interest in the continued forward movement of free, over-the-air broadcasting.  It’s a win for your ATBA because we will increase our strength through numbers as we grow together.

So what’s the next step?  If you’re ready follow this link https://www.broadcastingalliance.org/join-us/ to sign up.  If you have more questions please don’t hesitate to call a member of the ATBA board of directors by calling this number (877) 214-4277.   You’ll get a rapid response!

Thanks for taking the time to read this note and for your ongoing passion for the future of communication in this great country.


The Board of Directors – The Advanced Television Broadcast Alliance