In reply comments aimed at CTIA, the NAB acknowledged that nobody expects the wireless organization to advocate for broadcasters. At the same time, it should not be applauding an FCC regimen that “stampedes broadcasters off a cliff.”
The NAB team, led by Rick Kaplan, argued that Congress specified an auction that is in fact fair to broadcasters, and said that the Commission needs to restore balance to the proceeding as Congress intended.
Among the NAB’s arguments:
* Broadcasters should not subsidize wireless spectrum demands, as will likely happen when the $1.75B involuntary channel moving fund runs out with the job as yet incomplete.
*After repacking, broadcasters have every right to the exact same population coverage they were forced to abandon.
*Broadcasters should not be forced off air due to circumstances beyond their control, a possibility due to the too-short window for new station construction.
*The FCC should complete its negotiatins with Canada and Mexico in advanced of the auction.
*There are no advantages to a variable band plan that outweigh its troubles, including unnecessary damage done to LPTV and translator stations.
*Regarding unlicensed users, the FCC must make sure the engineering is feasible before adopting a plan, in opposition to CTIA’s advice.
NAB stated, “CTIA’s high-level but completely unsubstantiated endorsement of a host of Commission decisions in the Report and Order should raise red flags for the Commission. If the FCC continues on its current course, it will be expressly endorsing CTIA’s view that the possibility of recovering more spectrum defeats any competing objective. The problem is that Congress created a market-driven, voluntary auction, not a process that stampedes broadcasters off a cliff.”
NAB concluded, “Elevating spectrum recovery above all other considerations fails to implement the balanced approach Congress approved. It leads to warped outcomes, such as forcing broadcasters to subsidize the acquisition of spectrum by CTIA’s members, disregarding substantial concerns over the failure to complete international coordination prior to the start of the auction, and the adoption of a variable band plan that makes little sense as a practical matter. It renders the auction coercive, rather than voluntary. The Commission should return to the course Congress envisioned.”
