The FCC’s plan to repurpose television spectrum for wireless broadband will not work in the areas near Canada and Mexico without international treaties, and getting those treaties may require some heavy lifting. NAB has a plan and has shared it with the FCC.
“Without revised agreements,” stated NAB, “the Commission will be unable to repack a sufficient number of stations within 250 miles of the Canadian border and 170 miles of the Mexican border to yield viable nationwide bands of spectrum for commercial wireless use. The result would be far less spectrum repurposed and far less money for the U.S. Treasury. Further, a new agreement is needed simply to permit mobile broadband operations in the 600 MHz band.”
NAB said it is drawing on its experience with the 2009 DTV transition, making it “uniquely qualified” to address the issue. It offered a five point plan:
It seeks to identify and analyze protected foreign channels; find points of flexibility; study the impact of foreign TV on US broadband in auctioned frequency and vice versa; create a plan to share technical information across affected media and borders; and begin to engage Mexico and Canada to create a long-term plan.
Here is the more detailed NAB explanation of each point.
“First, identify the number of non-operational allotments that are currently being protected by Canada, Mexico and the U.S. Immediately thereafter, propose to Canada and Mexico using these non-operational allotments to find new channels that would be pre-approved and pre-coordinated to accommodate repacked U.S. stations in the border areas. For example, in the December 2008 Table A of the existing U.S. and Canadian Post-Transition Allotment Plan – the document that governs what channel allotments must be protected by both countries – Canada has 1,552 channel allotments designated for its TV operations. Of those 1,552 protected allotments, however, only about 550 represented operating TV stations. Furthermore, approximately 1,140 of the 1,552 entries (about 75%) are for channels in the UHF portion of the TV spectrum, and only 285 of these entries were assigned to operating stations. The post-transition allotment plans and the vacant allotments contained therein provide a useful starting point for the Commission to begin negotiations.
“Second, after determining what flexibility might be available, the Commission should expedite – and NAB could assist with – detailed technical and repacking analyses to determine the breadth and scope of the border challenge and its potential impact on spectrum recovery. These studies and analyses would establish baseline band plans to determine and maximize the amount of spectrum that can be recovered while still protecting existing Canadian and Mexican TV operations (although not protecting allotments, as noted above). The studies would help identify where and how many TV broadcast volunteers are needed to meet a reasonable clearing target during the reverse auction.
“Third, the Commission must study the potential impact of Canadian and Mexican TV broadcast operations on future U.S. mobile broadband operations, and vice versa. In many, but not all instances, the constraints on U.S. broadband operations will be manageable.3 This step is essential so that the FCC can make public prior to the forward auction any remaining encumbrances on particular blocks of spectrum. This will allow bidders to take into account any impairment that might exist should they consider pursuing those particular licenses at auction.
“Fourth, the Commission, with the help of the affected industries, needs to develop the technical sharing criteria between new broadband operations and existing TV stations. This includes agreeing with Canada and Mexico that commercial wireless operations are permitted on the channel allotments currently subject to the agreement (which they are not currently), and agreeing on the new separation distances required.
“Fifth, the Commission should also begin to engage with Canada and Mexico on a long-term 600 MHz band plan across the borders. This cross-border band plan should provide for the eventual commonality of broadband and broadcast use and harmonization of spectrum across the border.”
The plan was submitted by NAB EVP for Strategic Planning Rick Kaplan.