A coalition of group owners of local broadcast television stations responded to the FCC’s challenge that they defend current spectrum allocations, and they offered a strong defense despite the short time allowed by the Commission. They noted that it’s not only non-MVPD subscribers who get TV off-air; so do many of the actual MVPDs who then pass the programming on to their subscribers. They further reminded the FCC that broadcast television remains the nation’s #1 source of entertainment.
Using the collective name Local Television Broadcasters, and summarizing its argument, the group wrote, “Television broadcasting represents the highest and best use of the spectrum in the public interest. To remain competitive in the media marketplace, television broadcasters must have the ability to innovate and meet public demand. The channel-sharing and service area reductions contemplated in the Public Notice would take this ability away from broadcasters and likely result in widespread viewer reception difficulties. As it attempts to chart a path for spectrum use, the Commission must preserve television broadcasting, which will remain the most efficient way to deliver popular programming. The Local Television Broadcasters urge the Commission to avoid coercive measures and instead provide all FCC licensees with ample flexibility to respond to technological innovation and consumer demand, which will continue to change in ways none can predict.”
LCB points out that in most markets, the majority of viewers either directly or indirectly get their broadcast stations off air, even houses that subscribe to cable or a satellite service – since broadcasters routinely deliver their signals to the relevant headend off-air rather than via a direct wire hook-up.
LCB reminded the FCC that broadcasters are still the most popular deliverers of programming, and remain the number one choice of politicians as they maintain communication with their constituents. LCB notes that wireless data is spotty and suggests the FCC request further information from wireless providers as it has from broadcasters.
LCB concludes that broadcasters need their spectrum to continue to adapt, compete and respond to public demand going forward.
The team of television groups behind the filing includes Bahakel Communications, Boise Telecasters, Cocola Broadcasting Companies, Communications Corporation of America, Evening Post Publishing Company, GOCOM Media of Illinois, Granite Broadcasting Corporation, Gray Television, Lilly Broadcasting, Local TV, Malara Broadcast Group, McGraw-Hill Broadcasting Company, Media General, Meredith Corporation, National Communications, New Vision Television, Parkin Broadcasting, SJL Broadcast Management Corporation, Smith Media, SP Television, Tribune Company, White Knight Broadcasting and WNAC.