Whoa!!! Blair Levin is way off base…yet again!

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The idea advanced by [Former FCC Broadband Initiative Director and current Aspen Institute Communications and Society Fellow] Blair Levin to migrate digital television from MPEG-2 to MPEG-4 is of course, an advancement in efficiency, and SpectrumEvolution.org heartily supports it. MPEG-4’s benefits are already recognized by the broadcasting industry, which already used it as the video encoding protocol for mobile/hand-held ATSC. It is also part of the more advanced CMMB digital TV technology. However, MPEG-4 does nothing to increase the available “bits per second” and so does not significantly advance the efficiency cause that Levin is advocating. All it does is compress the video stream to use fewer bits to send a given image. In the case of MPEG-4, it is a 100% improvement; so that what takes 3 Mbps to stream in MPEG-2 can be carried in a 1.5 Mbps data stream in MPEG-4.


Levin’s objective is to show that MPEG-4 will make it easier for TV broadcasters to share a 6 MHz channel while still providing HD, 3D, mobile, or multiple streams. But that is a band-aid and not a cure. It will also obsolete most of the new digital TV receivers which the public has spent billions of dollars to buy, as well as all the digital converter boxes that the government spent many taxpayer dollars to subsidize, once again leaving the public to pay the bill.

“Levin says the new standard would ‘massively’ increase spectrum efficiency, from 19.4 to 30 or 40 million bits per second, which is one of the reasons 3D would be possible.”

That is just not true. It may take fewer bits to transmit an image, but the efficiency of spectrum use, which is how many bits per unit of spectrum can be transmitted, is not improved. The “bits per Hertz” increase comes from implementing a more sophisticated modulation scheme like OFDM or OFDMA, which increases the spectral efficiency by at least a 2x improvement over the current ATSC 8VSB modulation scheme.

Still lost on Levin and other National Broadband Plan (NBP) architects is the EXTREMELY more efficient use of the spectrum through the use of its “multicasting” (e.g. “Broadcasting”) capability, where the same small portion of the overall bandwidth is used to deliver the same information to an unlimited number of receivers. That is the broadcast advantage that no 4G or 3G solutions can deliver today.

In other words, if we are not going to continue to waste spectrum or use it all up now, leaving future demand unsatisfied and without resources, we must combine more efficient modulation with broadcast dissemination of frequently accessed content. Otherwise, there will be no long-term solution, and future generations will be short-changed.

CMMB and other advanced modulation schemes incorporate both advances. They are market-ready, and the beneficiary of huge global ecosystems. The American public and incumbent LPTV broadcasters deserve the chance to deliver, on these efficiencies and advance dramatically our progress to the National Broadband Plan.

“Levin said that he doesn’t know more about the broadcast industry than broadcasters, but that, as he looked at the business perspective and policy perspective, “there is a very nice confluence, but I see no activity by the broadcasters that recognize the value of that confluence.”

The problem with this approach is that as with all of the other broadband promotion by Levin and FCC Chairman Genachowski is purely focused on economic arguments to justify the policy agenda. The only public interest value they seem to recognize is how much Wall St. will pay for a stock.

Their point of view is completely ignorant of the decades-old covenant of free-to-air services, and the public service obligations that have always been part of the Broadcasters’ license obligations and a critical asset to our free society. It is a completely natural progression of that historical covenant to now allow broadcasters to deliver free advertiser-supported Internet services to the public, if just allowed to do so in parallel with a wide range of innovative new services for which they are already authorized to deliver.

The fact that broadcasters are already required to share 5% of their gross revenues from such new services has been completely ignored in the FCC Chairman’s “rush to auction.”

Broadcasters would provide the public with a perpetual annuity rather than a one-shot payment that will be eaten up by immediate government expenditures and gone forever and will have to be amortized and recovered by auction winners through higher prices to their customers.

The broadcast industry, and especially LPTV licensees, are ready and well-positioned to provide a substantial portion of the desired broadband services that are a national imperative. They can do it faster and at less cost than traditional wireless services. They simply need the FCC to permit them the opportunity to continue to serve their local communities with new broadband services along with broadcast programming. This is especially true in the rural and underserved areas and population segments of the country which will be the last ones reached by major wireless carriers but already have an LPTV broadcast presence.

–Greg Herman President, www.SpectrumEvolution.org
469-644-4683 [email protected]