CTIA, CES want TV broadcasters to use low-power antennas: CTIA files broadband comments

CTIA and the Consumer Electronics Association have proposed that TV broadcasters transition from high power/high tower antennas to a low-power antenna structure to free up between 100 megahertz and 180 megahertz of spectrum that could be used for mobile broadband services.
Separately, CTIA asked the Federal Communications Commission to ensure regulatory parity among all service providers as the nation moves to an all-Internet Protocol structure.
Freeing up broadcast spectrum
Regarding the broadcast spectrum, CTIA and CEA are proposing that broadcasters re-engineer their networks so that less spectrum is wasted on interference bands, freeing up spectrum that the groups estimate is valued between $35 billion and $70 billion.
“The concept of a network of lower power facilities synchronized with one another and transmitting the same data on a common channel (or frequency) is not new; this architecture is typically known as a ‘single frequency network,’ ” according to the petition. Broadcasters would not have to pay for the transition under the jointly proposed plan, nor would consumers pay. The cost would be borne by the beneficiaries of the newly freed-up spectrum.
“As previously noted, television stations typically require coordination over extreme distances and must generally avoid use of adjacent channels. That means, even though the typical television broadcast is a 19.4 Mbps stream in a 6 MHz channel, that it can actually occupy 12-18 MHz of spectrum,” CTIA and CEA said. “As discussed supra in Section IV(E), the conversion of the infrastructure to a low power architecture eliminates the need for vast cochannel or adjacent channel separations, which could free up one half or more of the UHF television band. Even in congested markets, approximately 100-180 MHz of spectrum could be recaptured for mobile broadband use. This substantial amount of spectrum is clearly worth pursuing, even if it does require significant adjustments to the broadcast network.”
Mobile broadband comments
In its comments on a national broadband plan, CTIA said the commission needs to ensure regulatory parity; ensure that the move to an open Internet doesn’t have unintended consequences, meaning providers invest less in the network, and explore the structure regarding universal service and intercarrier compensation rules.
“The commission should explore how to ensure that neither circuit-switched nor IP-based providers are advantaged or disadvantaged by regulatory structures while the two types of networks operate concurrently and compete with one,” CTIA said in its filing.
Specifically, CTIA said some VoIP offerings are set up to avoid FCC requirements, while other interconnected carriers are treated like telecom providers, which requires them to connect any call, regardless of the cost.
“As wireless providers transition to all-IP systems, VoIP – whether provided by the carrier or by a third-party application developer – will be packet data commingled with all other data requests on the network. However, because VoIP is sensitive to latency, carriers will need the flexibility to provide packet prioritization for VoIP in order to maintain quality of service. Moreover, absent this ability, carriers may delay IP network upgrade plans in order to be assured they can maintain quality voice service.”
Specifically, CTIA said that the FCC’s proposed rules require carriers to follow regulations that other players in the ecosystem don’t have to. “ The rules proposed in the Open Internet NPRM would by their terms apply to providers of broadband Internet access services, but would not appear to impose similar restrictions on other entities in the wireless ecosystem, like app stores and developers – or on circuit-switched providers. This creates the potential for unintended consequences, which is magnified when both Internet traffic (which would be subject to openness regulations) and non-Internet traffic (which would not) are carried over the same medium from end-to-end – as is the case with wireless networks. And, despite the Open Internet NPRM’s stated concern about broadband network operators’ conduct, most recent examples of actions that have or may raise questions at the commission have not involved Internet service providers, but application providers and operating system developers.”
The FCC is required to submit its National Broadband Plan to Congress in February and offered a sneak peak of its plan earlier this month.