Federal Communications Commission

Finding a Creative Spectrum Solution

December 8th, 2009 by Rebecca Hanson - Spectrum Director, National Broadband Taskforce

Last Wednesday, the FCC released a Public Notice seeking comment on a variety of aspects and uses of the TV broadcast spectrum.
Until now, the discussion has been somewhat binary and predictable. Many broadcasters want to simply maintain the status quo, and many wireless broadband proponents (licensed and unlicensed) would like most or all of that spectrum to become available to them. 
In order to explore potential solutions, however, the discourse needs to become more constructive and more creative. The National Broadband Task Force has been charged with identifying and exploring ways to deliver robust broadband to everyone, and mobile broadband is an essential part of the solution. But mobile broadband won’t advance unless we can find spectrum to avoid crippling network congestion in the future. For better or for worse, broadcasters occupy one of the most attractive bands for mobile broadband applications, and we have an obligation to Congress, and to the needs of the country, to explore that spectrum’s evolutionary potential.
Thus, the real question that broadcasters should be asking themselves is “How can we best become part of a mobile broadband solution?” 
For some broadcasters, the answer may well be to return their spectrum to the FCC via a market mechanism that we are trying earnestly to design. For others, the answer may well be to find an innovative way to do what broadcasters do best – deliver video wirelessly to receivers – to solve one of the biggest challenges facing mobile broadband today – delivering video wirelessly to receivers. 
Hence our call for creative solutions. We seek ideas for market mechanisms for broadcasters who want to return some or all of the spectrum they currently use (or don’t use), and we seek innovative operational solutions from broadcasters who want to secure a place in the next evolution of our communications ecosystem.
Change is hard, but necessary, and often creates opportunities for visionary thought leadership. This is what we hope to see in the Public Notice responses, and look forward to working with the broadcast industry and others in the process of forging the most sustainable path to our wireless future.
Please respond with your ideas to this blog post, or file your comments using our Electronic Filing Comment System, using either ECFS Express or our standard submission page if you need to attach a file.

12 Responses to “Finding a Creative Spectrum Solution”

  1. Guest says:

    This would definitely help many people get access to hdtv and high speed internet. But we need to keep a blanaced approach so businesses can adapt to the new regulations.

  2. Guest says:

    The first comment is very interesting; however, there's a more fundamental thing to be discussed, and that's precisely how many and what kind of middlemen do we want between content and content user.

    a. Do we really want or need "national networks"?

    b. Do we really want or need local broadcasters?

    c. Do we really want transport and content provision mixed, as we have to a greater or lesser extent today?

    Each one of these questions has a cost and benefit assessment associated with it. We know that "the marketplace" can't really make these decisions alone, because (a) the marketeers are beholden only to their shareholders, and (b) the kinds of infrastructure costs associated with this makes it impossible for there to be a large number of competitors in the space, thereby frustrating Adam Smith's "invisible hand". We also know that the Congress is incapable of deciding this because they have to run for office, and they need campaign funds, which will come from the well-monied interests at this trough.

    Probably a BRAC-like arrangement would be most successful approach. One thing's for sure: if we try to use "the usual methods" to do this, we'll wind up with "the usual results", i.e. decisions being made on the basis of who knows who.

  3. Guest says:

    Innovative ideas should always be entertained but should also be carefully evaluated in light of existing investments and the need to maintain backward compatibility with those.

    Since 1998, consumers invested billions of dollars (probably in excess of 100 billion) in expensive HDT Vs to comply with a mandated DTV transition that was just completed 5 months ago after 10 years of parallelism with analog. Broadcast stations also invested billions of dollars to build the infrastructure necessary for H/DTV.

    About 110 million H/DTVs were sold until Dec 2008. Most included integrated HDTV over-the-air tuners mandated by the FCC in 2002, which added an average of $704 to the price of similar tune-less DTVs when first implemented in 2003/4 HDTV models.

    Although they certainly cost less now, the point is that consumers and manufacturers complied again with yet another mandate and made expensive investments to implement integrated tuners in 100% of the TVs when it was known that only about 15% of the population actually needed the over-the-air tuners.

    To put this on perspective, here are some related FCC mandates/agreements/ideas:

    A) CableCARD was a failure, implemented as unidirectional in already bi-directional cable services,

    B) The public still waits for a bi-directional practical solution since 2002,

    C) The on-the-clear integrated QAM cable tuners agreed between the FCC and the cable industry are mostly useless because cable companies customarily encrypt even basic digital channels, which require the lease of a set-top-box,

    D) Most TV manufacturers stopped including CableCARD slots on their TVs because it was obviously a failure, confirmed by the relatively very small number of CableCARDS leased by subscribers,

    E) Regardless, the FCC later forced cable companies to include CableCARDS on their set-top-boxes, while the effort for a better bi-directional solution (such as OCAP, Tru2way, etc) was still slowly being worked on in parallel (since 2002),

    F) You are now looking for a new “do-it-all device” while mandates and agreements where incapable since 2002 to implement just one that properly does only one thing. Consideration must be given that such do-it-all-device may impose an elevated cost to consumers and companies typically interested in one service and not others,

    G) You are entertaining the idea of generalizing broadcasting in SD quality, while putting pressure to reclaim spectrum HD broadcasters, a bandwidth they use and need to distribute a quality image for which consumers purchased HDTVs for the preached promise of HDTV, not to view SD.

    When setting a new direction the FCC should not lose sight of the following:

    1) What consumers and the industry already spent to comply with mandates that mostly did not work, and learn from the mistakes not create new ones,

    2) The consumer expectation of viewing the promised HD quality image that is 9 times better than analog TV, and HDTV has reached 50% penetration in US households, and

    3) Not to rush and go to square-one in “creativity- mode-with-a- blank-piece- of-paper” (the “change” mind set), ignoring established markets, technologies, and investments, that exist and matured because everyone complied with “expensive” decisions made by whoever was in government power before.

    Please read this article:

    Rodolfo La Maestra

    P.S. The above is my personal opinion.

  4. Brett Glass says:

    Congratulations to the Broadband Plan team for recognizing one of the biggest problems facing broadband providers today: the staggering inefficiency of sending unicast video streams, on demand, to everyone who wants to watch online video. No matter how great our technological innovations, the fundamental laws of physics and information theory -- Shannon's Law in particular -- dictate that there is insufficient spectrum between DC and daylight to accommodate a dense city (such as New York) of prime time viewers each receiving an individual HD video stream. As actor James "Scotty" Doohan put it, in his wonderful Scottish brogue, "Ya canna change the laws of physics, Captain."

    If we're all to get video on our mobile devices or via our broadband connections, broadcasting, multicasting, and caching are the only possible solution. And, yes, broadcasters can play a role. What we do NOT want to do -- either in the Broadband Plan or in "network neutrality" regulation -- is mandate that broadband providers satisfy all demand for transmission of video via unicast over IP. It's like commanding the sun to rise in the west; ya canna do it, Captain.

    We also need to look beyond spectrum for mobile devices and ensure that there's spectrum for fixed broadband delivery as well. The service that WISPs provide to rural areas is far and away the most cost-effective way of serving areas with low population densities. It would be tragic if the Commission freed up spectrum and then gave it all to the cellular providers, leaving none for WISPs.

  5. Guest says:

    On the previous post, if you can edit it...

    Please change "we do not need a repeat of the experience we've had with telephone companies, that used such convoluted account that virtually no one outside the industry (and precious few within the industry) actually understand it." - The word account should be accounting.

    And in the final paragraph: "and now talking about (and in some cases implementing caps and meters on broadband service)." - the close parenthesis should be after the word "implementing", not "service."

    If you can fix those, thank you!

  6. Guest says:

    If broadcasters are allowed to drop HD programming, then the cable companies will follow suit (remember the "must-carry" provision; is it still in place?). Since the HD market would lose two of its largest outlets, whatever financial incentive to create HD programming that currently exists would also disappear. The numbers wouldn't work out.

    If all people see on their TV's is SD, the last bastion of High-Def -- Blu-ray -- will eventually follow suit as well. Why bother creating HD content when no-one cares about it?

  7. Guest says:

    In all the above, and in the general feel of everything said, there is the thought the consumer would be willing - just within the few years since they were already forced - to purchase some other government mandated hardware, no matter how insignificant you think it may be, to allow some people whom that consumer may have little, if anything, to do with, to use more of the existing bandwidth. Whom are you kidding? No one wanted to buy the DTV set top boxes in the first place, but the excuse was for "better television." Now they'll end up having to purchase another something to get less-than-better television because you're going to allocate the spectrum to something or someone else. You'll have a really tough sell with that!

  8. Guest says:

    I'll just throw this thought out - one reason that we have an issue may be because so much bandwidth is wasted.

    Consider the case of a television viewer that wants to watch a specific network program at its regular broadcast time. As far as that viewer is concerned, he only needs one good feed of that program, and in most cases he wants it to be as high quality of a feed as possible - today that's a 1080p HDTV signal - and with no breakups in the signal, or interference that causes the loss of picture or sound.

    But because of the way television is transmitted, he may in fact be within range of hundreds of essentially duplicated feeds of that same signal. First of all, there's his local over-the-air network affiliate, and depending on his location, there may be more than one. Then there is Dish Network, which not only retransmits his local affiliate, but also all the other local affiliates in his time zone (because of scrambling by Dish he can't receive all those signals, but they are consuming bandwidth). And then there is DirectTV, which does the same thing. And there might even be a few other feeds on C-band or Ku-band satellite. microwave repeaters, low-power TV repeaters, etc.

    When you think about it, the ONLY real difference in these feeds is the quality of the signal - some are more highly compressed than others - and the local inserts and overlays. Many viewers find the local overlays intrusive (I would so love to be able to turn off the gaudy local radar map that a couple of my local affiliates feel the need to superimpose over the picture) and in most cases, the local commercials could be pre-delivered and stored at the receiver until called for. If McDonalds is running a campaign promoting a new McFood, and is running the same commercial on every network and nearly every local station, there's no reason that commercial could not be pre-transmitted on a side data stream and inserted into programming at the proper time by the receiver.

    So, let's borrow a page from the cell phone industry. Instead of having each TV station have its own tower, let's have a grid of transmitters that could deliver both broadcast TV (and digital radio) and broadband Internet service (since it's all really data anyway). Existing broadcasters would just "feed the grid", but with an important difference. When the viewer sits down to watch a network show, that program would be fed at the highest quality direct from New York or wherever, and the data stream would be sent out simultaneously to all transmitters. At the same time, another data stream would send local commercials, which could be pre-buffered up to a certain number of minutes in advance, and if the same commercial is to be seen on multiple networks it would still only need to be be sent once. Yet another data stream might carry essential local information that would appear as a dismissible text overlay on the screen, but it would be keyed to the viewer's location more than the station's - a viewer in New Jersey would not see any local information only pertinent to New York residents unless he set his receiver to receive those (conversely, when away from home one could program the receiver at their location to pick up their local information from back home - for example, a person in New York might want to know about school closing at a particular school district in New Jersey if she has children there).

    In the case of syndicated shows that are seen nationwide, they could be offered on a "store and play as desired" basis. For example, a show like "Wheel of Fortune" or "Jeopardy" could be sent as a nationwide data stream at 3 A.M.; the viewer could then watch it at its usual time, or any other time of the day (local commercials would be sent as a local data stream and inserted where appropriate). Local programming by the stations could be sent as a separate stream, but only over those transmitters covering their local service area.

    The only requirement to make this work would be new HDTV tuners with internal storage capability sufficient to hold a day's worth of stored local and syndicated programming for the viewer's area. By the time a system like this could actually be up and running, that kind of storage capacity could be very inexpensive and readily available (consider that even today you can get a 1.5 terabyte hard drive for under $100 when it's on sale at some online merchants, and the type of system we are talking about here would probably take years to complete).

    So to break it down, what we would have is this:

    A grid of towers spaced much closer than existing television broadcast towers, sufficient to give a Class A signal to every inhabited part of the country. These would replace all existing television, radio, paging, and wireless broadband towers (and possibly some cell phone towers), and would be operated by entities that would be barred by law from acting as a broadcaster, telephone service provider, or broadband service provider. These would be like streets and highways, maintained for the public good but leased to those who would use them for profit, and would carry only data streams - no analog. Of course, in some cases existing towers could possibly be repurposed for use with this new network.

    As mentioned, these towers would carry one-way AND two-way data, including but not limited to:

    1) National feeds of all major networks (those that will pay for the bandwidth to distribute their programming), at the highest possible signal quality, only ONE feed per channel in any time zone (nationwide or regional real-time video)
    2) Local "live" programming, such as local newscasts (regional real-time video)
    3) Syndicated, pre-recorded programs (nationwide stored-and-delayed video with limited retention)
    4) Commercials and other pre-recorded advertising (nationwide OR regional, near-real-time but could be stored and delayed to avoid duplication of data).
    5) Text information streams - emergency and urgent local information presented as a static text or "crawl" overlay on the TV screen - normally dismissible once the viewer determines it is not applicable, or has read it through once. (national or regional, real-time or near-real-time, based on location of the viewer, not the station. TV's so equipped could overlay the display even when the viewer is not watching traditional broadcast video. Sets would also have settings to permit viewers to receive notifications for other nearby locations, such as another school district or another nearby locality of interest). NOTE: It may also be desirable to have an audio-only stream carrying these same notifications, using human or computer-generated speech, for the benefit of visually impaired users -sets could then have the option to display the notifications as text (the default), audio, or not at all. The "not-at-all" could be overridden for life-threatening events such as tornadoes, etc.
    6) Dismissible graphic overlays - to show weather radar displays, etc. but only to those viewers that elect to see them (national or regional, real-time or near-real-time, low bandwidth video)
    7) Emergency video - again, this should be on a separate stream that is dismissible by those not affected. If you are watching a program and a tornado warning is issued, you only need to know about it if it affect you or your family. So it may override all programming (and indeed, on sets so designed, even computer displays or video games) in only the directly affected area, and be carried as a dismissible stream in nearby areas. (regional, real-time)
    8) Digital broadcast radio (CD quality or better - would eventually replace FM radio). (national or regional, real-time)
    9) Paging and similar low-bitrate high-latency data services (national or regional, near-real-time)
    10) Two-way broadband Internet. Note this could be resold in ways other than simply broadband Internet service - for example, some resellers might choose to offer a voice-only replacement for telephone service based on VoIP. Both the wholesaler and retailers should be required to adhere to strict net neutrality provisions; also bandwidth should not be "metered" - if there is congestion then that is a problem that needs to be addressed, not an excuse for trying to shake customers down for more money. On a temporary basis, congestion should cause all customers to experience delays and latency, but it is important to design this from the get-go so that it would be nearly impossible for normal Internet usage (or even abnormal usage patterns that can be reasonably anticipated) to cause congestion issues. PEOPLE HATE METERS ON THEIR USAGE!!! (Sorry, but felt that had to be emphasized, especially since certain large monopolistic ISP's don't seem to be getting that message).

    Note: You'd have to be VERY careful with any emergency interrupt features to avoid interrupting normal usage when it's not absolutely essential - that is, there must be imminent danger to life or limb (mere property damage would not rise to this level) - otherwise consumers will get very upset that something is taking over their receiver unnecessarily, and may look for ways to disable the functionality entirely. My biggest gripe about local broadcasters is that they so often interfere with network programming in ways that are more obtrusive than necessary - for example, it is not necessary to show a weather radar insert throughout an entire evening of network programming unless they are tracking a tornado or hurricane! They could limit the display to a minute or so at the top and bottom of the hour (or at :15 and :45) and most viewers would still get the information.

    How would local broadcasters fit into this new system? They would essentially become programmers, but with a different meaning to that word (think computer programmers). Instead of transmitting multiple discrete streams, they would transmit suggested lineups of shows. Those viewers that are used to "channel surfing" would get whichever network or local program (whether "live" or stored earlier) that is shown on one of the station's "channels." But behind the scenes, a "channel" would be a list of instructions to the television tuner - display this data stream (perhaps a network TV show) at 8:00 PM. At certain designated cutouts, display these particular commercials (which may have been pre-sent by a few minutes, particularly in the case of local/regional commercials). The local broadcaster would not, except in the case of their own local programming and locally-produced commercials, actually originate the data stream. Behind the scenes, the receiver might be switching frequencies and data streams to set up the scheduled programming. Commercials, PSA's and similar pre-recorded material could be stored in the receiver's buffer prior to display and called up by an identifier in the channel's schedule.

    How would this be advantageous to local broadcasters? No need to maintain their own transmitters. No gaps or weak spots in coverage areas, and no competitor would have a better signal inside their designated broadcast area. The ability to sell truly local commercials - for example, when carrying an ad for Chevrolet automobiles, each dealership in their service area could have their own trailer that would only be shown in that dealership's city (of course a dealer could buy a commercial covering an entire region if they wanted to). And, the ability to offer more total programming that viewers really want to see, since pre-recorded syndicated shows could be played any time during the day at the viewer's convenience, yet still contain the local commercial package.

    How would this be advantageous to networks? Quite simply, every viewer in every part of the nation would get a gorgeous, absolutely perfect HDTV signal (in whatever resolution the network originally broadcast it), delivered from a tower close to the viewer. No having some stations relegate the signal to a low resolution sub-channel. No framing the network picture down to two-thirds size so that local information can be displayed, without giving the viewer a way to dismiss it and see the original programming full-screen (if local stations really hate that idea, you might bring up the point that we really don't NEED local broadcasters to carry networks programming at all - the networks could become like "super cable stations" and cut out the local broadcasters entirely, and many viewers would cheer on the day that happened, given some of the abusive practices of local broadcasters).

    How would it impact Internet Service Providers? Basically, it would make the ISP market competitive again, as it was in the dial-up days. An ISP would simply lease a certain amount of bandwidth on the system, either regionally or nationwide, at wholesale rates, and then offer it to retail customers in whatever manner they see fit (much the way a CLEC offeres service to phone customers while using the facilities of an ILEC). To make this work, it would be extremely important that the owners of the tower network NOT be allowed to sell television or radio programming, broadband service, telephone service, or any other service to retail customers, except in a case where there are not at least two competitors offering the service on a retail basis in a given area - and that in the case where an exception is made, it should only be on a temporary basis, until a second competitor enters the market, at which time the customers of the wholesale company should be given a limited time to switch their service to one of the competitors.

    The wholesale carrier would have to be very tightly regulated. Remember, the whole idea here is to avoid signal duplication, to not be transmitting the same data stream twice (at least not within a window of a few minutes). Having competition at the wholesale level, while it would allow the free market to drive prices down, would be as inefficient as having two competing toll roads running on adjacent strips of land. Whatever company gets the bid for this should be required, on an annual basis, to justify all costs, and there should be penalties for not operating efficiently. And the accounting should be required to be "clear and simple" - we do not need a repeat of the experience we've had with telephone companies, that used such convoluted account that virtually no one outside the industry (and precious few within the industry) actually understand it. The wholesale carrier should not be permitted to own affiliated manufacturing companies, nor set up sweetheart deals to buy equipment from a particular supplier at inflated prices. Also, here's a novel idea, how about as a condition of getting a license to construct this system they must agree not to engage in any form of lobbying or political influence?

    I want to make it clear that the above is NOT a fully baked proposal - I saw your request for comments, started typing, and what you see is more or less what flowed out, with some editing. It sounds like you want ideas to knock around, so what I've written here falls into that category.

    I'd like to make one other point, that I touched on above. I know you have to deal with the National Association of Broadcasters and their lobbyists and such, but as a viewer, most of the time I could not care less about local broadcasters, per se. What I am interested in is the content, and often the broadcasters do a very poor job of delivering that content in the form we viewers want to see it - which is, uncompressed HD, without gaudy station ID "bugs" or weather radar or other displays that are pointless after about 30 seconds, and without other "noise" covering part of the screen area of the program we really want to see. In my opinion, the ONE thing local broadcasters do well is deliver local news and information programs, and lately many of them have even been slacking on that (by consolidating local news operations, etc.). So while I am all for letting the local broadcasters continue to do local news and information programming, that people can view IF they want to, I do not think that their needs or wants should be given a lot of weight in designing this new thing you are considering. With radio the situation is even worse, since most radio stations nowadays are satellite broadcasts and true local programming is a thing of the past.

    So, to some degree, I think the whole concept of local broadcasting needs to be re-examined. We do not live in the same world as when television broadcasting started; perhaps it's time to let go of the idea that local broadcasters as we now know them (essentially a conduit for network and syndicated programming) are absolutely essential. In the new system, they could still produce and offer local programming (perhaps making it available to more viewers, due to lack of geographic restrictions and the ability to tune in the programming at other than a particular fixed time of day) and they could still act as agents for the sales and production of local commercials and PSA's. But, they are no longer driving the bus (because users can now go around them to view network content, via sites such as Hulu), and if they want to go along for the ride they should not over-estimate their own importance.

    And one more point: Cable TV is not, and never will be an adequate substitute for free over-the-air programming. Cable TV companies have gotten far too greedy, first raising cable price far in excess of the rate of inflation, rebuffing all attempts to let viewers subscribe only to the channels they really want (a la carte subscriptions), and now talking about (and in some cases implementing caps and meters on broadband service). The Commission and especially the federal government made a huge mistake in ever allowing them to become this big and powerful, to the point that their customers are getting royally screwed, if I may say that. This is one reason I say that the new system needs heavy regulation, clear and open accounting, and a prohibition on lobbying and political influence games, so we don't just wind up with an even more oppressive version of "big cable."

  9. Guest says:

    1) What do you mean give back the spectrum all of them, the companies like sprint and verizon bought that infrastructure from you FCC. 2) the 2.5ghz Wimax or Clear spectrum is really the only chance of getting broadband to rural areas.Or LTE. 3) The current 4G ISPs already stream HD and run voip. 4) The problam is the rest of the spectrum you have left will not support what your are trying to do the 1st person had a good idea but with out all the other stuff for areas that doesnt have as good as a picture run repeaters thats all. 5) Oe better yet take the satilite companies use those for 1080p tv and us the mhz and ghz infrastructure for broadband only then there would be plenty of badnwidth.Tv is not alot of data but it eats bandwidth remove it from the wireless spectrum that you control not the private companies. Verizon, Sprint, ECT.

  10. Guest says:

    Please make inprovements to the "free TV" and local broadcasting. I don't have cable or satellite, it is a waste of money. People already watch to much TV. Force the stations to provide more Free TV not more paid TV.
    The FCC should look at what is best for consumer and no cost to consumer. It is bad enough I had to purchase converter boxed, the boxes are not very good. The remotes are even worse. The FCC must do want is good for the taxpayers and people who don't want to pay for service.
    If people want more they can pay for it. People want movie quality in their homes, WHY? go to the movies.
    Why should I have to suffer and lose access to over the air TV because if the people who want cable?
    If more people knew that over the air channels are very good less people would waste money for the same service.
    Why not do a study seeing how many stations do the maybe 80% of paying customers actually watch more than local stations? If more people knew that they are paying for nothing many would get rid of it. So invest in over the air TV, not forcing the casual viewer to pay for crap we don't need or want.

  11. Brett Glass says:

    Why "mobile?" To focus exclusively on spectrum for mobile providers would be to kowtow to large, well monied corporations which are politically influential but not to serve the public interest. The broadband that people get when they're on the job at work, and when they come home at the end of the day -- when they are going to study and engage in serious political participation -- is far more important than the few bits of it that they get to use on the run. An entire industry -- the WISP industry -- has been hobbled completely unnecessarily because the auction lots in recent spectrum auctions have been tailored toward mobile providers.

    What's more, the auction rules have precluded local fixed providers from bidding by requiring immediate payment (rather than "pay as you go" licensing fees which would actually generate more long term revenue) and failing to correct for the fact that the foreclosure value of spectrum is greater than its utility value.

    The Broadband Plan is not being crafted for the benefit of the huge mobile providers but for the public good. To serve that purpose, it must indeed provide spectrum -- but not to the large providers, many of which are in fact hoarding spectrum, and keeping it unused, simply to keep it out of the hands of competitors. We need spectrum for smaller, more responsive, local fixed broadband providers, who will solve the problem that Congress tasked your team with solving: reaching unserved and underserved citizens.

  12. Guest says:

    Please do not take away my only TV broadcast source. I do NOT have the luxury of cable or satellite TV any longer. I rely SOLELY on the free over the air broadcast signal. Please maintain FREE broadcast TV and allow broadcasters to boost their signals for those of us who live in more remote areas and have difficulty receiving the current signal level.

    I think free broadcast television is an important part of getting up to the minute information out to the majority of Americans. Many that live in more rural locations do not have other options. If options are available, the cost is prohibitive.

    We need, rather, we MUST retain FREE broadcast television.

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