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This note gives a good set of points relating to the "Spectrum Grab" -- MIT Memo to Markey on Spectr
From: David Farber <>
Date: Mon, 7 Mar 1994 19:04:59 -0500
Memo to: The Hon. Rep. Edward J. Markey, Chairman, Subcommittee on Telecommunications, U.S. House of Representatives From: David Carver, Tom Hargadon, Jr., Clark E. Johnson, Jr., Lee McKnight, Russell Neuman, Suzanne Neil & Richard J. Solomon Research Program on Communications Policy Center for Technology, Policy & Industrial Development Massachusetts Institute of Technology Cambridge, Mass. 02139 The proposed Sec. 203 Broadcast Spectrum Flexibility amendment to HR 3636 fails to take into account recent radical changes in spectrum technologies. Any changes in the use of the invaluable TV spectrum should not be made with undue haste. New legislation on the re-allocation of spectrum use requires careful technical and economic evaluation and broad public debate. For example, these following points must be addressed to be sure the public interest is fully satisfied: - The spectrum is a public resource, and the public owns it. As a matter of equity, a public trust is given to private enterprise to develop its uses. The TV spectrum public trust was for broadcasting television, sponsored by advertisers. If non-conventional television services are to be provided, others besides the existing broadcasters should have the option to bid on its use including telephone carriers, personal communications providers, cable networks, minorities, and other entrepreneurs and non-profit enterprises. - Proposed Sec. 302 changes the HDTV agenda. It says HDTV is not really about TV, but how the spectrum is to be allocated. New digital technologies -- some developed by U.S. HDTV researchers -- make it possible to do a number of different things with spectrum. Cellular digital TV promises to be a very efficient way of using this scarce public resource. However, there has not been sufficient time to analyze these new opportunities, nor have any of these technology shifts been reviewed in Congressional Hearings. The Congressional Office of Technology Assessment has just begun a study on how new radiofrequency technologies can be used for local infrastructure, and ARPA has several technical studies underway on broadband spectrum utilization. Before Congress narrowly re-allocates the spectrum, it may be best to wait until those studies are completed. - The auction of roughly 40 Mhz of spectrum for personal communication services (PCS) isexpected to bring in some $8 Billion in sorely-needed revenue for the Federal Government. In contrast, some 400 Mhz of TV spectrum might become available because these of new technologies. If auctioned off, the 400 Mhz could be worth more than $100 Billion to the taxpayer. Proposed Sec. 302 does not adequately address this issue, because passage of the Amendment may devalue the PCS spectrum before auctioning. Without a serious economic study, we do not know what we may be giving away. - This bill is intended to open up competition in telecommunications industries that are converging due to digital technologies. TV spectrum is an important part of that convergence, especially for local infrastructure, since it can solve many of the "last mile" access problems for broadband links. Competition should extend to use of the TV spectrum for non-television purposes if Congress expects to maintain a "level playing field" among competitors in the local arena. Legislation should be explicit about how this competition will be maintained. - Each UHF TV station today has one or more unused ("taboo") channels associated with it, in some cases as many as 3 or 4 taboo channels per station in each region that cannot be used due to interference. If HDTV is desirable in the public interest, as the FCC has already stated in its Report & Order, it is important that legislation explicitly specify that the taboo channels cannot be used for anything else except HDTV. Any attempt to use these taboo channels for anything else during the transition may effectively kill terrestrial HDTV implementation. Therefore, several major American corporations may have invested millions of dollars for nothing. Also, any perceived American lead in world HDTV technology may have been destroyed before it began. - With new digital technology, it may be possible to use the taboo channels for other services, including cellular local broadband two-way communications, or additional TV stations, without interfering with existing TV stations. The current wording of Sec. 302 is too vague, since it could imply that channels not being used today because of interference are part of the current broadcasters' dominion. - Cellular TV techniques being proposed by the broadcasters might actually free up as much as 20-30% of the UHF spectrum including the taboo channels, depending on the mix between HDTV, regular TV, and other services. If these new technologies are used, existing television and radio broadcasters would have no need for any additional spectrum for broadcasting even if they wanted to add conventional channels. The technologies are currently under rapid development in the U.S. and in Europe, however, there are still too many unknowns to make a clear legislative decision on changing the way spectrum is allocated. Any additional space that is freed up should be made available to anyone who bids for it, and legislation should make that explicit, not fixing in advance who may use it. - Any major modification of the use of TV spectrum to be compatible with the needs of the national information infrastructure must take into account universal access, including two-way interactive, symmetrical needs. There are many firms investing in interactive spectrum-based services who need to appreciate how much competition they will have before making large investments. It is not clear in the proposed legislation whether one-way broadcasting or two-way interactive services will be permitted. This should be explicit.
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- This note gives a good set of points relating to the "Spectrum Grab" -- MIT Memo to Markey on Spectr David Farber (Mar 07)