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Should the Entire TV Band Be Repurposed?

The engineers who worked heroically to push broadcasting across the digital threshold had barely caught up on their sleep before agitation for more change began to erupt. The National Broadband Plan concluded that the amount of over-the-air viewing doesn’t justify the number of broadcast stations, and that the FCC could use incentive auctions to re-pack broadcasting into a smaller band of spectrum. Now incentive auctions are the law. This decade we will likely see more broadcast spectrum repurposed for mobile services and another “transition” as hundreds of broadcasters conform their facilities.

So what’s the connection between incentive auctions and talk of a new technical standard? The FCC thinks we need more spectrum for mobile services — in large part because of rising use of video on mobile devices. But the FCC’s rules dictate a broadcast television technical standard that means much of the most popular video — which is already available free-to-air — can’t be received by mobile devices. The FCC is right that spectrum best suited for mobile services should be useful for mobile services. So why stop with the highest frequency TV channels? If we’re going to do all the work of another transition, why not open a path for consumers to access the entire TV band with mobile devices? Many of the same forward-looking broadcasters that championed 8-VSB are working with others on a new standard that incorporates next-generation transmission technologies, as an article in TVNewsCheck reported earlier today. ATSC 3.0 would be easily accessible on mobile devices and provide a much better indoor viewing experience as well. And it will be ready to deploy when incentive auction repacking takes place.

But will every broadcaster want to upgrade at the same time? And what about consumers? FCC rules require all broadcasters to use the same digital standard to ensure universality — so every television can receive every broadcast signal. But not everybody thinks that’s the best policy. Back in the 1990s, the FCC itself debated whether it should select one standard, approve several standards, or simply let the market work things out. It adopted the ATSC standard, but it also asked whether the requirement to use that standard should sunset after a critical mass of deployment was reached.

Nobody wants a television Babel. But what does universal access mean when people increasingly consume their video on-the-move and on devices that we don’t think of as televisions? In my home near downtown Bethesda, Maryland, pretty close to many of the region’s television towers, I can reliably receive only three stations, even with an attic-mounted antenna. I can’t receive any broadcasts on any of my computers, tablets, or other mobile devices.

I love broadcast television, but in my case, it’s difficult or impossible to use most of the time. Millions of other Americans either don’t use over-the-air television directly, or use it less than they otherwise might, for similar reasons.

As things have turned out, universal use of the first ATSC standard has not fostered universal access to broadcast television today. While all televisions in theory can receive all digital broadcasts, the need for often unwieldy external antennas and fixed installations leads most people to get their television (even their broadcast television) through a different delivery system — usually cable or satellite. And increasingly, people watch video on devices that don’t have ATSC television receivers at all — mobile and transportable devices like smartphones, tablets and computers that aren’t even tethered by power cords, much less by large, external antennas.

So the government-mandated broadcast standard, which was probably a necessary element of the first transition, hasn’t translated into universal access. By today’s very high standards, the original ATSC standard is inflexible and, for most consumers, too hard to use. My Android smartphone works everywhere in my house — on the same frequencies broadcasters used to use. I don’t even have to think about it. What if I could buy a 50″ television, mount it anywhere in my house, and receive dozens of channels on it for free and without any futzing around? What if most or all broadcast signals, in their native form, were easily receivable on tablets and smartphones?

My bet is that OTA usage would grow enormously and become far more “universal”. Nobody would distinguish between mobile and “fixed” television because it would be the same service. Networks and program suppliers wouldn’t be able to block broadcast stations from replicating their programming on mobile devices because the bitstream could be the same. Wireless carriers would eagerly include OTA capability in their devices, because the cost would be low, network congestion would be reduced, and they could count on a consistent, uniform quality of service indoors and when mobile (wireless carriers get lots of customer support calls when features don’t work consistently on devices they deploy).

All of this sounds great, of course, but broadcasters, the government and consumers just spent billions transitioning to ATSC. And who would choose the next standard and manage the next transition? Who would pay for the transition? Wouldn’t we just face the same issue again — by the time the next transition is complete, it would be time to upgrade again?

Let’s take these one at a time.

  • Cost of the last transition: Any economist or investor knows that when planning the best course of action for the future, you ignore sunk costs. The objective is to make the right decisions about the future, not to justify what was done in the past. If the objective is to best serve the public, it makes no more sense to require broadcasters to change technology prematurely than it does to prohibit them from changing when the market demands.
  • Choosing the next standard: Not the government. The government moves too slowly and has to cater to too many different interests. The next standard must be chosen by the market, which will take into account all of the same factors that have made less regulated communications services (wireless and broadband) so successful — cost, performance, flexibility, ease of use, global trends, and consumer benefits. Some fear a broadcast Babel if the government doesn’t mandate a standard, but that won’t happen. The wireless carriers have converged on LTE for 4G service with no government involvement at all. Broadcasters won’t transition until there is widespread agreement on technology by consumer electronics manufacturers and other broadcasters. Of course, the FCC has a big stake in this. FCC input is essential, its imprimatur is invaluable, and it must consider and regulate the interference environment. But the market should choose the next standard, and the next one after that.
  • Paying for the transition: Not the government. It won’t, and broadcasters shouldn’t want it to. The last transition took more than a decade. Of course ATSC is a huge improvement over NTSC. But the transition had to be heavily subsidized by broadcasters and the government because the government, not the market, set the transition timetable. If broadcasters are free to deploy new technology, they will deploy it when there is a good business case for making the investment. They will find ways to reach more viewers more often without disenfranchising the viewers they have. Rather than having to buy new televisions or converters, consumers will find that free broadcast signals are available on devices they already have. Or they will buy new televisions or converters willingly, because the performance and features will be vastly better.
  • Managing the transition: If broadcasters are free to deploy new generations of technology as the market demands, the whole notion of a “transition” as a unique event that has to be planned for and coordinated across government and industry would disappear. Not all stations would have to “transition” at the same time, or even transition at all. Will consumers lose “universal access” if different stations broadcast with different standards? No. Broadcasters would find ways to simulcast — perhaps through channel sharing, or perhaps by acquiring underperforming stations and using those to simulcast (the FCC should permit this by rule change or waiver). In any case, can an FCC that is encouraging broadcast stations to turn in their licenses and shut down to improve the mobile ecosystem really be concerned about some temporary, isolated loss of broadcast service to ATSC devices during a market-driven transition that improves service to the mobile consumer?
  • Subsequent transitions: These won’t be a problem. Broadcasting doesn’t need a sequence of transitions, it needs rules that permit continual transition. This is the norm in communications services when the FCC doesn’t mandate the technology, and it should be the norm with television broadcasting. Wireless carriers support two, three and occasionally even four generations of technology simultaneously while consumers upgrade their devices. They add a new technology every seven or eight years, then occasionally retire an old one and use that spectrum for yet a new generation of technology. The process is market-driven, almost invisible to consumers, and graceful in comparison to a government-orchestrated upgrade. If broadcasters are given the same flexibility, they will be able to roll out new technology to better serve consumers when the time is right, instead of when the government is ready.

None of this is intended as criticism of the existing ATSC standard. The entire digital video revolution was built on the pioneering work of broadcasters and the ATSC in the 1990s. But as the ATSC plans the next groundbreaking standard and the FCC plans to restructure the television bands, it’s plainly time to start thinking about how new technology gets deployed in the new band plan, which will not support companion channels. And to be clear, I am not suggesting some sort of regulatory back door that allows broadcasters to morph into broadband service providers. I like television. It’s a core service and the fact that Americans have access to a core service for free is a wonderful thing. This is about taking steps to ensure that the free, over-the-air broadcasting service we have today remains widely accessible as people change the way they use media in response to new technology.

Almost everyone agrees that the UHF bands are the best bands for mobile services and that demand for mobile services is growing fast. Doesn’t it make sense for the government to allow all consumer services operating in the UHF bands to be mobile-friendly? The incentive auction is going to happen; shouldn’t we all aim to make it successful? And shouldn’t we define “success” as bringing the best service to consumers that technology and the market can deliver? It’s hard for me to think of a good reason for the government and broadcasters not to take this sort of approach. If you agree, or don’t, I’d enjoy hearing your thoughts.