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  • alisonneplokh 9:32 am on March 13, 2018 Permalink  

    The Negative Sum Game 

    Microsoft would have you believe their proposal to require broadcasters to hold open at least one additional channel in the broadcast band for unlicensed use is not a zero-sum game. They are right, but not in the way they want you to believe.

    TV white spaces held a lot of promise over a decade ago. Perhaps it still does today – by letting unlicensed devices use channels TV stations aren’t using, there is the possibility to make more efficient use of spectrum and provide new services, potentially including additional options for rural broadband access. Broadcasters don’t have any problem with letting Microsoft use truly vacant channels, provided that broadcasters don’t permanently cede their rights to build on those channels in the process. NAB has and will continue to work with Microsoft and other TV white spaces proponents to make reasonable rule changes that improve the ability of unlicensed devices to make use of vacant TV channels.

    But that’s not at all what Microsoft’s “vacant channel” ask is about. Microsoft’s ask is not about using vacant channels, it’s about creating vacant channels. Microsoft is asking the Federal Communications Commission to require that, before broadcasters can make any changes to their existing licenses, they first ask whether there would still be at least one channel available for unlicensed use throughout their entire service area. This creates several costs to broadcasters and their viewers:

    1. No matter what Microsoft says, this is not a win-win proposal. The only way this creates extra space for unlicensed use is by denying a broadcaster a channel. Whether this broadcaster is a major network affiliate delivering high-demand programming and top-notch local and national news, a public broadcaster delivering high-quality educational programming, or an independent broadcaster delivering in-language programming to minority communities, this policy means one less voice in the media market. Microsoft maintains this would be a very rare scenario. But that evades the point that this policy is either irrelevant (because there are plenty of empty channels) or is harmful because it deprives viewers of service.
    2. Broadcasters would have to hold open a channel, even if nobody has any interest in using it. Whether it’s that the particular market in question has no demand for white spaces or that the whole white spaces idea is never successful, broadcasters can’t retain or expand broadcast service, because it would violate Microsoft’s proposed rule. White spaces is supposed to be about letting people camp on empty lots, not forcing broadcasters to leave their lots empty just in case someone wants to come along and pitch a tent, even if nobody ever does. Effectively, Microsoft gets squatters’ rights without even having to go through the trouble of squatting.
    3. Even if there is plenty of space available, broadcasters have to spend money to prove that. A few thousand dollars to conduct a study might sound like a small issue when you envision a large broadcast group, but this also applies to rural low-power television stations and TV translators that operate on a shoestring budget and are often community funded. And, multiply that “small number” by thousands of broadcast stations across the country, and you get to a really big problem.

    Calling this a zero-sum game is actually optimistic. At best, this proposal creates winners – the massive Microsoft Corporation – and losers – local broadcasters and their viewers. But most likely, everyone loses.

  • alisonneplokh 10:00 am on November 7, 2017 Permalink  

    Next Gen TV: Something to be Thankful For 

    With Thanksgiving coming up, I’m practicing my Olympic-caliber skills at dodging awkward conversations about politics, religion or when I’m going to have children. And that means having an answer to the question “what are you working on?” that does not immediately cause eyes to glaze over.

    Spectrum policy is really interesting to me, but I have to accept the fact that not everyone shares my passion for more efficient modulation or how in the world 984 television stations are going to change channels in a mere 39 months (now closer to 32). So, this year, I hope to hold people’s attention a little longer celebrating the FCC’s success in setting the stage for the future of television by approving Next Generation TV.

    But “what,” they ask, “is Next Gen TV?” It’s better pictures, better sound, enhanced emergency alerting with the ability to wake up TVs when there is major trouble headed your way, more interactivity, personalized programming and more. That should keep us busy for a while.

    But here’s my silver bullet for when the conversation starts to turn back toward when I’m having children. Next Gen can also offer a whole new way of bringing educational programming to children. As the Association for Public Television Stations pointed out last year [1], Next Gen TV brings with it the possibility of distance learning on a customized local level. Children could get lessons and materials customized to their curriculum at home without needing a broadband connection. Educational videos could be downloaded to Next Gen TVs in non-real time to be viewed on the student’s schedule, and applications could be delivered to practice these new skills.

    PBS Kids programming has proven to be very effective in improving kids’ academic scores [2]. Not to mention, its content is the most-watched educational programming out there. Low-income families in particular stand to benefit from the interactive educational features of Next Gen TV becoming available over the next several years.

    And, of course, I can remind everyone that those football games are going to look even better in 4K. I’m already looking forward to dessert.

    [1] APTS Ex Parte

    [2] Public Television comments, page 5

  • alisonneplokh 12:03 pm on February 13, 2017 Permalink  

    An Innovative Process for an Innovative Proceeding 

    Next Generation TV is all about finding new and innovative ways for broadcasters to reach the public. That’s why we think it’s very fitting that one of the proceedings Federal Communications Commission (FCC) Chairman Ajit Pai picked to pilot the FCC’s innovative approach to transparency is a proposal to move forward with Next Generation TV.

    This idea, first championed by Commissioner Michael O’Rielly, dramatically increases transparency in the Commission’s processes. It has always been the case that interested stakeholders in Washington can speak to staff in the commissioners’ offices to get a good sense of what is in an item on circulation. But, as they say, the devil is in the details. Frequently, those of us subject to the Commission’s rules can accept or even welcome the policy goal being advanced in an item, but complying with the specific rule as written by staff would be unnecessarily complex or burdensome. Without seeing the specific proposal before the Commission, stakeholders could only comment on broad outlines of a proposal.

    I also know how helpful this approach can be for Commission staff. As a former Commission staffer, I often longed for feedback from stakeholders on the feasibility of the rules we were preparing to adopt. Unfortunately, because my colleagues could not share the text of the item publicly, we were limited in our ability to get that feedback. Chairman Pai’s innovation changes that, allowing stakeholders to provide more helpful input and allowing Commission staff to ask more specific questions.

    Process reform like this can lead to tangible benefits down the road. When the Commission operates in the dark, it risks making avoidable mistakes that lead to petitions for reconsideration or litigation. This ties up Commission resources and is expensive and time consuming for industry and public interest groups alike. We’d much prefer the Commission get it right the first time, and increased transparency helps make that more likely.

    Of course, NAB doesn’t support every word of the draft Notice of Proposed Rulemaking. If we did, it would be hard to see a reason to support publishing a preview anyway. For example, the draft asks a lot of questions about a tuner mandate, something we and our co-petitioners agree would be counter-productive to the goal of a market-based transition. Additionally, the draft devotes a lot of space to retransmission consent arguments that have no bearing on enabling innovation in broadcast services, other than to stifle them. However, the opportunity to see the item before the Commission adopts it gives us a chance to provide thoughtful feedback and help the Commission frame the debate.

    We are thankful that we have had an opportunity to review the proposed rules before they are voted on to help ensure that the Commission’s proposals and questions make sense, and are even more excited about the prospect of having the same opportunity for draft Commission orders in the future. We applaud Commissioner O’Rielly for championing this approach and Chairman Pai for having the courage to implement it. We strongly believe the pilot will be a success.

  • alisonneplokh 9:55 am on January 6, 2017 Permalink  

    Google and Microsoft Continue Pushing Plan to Seize Channels That Actually Aren’t Vacant 

    As the broadcast TV spectrum incentive auction inches closer to its conclusion, Google’s so-called “vacant channel” (although more properly known as “Google channel”) proposal has once again crept out of the shadows. The proposal, for those who may have let this debacle fade from their memories, is that before thousands of low-power television stations and TV translators (we’ll just say LPTVs for simplicity) displaced by the incentive auction are allowed to find new channels to continue serving viewers, they must ensure there would be at least one channel available for unlicensed – or Google’s free – use. This time, the Open Technology Institute (OTI), Microsoft and Public Knowledge are carrying Google’s water. Perhaps inspired by the fall broadcast television lineup, Google and Microsoft are angling for “Designated Survivor” status.

    “Don’t worry,” they say, “our Google channel proposal won’t actually take LPTV stations off the air, as there is plenty of spectrum to go around. And besides, what is more important, television or internet?” Let’s unpack that argument a little.

    Plenty of spectrum to go around? If that were actually true, Google and Microsoft wouldn’t need a policy change; they could simply use the available space under the FCC’s existing TV white spaces rules. They know, however, that the incentive auction will send many LPTVs scrambling for new homes and that some markets are going to have such scarce spectrum availability that, even without finding homes for all of the LPTV stations, there will not be enough room for unlicensed operation in the TV band. To try to get around this unfortunate reality, in March, Google submitted a heavily flawed study that assumed the FCC would need to buy nearly twice as many stations as it must in reality to reach a conclusion that the impact would be minimal. Sure, if the government spends extra tens of billions of dollars to purchase spectrum, Google and Microsoft could get access to a little more “free” spectrum. And, of course, Google is conspicuously not bidding in the auction, either. Again, if Google was right – that its was a cost-free proposal – then what would be the point? Unlicensed devices can operate in the TV bands already where space is available. The Google channel proposal is really about turning away existing LPTV stations to make room for unlicensed Google devices.

    Which is more important? Usually that’s not even a question when you are addressing whether an unlicensed service should disrupt an incumbent licensed service, but okay, we’ll bite. Let’s first remember that, in 2008, Google promised “Wi-Fi on steroids” by the 2009 holiday season. Now having just concluded the 2016 holiday season, there are still fewer than 700 unlicensed devices operating in the TV bands, nationwide. Total. The TV white spaces rules have been in effect for nearly a decade, there are plenty of channels available and three times as many people bought the now-discontinued $10,000 18 karat gold Apple Watch than have bought TV white spaces devices.

    In contrast, there are hundreds of thousands of viewers relying on the signals of thousands of LPTV stations. For many people, LPTV is the sole source of televised news and entertainment. While unlicensed devices have others neighborhoods – 2.4 GHz, 5.8 GHz, now 3.5 GHz – the spectrum at issue is television’s only home.

    Also, we can’t help but point out that because the “open” in Open Technology Institute apparently only refers to their level of disregard for television viewers throughout the country, OTI did not file in the dockets dedicated to the issues they have raised. The filing also includes references to discussions about eliminating critical protections for licensed operation in the TV bands and a flimsy dismissal of NAB’s analysis of errors in the white spaces databases on the basis that the nearly non-existent deployment of TV white spaces devices has not yet caused harmful interference. These are open issues in two separate dockets in which OTI failed to file.

    Now we are beginning to see why Oxford Dictionary labeled “post-truth” as the 2016 international word of the year. Hopefully, 2017 can be the year when truth doesn’t mean a lie, open doesn’t mean concealed from the public and unlicensed doesn’t mean kicking off licensed services upon which the public heavily relies.

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