WASHINGTON-America's Public Television Stations (APTS) and the NAB are calling on the FCC to allow them greater use of Distributed Transmission Systems, while subsequently arguing that any proposal creating rights for unlicensed and secondary services to use DTS should be rejected.
These stances come from comments filed jointly by APTS and NAB regarding a Notice of Proposed Rulemaking by the FCC on changing its rules governing DTS.
APTS and NAB state that initial comments to this NPRM are supportive of the amendment that would have the FCC permit greater use of DTS. They say there are public interest benefits to amending the rules that would enable broadcasters to provide superior coverage, including at the edge of stations' service areas. It is also argued that such amendments should be done as quickly as possible as it could have an impact on deployment plans for stations transitioning to ATSC 3.0, the NextGen TV standard.
Swift approval of the requested changes will improve service to viewers, encourage investment and speed the rollout of ATSC 3.0 services, the comments read. We urge the commission to move forward quickly with an order amending the existing DTS rules.
The two groups acknowledge what they call the sole opposition to the DTS proposal, advocates for unlicensed and secondary services who are asking for the FCC to provide them with new spectrum rights. However, the National Translator Association has also shared its opposition to new DTS rules to the FCC via filed comments.
Specifically in its comments though, APTS and NAB name Microsoft, New America's Open Technology Institute and Public Knowledge that are pushing against changes to DTS rules because of the potential for such changes to diminish opportunities for the use of TV white space technology to close the rural broadband gap.
These arguments are inconsistent with commission rules and precedent and lack any sound basis in public policy, the comments read. The commission should reject the invitation to use this proceeding to create unprecedented and legally unsustainable rights for unlicensed and secondary services.
In fact, APTS and NAB make the case that expanded DTS operations could result in more opportunities for white spaces as it would help reduce dependence on TV translators operating on different channels to reach difficult service areas.
Broadcasters have proposed very targeted changes to the existing DTS rules that will allow them to realize substantial public interest benefits associated with DTS deployments, the comments conclude. The only opposition to this proposal comes from parties with secondary or non-existent spectrum rights that ask the commission to provide them with unprecedented and unwarranted protections that will have the effect of constraining innovation. The commission should reject these requests and allow broadcasters to provide better service to viewers through more robust in-home and mobile coverage and enhanced spectrum efficiency.
The full comments are available on the FCC's ECFS.
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WASHINGTON-America's Public Television Stations (APTS) and the NAB are calling on the FCC to allow them greater use of Distributed Transmission Systems, while subsequently arguing that any proposal creating rights for unlicensed and secondary services to use DTS should be rejected.
