[SBE] The Future - What can we do about it.

[Dennis C. Brown]

I suggest the following:

    Former FCC Chairman, the late James H. Quello, explained what the 
FCC does, thusly:  "We take very difficult legal, technical and economic 
questions and to those questions we give political answers."  For some 
years, the FCC's political thinking has revolved around economics with 
legal and technical considerations often in second and third place.  The 
FCC is thinking in terms of the economic value of spectrum when used for 
various purposes.  It is under political pressure from various interests 
to improve broadband penetration and it is going to do something to 
satisfy those political interests.  SBE's objective should be to 
preserve and advance broadcast engineer employment.  That means that SBE 
should seek to limit the damage to broadcast engineer employment and to 
postpone the date on which any damage occurs.

     Economics:  Economists love to study.  SBE should analyze the 
economics of the proposal, hire economists to counter the proposal, and 
call for a great deal more, years more, study of the economics.  Argue 
the comparative economic merits of reallocating spectrum from someone 
else, rather than from broadcasting.

     Legal:  For the government to share auction proceeds with broadcast 
owners would require amendments to the Communications Act.  SBE should 
be involved in lobbying Congress for the most favorable, most postponed, 
legislation possible.  Broadcast owners will be resistant in proportion 
to the extent that they won't get their "fair share" of the auction 
revenues.  Among the arguments that SBE can raise are that, in the 
United States' current financial position, the United States can't 
afford to split the auction revenue; and the broadcaster is entitled to 
no more buyout compensation, if any, than current revenues times the 
number of years remaining on its license.  SBE could lobby for 
protection of stakeholders such as broadcast engineers by the 
government's providing copious quantities of funds for occupational 
retraining and retirement compensation.  If there is to be a split of 
revenues, demand that the broadcaster be required to buy out displayed 
employees.  Recognize that there will be a split between broadcasters 
which want a buyout opportunity and those which don't.  Make an ally of 
the category which doesn't want to surrender and take a coordinated 
position on the economics.

     Technical.  Whatever the plan is, broadcast engineers are the ones 
to show that it won't work.  Call for more, oh my, years more, technical 
study, especially in light of the FCC's surprisingly wrong projections 
of digital VHF propagation and the limited extent of knowledge of ATSC 
reception problems and solutions.

     In short, SBE should use all three avenues, economic, legal, and 
technical to make it difficult for the FCC to act.  SBE's forte is 
engineering but SBE cannot neglect the opportunity to approach the 
problem from all three vectors.

     We need to recognize that this is not the first time that 
reallocation of spectrum to satisfy political demand has been proposed 
or has occurred.  For example, there is no TV Channel 1 because the FCC 
took it from TV and gave it to land mobile and then to the Amateurs.  To 
accommodate Nextel, the FCC forced thousands of small business land 
mobile entrepreneurs to swap channels with Nextel.  To accommodate 
various interests, the FCC reallocated TV spectrum above 700 MHz and 
destroyed some of the value of hundreds of millions of TV receivers.  To 
accommodate the FCC's desire to decrease bandwidth, thousands of land 
mobile radios will become obsolete in the next few months.  We cannot 
underestimate the tenacity of the FCC once it makes a decision.  But it 
makes decisions slowly.  In this case, the slower, the better.

Curt Brown

On 3/19/2010 4:22 PM, Barry Thomas wrote:

> I laid the gauntlet out; let me be the first to offer an answer:

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> The chair of our Atlanta SBE Chapter, #5, is committing one of the monthly meetings to just this issue.

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> Full disclosure, Bill asked me to be on the panel since I'm the national Government Relations Chair but you get the idea.  Details at www.broadcast.net/~sbe5 (links, bio info, etc.)

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> Barry Thomas, CPBE CBNT

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