FCC Commissioner Mignon L. Clyburn believes that it might be time to evaluate whether low-band VHF channels 5 and 6 (76-88MHz) would better serve Americans with a large variety of radio broadcast channels as opposed to a handful of DTV signals.
At least that's what Clyburn indicated in her remarks to the 35th Annual Community Radio Conference in St. Paul, MN, on June 10. Addressing a perceived shortage of available allocations for LPFM, the Obama appointee noted that TV 5 and 6 "have proven difficult for television broadcasting … this spectrum is not well suited for digital (broadband) transmissions. It certainly is possible that this spectrum could be used for LPFM, expanded NCE use, and AM broadcasters."
But Clyburn stopped short of advocating immediate reallocation of those channels, saying instead that the Commission needs to see where AM, expanded NCE FM, and LPFM radio broadcast services fit in as the government re-examines how it uses spectrum. She also encouraged would-be community broadcasters to consider the possibility of populating HD-2/HD-3 channels on existing NCE or commercial stations, reminding the audience that such channels are eligible programming for FM analog translators.
Clyburn's comments must seem a bit ironic -- or at least overdue -- to members of the Broadcast Maximization Committee (BMC), a group of respected consulting engineers and industry professionals who proposed reallocating TV 5 and 6 to a new digital-only transmission system (possibly employing an open-standard technology such as DRM+) well over two years ago. At that time, the organization submitted a thoughtful, well-developed, 122-page , suggesting that such a service could accommodate LPFM, expanded NCE, as well as all current AM services in an adjacent portion of the band.
When it was filed, the proposal drew little reaction from the FCC and was labeled a pipe dream by many industry pundits. Yet two years after the fact, the concept may be gaining traction, as diminished fortunes in TV broadcasting makes another substantial reduction in over-the-air TV spectrum now seem probable or even inevitable. Likewise, the potential for mobile broadband to overtake terrestrial radio as a primary delivery source for audio services looks increasingly dubious, as cheap unlimited mobile broadband plans disappear.
Curiously, Clyburn's remarks seem to center on the radio potential of TV 5 and 6 as a space for expanding analog FM service -- presumably with an IBOC hybrid option. But analog radios with coverage of more than 5 percent of that band currently don't exist. If the process is to move forward, broadcasters and policymakers will have to grapple with the issue of having to convince Americans to buy yet another "new" radio, regardless of whether pure digital or analog/digital hybrid technology is specified. As the BMC proposal points out, fresh spectrum presents a unique opportunity to deliver the efficiency, flexibility, and throughput of all-digital delivery. And that's something anyone looking at re-purposing TV 5 and 6 need to keep squarely in focus.
It's quite possible that Clyburn's comments may amount to nothing more than rhetoric calculated to please a select audience. But if they do indeed signal a new willingness by Commissioners to take up the issue in earnest -- as they should -- let's hope policymakers consider all the options and stakeholder interests thoughtfully before acting.