The FCC’s National Broadband Plan Public Notice #26, which sought comment in December on whether TV broadcast spectrum should be repurposed for wireless broadband use, triggered significant debate among broadcasters, commercial wireless companies, and public safety entities.

According to the wireless industry, up to 800 MHz of additional spectrum must be allocated for commercial use in order to meet growing consumer demand for wireless broadband services. CTIA and the Consumer Electronics Association (“CEA”) argue that by shifting full-power TV stations to a low-power architecture, 100-180 MHz of TV broadcast spectrum would be available for commercial wireless services. Under this proposal, full-power TV stations would be grouped into a smaller portion of the existing TV broadcast allocation by reducing the spectral separation between licensees. Other members of the wireless industry noted that consumers are increasingly using means other than over-the-air broadcasts to receive video programming, such as multichannel video programming distributors and the Internet.

However, broadcasters urge the FCC to make wireless companies demonstrate that they are using already-allotted commercial wireless spectrum efficiently before reallocating TV broadcast spectrum. One group of broadcasters noted that “the channel-sharing and service area reductions contemplated in the Public Notice” would eliminate their ability to “innovate and meet public demand” and would likely lead to “widespread viewer reception difficulties.”

Two public safety groups – the National Public Safety Telecommunications Council and the Association of Public Safety Communications Officials – also urged the FCC to consider public safety needs when looking at TV broadcast spectrum. According to the groups, a part of TV channels 14-20 are allocated for public safety use and other private land mobile radio communications services in 11 of the largest U.S. metropolitan areas and “has become a principal source of radio spectrum for interoperable public safety communications systems.” The groups further argue that public safety entities require access to more spectrum, not less.

In response to some broadcasters’ claims that the FCC intended on shutting down free over-the-air broadcast service, members of the staff working on the national broadband plan stated that they intend to recommend that any reallocation of TV broadcast spectrum for wireless broadband services be voluntary.