3/20 FCC Reply Comments with Public Knowledge and Consumers Union Opposing Allocating Vacant TVWS Channels for the Next Gen TV Transition

New America's Open Technology Institute filed reply comments with Public Knowledge and Consumers Union to the Federal Communications Commission (FCC) opposing a proposal to give broadcasters access to vacant channels to facilitate the transition to ATSC 3.0. OTI, PK, and CU responded to arguments in the record to note the strong opposition to the proposed spectrum giveaway, that the Communications Act prohibits the giveaway, that the proposal would incur significant damage on the public interest, and that the proposed giveaway is unnecessary and will come at great costs for consumers and other parties. An introduction is copy and pasted below:

Consumers Union, the Open Technology Institute at New America and Public Knowledge (Public Interest Organizations or PIO) hereby submit the following Reply Comments to the ATSC 3.0 Further Notice of Proposed Rulemaking. The record demonstrates that a broad and diverse range of industry associations, companies and consumer advocates strongly oppose the premature, legally questionable, unnecessary, and ultimately counterproductive proposal by Sinclair‘s ONE Media that some select group of local broadcast licensees should be granted a free additional channel of spectrum to compete with mobile carriers in providing new, mostly fee-based mobile video services. Doubling a station‘s free spectrum assignment may hasten the rollout of certain fee-based ―Next Gen TV offerings that compete with mobile carriers and other ISPs, but it is not necessary at this time to protect consumers and it comes at a high cost, as rural broadband providers, Wi-Fi innovators, wireless microphone makers, cable MVPDs, and other stakeholders described in their comments.