FROM: James Edwin Whedbee
RE: Broadband Plan
To the Commission:
I am the owner of KZJW-LD. I continue to hear about suggestions by the Commission staff that the FCC intends to allow broadband providers to occupy television broadcast frequencies by removing broadcasters. After the digital TV conversion, citizens are having greater difficulty getting important TV broadcasts (like Tornado/Storm Warnings, for example). Sir/ma'am, I feel strongly that you are being intentionally misled into believing that there is: [a] a shortage of frequencies for broadband providers; and, [b] that broadcast TV spectrum must be taken away from broadcasters to furnish those frequencies. That is a lie. The Commission's current rules and regulations already permit broadcasters to use their TV frequencies to provide broadband services, either by doing so directly or leasing that spectrum to broadband providers. The broadband industry knows this.
Sir/ma'am, we provide a public service and programming free of charge to the public, and this erosion of our broadcast services is damaging the public by taking away their free access to those services. Taking away our spectrum and giving it to broadband providers amounts to the FCC picking winners and losers, a job the FCC was not given. If broadband providers truly had a shortage of frequencies, they could already have approached broadcasters with their own equipment and a reasonable offer to lease our facilities (the digital bitstream of the TV signals) and I'm quite sure that, given the economic times we're in, we'd lease them spectrum gladly. They've not done that. Put directly, broadband providers are crying wolf about a spectrum shortage they could already resolve by using what they've got more efficiently and approaching existing licensees and permittees if they wanted more...they'd rather lie to the FCC instead (and paper over their lie with faulty data to suggest a shortage). Sadly, some in the FCC are falling for this hook-line-and-sinker.
Sir/ma'am, before allowing the Commission to go one inch further on using TV Broadcast spectrum for broadband, please ask the broadband providers to approach us in broadcasting directly. We could use the fiscal leg-up and they'd get what they want without upending myriad FCC rules and regulations that serve the public interest well. We've not been given a fair shake in these proceedings and you and your staff are being used by an industry whose lobbying firms know how to get what they want. Alternatively, there's the 3650-3700 MHz band that's underutilized and already set aside for broadband. To these ends, I am...
Yours very truly,
/s./ James Edwin Whedbee, M.Ed.
5816 NE Buttonwood Tree Lane
Gladstone, MO 64119-2236
26 February 2010