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NPRM Info - APTS Urges FCC to Preserve EBS Requirements

APTS Urges FCC to Preserve EBS Requirements

On Thursday, March 7, America’s Public Television Stations met with the FCC to discuss the proposal of removing educational requirements for stations wishing to operate through the 2.5 GHz band previously available to Educational Broadcast Systems, among some other things. APTS filed an ex parte detailing its talking points in regards to this discussion.

For the actual meeting, Lonna Thompson, executive vice president, chief operating officer and general counsel for APTS, and the undersigned counsel for APTS, met with Rachel Bender, wireless advisor to FCC Chairman Ajit Pai. Thompson was joined over the phone by Tom Axtell, general manager of Vegas PBS; Anthony Padgett, president and CEO of South Carolina Educational Television Commission; and Georgeann Herbert, director of content and community engagement for Detroit Public Television.

As part of their presentation, Thompson and the others provided a list of the currently licensed public TV stations that also hold EBS licenses. They said that PTV stations have been “pioneers in using EBS stations to enhance educational service.”

The APTS also points out that EBS, following a previous transformation of the 2.5 GHz band in 2004, already accommodates emerging technology, including wireless broadband services, stating that the band is an example of a successful operation where it is licensed. It also makes the case that the EBS spectrum is not being underutilized, as its licenses cover 85 percent of the U.S. population; the band also is a component of Sprint’s 4G network and its upcoming 5G network.

In addition, APTS claims that the band facilitates both wireless educational services and commercial broadband deployment to consumers.They suggest the FCC should use this model to license EBS in areas where the spectrum remains unassigned, including local priority filing windows for Tribal Nations and educational entities.

And as for removing educational requirements for the band, APTS says that this will not create an open market as it might initially suggest. “The existing leasing model provides licensees with the opportunity to negotiate ongoing educational benefits, including devices, services and support from commercial operators,” the filings read. “With open eligibility, that relationship will dramatically shift. Commercial entities will have the incentive and ability to offer licensees unfavorable sale terms rather than new or renewed leases, cutting off educational benefits under the leasing model.

Other supporting documents that were presented by the APTS included a history and summary of services from Detroit Public Television on how it utilizes the EBS spectrum, and a letter on the benefits of EBS from Fritz J. Erickson, president of Northern Michigan University.

Another ex parte was filed last week by Thompson and the APTS, this time joined by PBS. This document detailed the organizations’ support for exempting or reducing the obligations on public broadcasters from the FCC requirement of broadcast licensees to provide public notices of the filings of various applications. The discussion also covered whether eliminating on-air public notices and converting to online public notices would ease or increase the burden on public stations, as well as the groups’ opinion that any modernization should reduce the regulatory obligations of public broadcasters.

Credit: Michael Balderson, TV Technology