The FCC: corrupt, sanctimonious, and technocratic

Those vilifications of the FCC don’t come from me; they come from Jesse Walker, an expert on pirate radio. He has gotten to know the FCC pretty well over the last ten years and that is his assessment. Now my assessment is not quite as harsh. Firstly I would like to apologize for a factual error in that blog post. I said that the FCC was going to auction off the VHF channels 2 to 13. That is currently incorrect and I apologize. The FCC was going to auction off the spectrum, for a cool 30 billion or so but then changed their mind. This is probably due to a multiplicity of factors. First off, the wireless carriers that are trying to buy all the spectrum realized that channel 2 starts at 54 MHz and you would need a 10-foot antenna to get good reception. That means channel 2 – 6 are not very good for mobile applications and it is mobile where the cell phone companies can charge the kind of criminal rates that justify these billion-dollar auctions. Also there was sure to be some complaints from the broadcast industry that valued the VHF band. It will be interesting to see what happens to VHF now. The broadcasters have since done testing and they see that digital TV that they are required to broadcast after Feb 2009 does not work very well on VHF frequencies. So if the cell phone people don’t want VHF and the TV people don’t want VHF, the FCC can’t have a filthy lucre spectrum auction. As my previous post suggests, the FCC is not about insuring good reception any more. It is about making money. I wouldn’t worry too much, I am sure somebody will want to pay for the bandwidth. After all, the FCC themselves say that: “…all-digital broadcasting will free up frequencies for public safety communications” I suspect they will get Motorola to give them a few billion for the right to sell police radios. That is a lot less than the 30 billion they thought they would get for VHF, but hey, some lucre is better than no lucre.

Now maybe we should have a quick technical review, which, since the FCC is involved, will also review politics. See, the cell phone companies have way better lobbyists than the TV companies if only because the cell phone companies have a lot more money. I heard George Gilder give a speech were he said that the analog cell spectrum has generated more revenue than the entire TV broadcast industry since 1949. And it is not only the cell phone companies that want to gobble up spectrum. Intel and Google want to deploy wireless networks all over the country so they can sell hardware and advertisements respectively. So there has been a ton of pressure for the FCC to confiscate the TV channels and sell them off. The NAB is not exactly powerless, so the FCC knew that they would have to buy the TV stations off in addition to the usual threats of license revocation and other bully maneuvers the FCC has used over the years. So the FCC made a deal—they would give the TV stations 5, count them, five digital TV stations for each analog station. So if you had Fox channel 2 here in the Bay area the FCC gave them UHF channel 56. Then they invoked the magic of digital. Since digital TV is a compressed format, the new digital TV standard provides for 5 stations in the same bandwidth that the old analog channel took. They can offer just one station, and the broadcast will support pretty decent HDTV. Fox has chosen to broadcast two stations on channel 56, they have 2.1 which is the same as their VHF channel 2 and they also broadcast 2.2, which has some Spanish content.

So what’s not to like? Well quality for one thing. PBS channel 9 was given UHF channel 30 for its digital broadcasts. They use 9.1 for high-definition, 9.2 for re-runs, 9.3 for political and 9.4 for Spanish and 9.5 for kids shows. But because they are broadcasting 5 channels on the bandwidth of one old analog channel, the quality of the HD on 9.1 is abysmal. There are horrible artifacts. I called them jpeg artifacts in my last blog and someone pointed out the DTV is mpeg, but the mpeg standards is just a jpeg frame followed by something like 64 frames of change, or delta data—which pixels changed from that jpeg key-frame. So when the HD channel is showing pans or zooms or fire or running water the picture just turns into one hundred square blocks and looks like crap. The FCC gave 5 stations for 1, only you can only have talking heads if you want to use all five. It’s an analog world and you can’t get something for nothing, even with digital TV.

OK, now here is the rub, come February 2009, it is my understanding that Fox Channel 2.1 will stay up on UHF channel 56 and VHF channel 2 will go dark. Indeed there is some noise about TV stations complain that the FCC will make them switch to digital on their old VHF frequency. What has happened is that the TV engineers have figured out that the digital modulation used on digital television is really pretty touchy and it does not take much interference to ruin it. Older articles talk about how immune to interference digital is, but that seems to be a bunch of marketing. TV stations would rather stick with the interference they understand on the UHF bands then switch their VHF frequency over to digital modulation. Now as long as the FCC was moving everybody off the VHF band it was a no-brainer that they would sell it off. But I was wrong that all VHF stations are being given UHF digital stations. For the most part that is true but our NBC channel 11 in the bay area was given VHF frequency 12 for its digital channel 11.1. So the FCC has stopped clearing off the upper VHF band, the channels 7 to 13 that are above the FM radio bands. And now they realize that channels 2 to 6 need really long antennas and can’t be used for mobile, well, whets a bureaucracy to do? I am sure they will think of something that further reduces our quality of life and enriches the politicos and the government.

The quality of life issue will not concern most of you high-dollar engineers. You have cable or satellite TV. But this important article in the NY Times points out there are 17 million people like myself that have analog over-the-air broadcast TV. And 13 million of those use rabbit ears. This is what the disaster of the digital TV switchover will be. People will pay about 40 more bucks for a converter box, above and beyond the 40-dollar coupon they get from the government (politicians have to pay everybody off to do something as sweeping as rearranging the spectrum allocations). But after people hook their rabbit ears to the TV, they will see that there are some stations they can no longer get. I myself went through this. I only got a few digital stations on my Sharp 45 inch LCD with ATSC tuner when I had a ground-level antenna. Then I put up a 15-foot boom and I get most stations but some break up. Channel 36 is typical. I can watch analog 36 and it has a little snow but the audio is perfect. Digital 36.1 which is really on channel 56 keeps breaking up. I notice that after February channel 36.1 will go back to channel 36 frequencies. Who knows if the reception will improve or degrade?

So the disaster for the 17 million people that get broadcast TV will not be the extra money for a converter box. It will be the need to install a TV mast and put a rotator on the antenna as well as a beam-head amplifier in order to reliably get digital reception. And believe me, when some military sideband spurs come crashing in from Moffett field, the digital TV will just go away for 2 seconds until the stream gets reestablished and recoded. I can see this happen now when I watch digital TV.

Not everything is bad. Not at all. If a broadcaster puts out an HD program without having 4 other channels on the same frequency band, well the picture is stunning. This is obviously where we are headed. The TV broadcasters will realize they got hoodwinked by the FCC and the cell phone lobbyists and all they really got was one usable channel, not 5. If they get good equipment and make sure their antenna is optimum, those of us with towers and rotators will get pretty good reception. I don’t use cable and satellite on principle. The few hundred bucks and $1000 in labor for the antenna and tuners will be no big deal. I wish I could say the same for the 17 million other users of broadcast TV.

OK, the FCC never sleeps and now that they have made TV very prone to interference, well, why stop there? After all, there is plenty of filthy lucre out there. So now that there are real interference concerns with digital TV and the switchover is not complete and we are not sure how bad the interference is going to be, what would be better than putting up transmitters in the old guard bands between the TV channels? What Google and Intel plan to do with the bands is not clear, but the FCC is always willing to make a buck.

Now it is interesting that it is the digital and software people that are so sure that filling the guard bands with RF won’t cause any interference. I am sure there is lots of math and even more wishful thinking that wants to make it so. But just think for a second. The new transmitters in the guard band are not in outer space. Somebody has to be close to them, and those people will get clobbered with the inevitable side spurs that RF transmissions generate. Then you get multipath effects and all kinds of other joy as well. It is clear the FCC no longer cares about interference. It cares about money.

So I guess that is why my perspective is a little different from Jesse Walker’s. I don’t see the FCC as evil, they are just a bunch of people reacting to incentives, and all the incentives make them put revenue first, business profit second, and the people they are supposed to serve last. There is still a technical core at the FCC and those folks are the best. Just look at the FM radio station allocations. Some hard-core technical people at the FCC worked over the last 50 years to make sure that FM stations did not clobber one another. They even require some stations to reduce power at night when skip off the ionosphere could cause the station to interfere with another station in a town far away. This is what I call the old FCC, the men and women that are really concerned with keeping interference to a minimum and making sure we can all receive radio and TV broadcasts. They are primarily a technical bunch. The new FCC is mostly politicians. They preach about free market and business opportunities, but if they really believed in the free market they would sell the spectrum, not license the use of it. Then none of these issues would matter.

So I don’t want to be a too pessimistic here, I do not want to be a nattering nabob of negativity. It would be nice if the FCC really served us, then they would just make giant bands that were unlicensed but strictly controlled for power and modulation. Then Nokia could make phones that worked like walkie-talkies and you could talk to all your local pals for free since you would not need a “provider” to cell your calls and charge you a fortune. But the cell companies have the lobbyists so we are stuck paying for communications by the minute for a long time. So what can we do? Well, make sure the FCC does not come after the ham bands next. They already screwed people like model airplane enthusiasts, those RF transceivers have to put up with existing interference and it is sure to get worse when all these new transmitters come on line. I am going to ask a pal to do a little web feature on VHF and UHF antenna design so you can whip up your own cheaply. Also I will explore beam head amplifiers and rotators. Since I have two TVs that I watch simultaneously on different channels I am concerned about the need for rotators. I may try to make a multiple UHF antenna setup and let you know how that works. I would tell you to complain to the FCC but don’t bother, like the NBA, the fix is in and you just don’t matter to them.

One valuable resource was pointed out in the NY Times article. This site will show all your local TV stations and their assignments and their direction. Ignore the data mining—just type in your zip code and hit continue—then use the map to pinpoint your location. Continue once more and you will get a great list of all the nearby stations, the type of antenna recommended, and the direction and distance to the transmitter. Great stuff, you will need it in February when some of your friends and neighbors are trying to watch the Simpson’s and ask for your help.

Nice chart of the radio spectrum

Authorized frequency usage

History of American Broadcasting