Reading today's hometown newspaper, the TV Highlights column at left caught my attention. For a long time our local paper had included in reviews and recommendations non broadcast video sources such as HBO and Netflix, but this was the first time that I, at least, noticed a nonsubscription streaming service such as Crackle - "Your source for free streaming entertainment". Now Crackle in some ways is not that different than YouTube, in that both offer free video, sometimes with advertising.


But now a major newspaper is placing them in the same category as NAB members and multibillion dollar HBO and Netflix. Wow!


Then I noticed the tweet below from @bcbeat = Broadcasting & Cable magazine. Those of us who have been along for a while remember when Broadcasting magazine, the predecessor of today's Broadcasting & Cable, under the late Sol Taishoff, was the TV broadcasting industry's biggest cheerleader. It didn't cover broadcasting news, if was more like today's Fox News' relationship with conservative Republicans and Sol played the Rupert Murdoch role. Today B&C includes "cable" in its name, dropped all coverage of radio broadcasting, and is owned by NewBay Media, a publishing firm also in several other areas of media business publications.

After HBO, which network won the second-most awards at the 2015 Primetime Emmys? Take our annual News Quiz: https://t.co/6CbDnrQkQ2

— Broadcasting & Cable (@bcbeat) December 29, 2015

Note that the B&C tweet very visibly reminds readers of the embarrassing detail, reported previously here, that mainstream OTA broadcasters are getting smaller and smaller shares of the annual Emmys. Who knows, maybe Crackle will become eligible soon?

Then I was listening to NPR last week and heard a story from their TV reviewer:

When it came to new programming, broadcast TV didn't impress critic David Bianculli much this year. But if you add in cable and streaming services, then the story changes.

All told, cable and streaming made it "another great year for TV," Bianculli tells Fresh Air's Terry Gross. The year was so good, in fact, Bianculli says he could have made a Top 20 or even a Top 30 list, but in keeping with tradition, he has narrowed it down to 10 — OK, fine, 11 — picks:

Bianculli's picks are here. They include "The only show from broadcast TV on my Top 10" - The Good Wife as #4. AMC and FX had 3 shows each, Comedy Central 2 , and Amazon and Showtime had 1 each.

So with the incentive auction coming up, we hope industry will consider why there is a flurry of such news stories. Is it a CTIA conspiracy or is it just the "writing on the wall"?




UPDATE

Concerned that we are unfairly dissing the content of OTA TV?

I was watching NBC's Today Show New Year's morning on my DVR. (See, I do watch some OTA! But usually on my DVR since most of the commercials are so annoying.) At 7:42 AM they had a segment on "What to Watch For in TV, Music, & Movies" in 2016. The person interviewed was Ms. Meeta Agrawal, Deputy Editor of Entertainment Weekly. Her recommendation for TV: USA Network's Mr. Robot.

Now I realize that USA Network is part of the same NBCUniversal that brings you the Today Show and owns the NBC affiliate in DC, but with a straight face could they have mentioned some OTA show as something great to watch for 2016? Despite all the great cheering from NAB and the kowtowing from FCC commissioners, isn't OTA TV losing to other video alternatives because of the quality of the programming they offer - independent of any spectrum policy issues?

Tags: broadcasting, incentive Auction

On July 7th an unusual coalition filed a letter in the incentive auction proceeding to “urge the Commission not to relocate television stations in the duplex gap in the forthcoming broadcast television spectrum incentive auction.” The coalition consisted of:

National Association of Broadcasters, Radio & Television Digital News Association, Microsoft Corporation, Utilities Telecom Council, Wireless Internet Service Providers Association (WISPA), Engine Advocacy, Spectrum Bridge, Consumers Union, Consumer Federation of America, Open Technology Institute at New America, Public Knowledge, Free Press, Common Cause, Benton Foundation, Rural Broadband Policy Group, Institute for Local Self-Reliance, Access Humboldt, and Akaku Maui Community Media.

Kudos to those who were able to bring such a coalition together on any issue! We do not necessarily disagree with the bottom line of the letter with respect to preserving the duplex gap for unlicensed and wireless mic use, but we want to make clear:

Future of Local TV News Does Not Depend on Duplex Gap Spectrum!

The letter has several statements on this issue:

• “Placing television stations in the duplex gap …would significantly undercut the public interest benefits associated with the auction ..r by preventing both mobile news reporting and deployment of low-band unlicensed spectrum in the places where low-band spectrum is most needed to effectively provide these services.” p. 1
  
• “…eliminating reserved spectrum for wireless microphones could leave newsgathering operations without necessary spectrum to cover breaking news.” p. 1
  
• “…preserving critical news reporting” - p. 2
  
• “The proposal would hamper reporting of breaking news in the most populous cities.” - p. 2

The above statements only make sense with respect to using the wireless microphones that are presently owned by TV stations. TV stations sell for prices in the order of millions of dollars. The value of their wireless mic equipment inventory is a negligible fraction of their net worth. While it is true that alternative spectrum wireless mics are not available in the US today, the main reason is the basic truism:
Free spectrum is always cheaper than any new technology!

And the wireless mic spectrum referred to in the letter is FREE spectrum using outdated technology!

Today’s Wireless Mic Spectrum is Both a Technological and Policy Anachronism

Maj. Armstrong - Inventor of FM

Use of wireless mics in interstitial channels between active TV stations was a good idea in the era of analog NTSC TV when the “UHF taboos” resulted in only one out of every 6 channels being used in a given city. Most wireless mics still use the FM technology invented by Maj. Edwin Armstrong 80 years ago and which has been or is being phased out in almost all radio services. Indeed, in FM wireless mic systems FM intermodulation due to receiver limitations is usually the limiting factors in spectrum utilization - not the required bandwidth of the signals.

The irony is that even with the duplex gap available, in major cities theatrical productions, concerts and major sporting events will be hard put to use traditional wireless mic technology because of the near or complete elimination of virtual channels.

Since 1995 commercial spectrum users, e.g. broadcasters, have generally been expected to pay for spectrum use. Note that the PTC-related rail accident in Philadelphia highlighted the fact that Congress ordered he railroad industry to implement spectrum-based PTC but told them to buy spectrum access for existing licensees. Why do broadcasters feel they are entitled permanently to free spectrum access for wireless mics?

Is there a technological option? Yes at least one and certainly many others. But FCC's focus at throwing more spectrum at the problem removes any incentive for private capital formation for more efficient technology. Qualcomm developed several years ago a technology called FlashLinq for peer-to-peer communications in cellular spectrum under the control of cellular carriers similar tpthat way they control femtocells. This technology would allow cellular carriers to sell access to inevitable "white space" in their service areas that can only be used for lower power short range communications. Why is the product dead or dormant? Neither wireless mic users nor cellular carriers want anything to do with it! Wireless mic users are addicted to free spectrum and obsolescent technologies. Cellular carriers are addicted to the "killer app" mentality where they don't want a new service or revenue stream unless it is huge. Cellular operators can't fathom that eliminating other spectrum using by converting them to customers rather than fellow spectrum lustors might actually help their long range goals.

Today's smartphones are basically 2 way communications systems capable of sending and receiving 100s of kilobits or more of data. While your standard iPhone offers neither broadcast quality audio not easy access for sending high speed data from an external source, it is not rocket science to modify the interface to permits external high quality microphones with analog/digital convertors to interface with such a smartphone so the on the screen newsperson gets his/her audio out that way, not via Part 74 spectrum.

Other technical option are possible, but who would develop them given the present wireless mic policy impasse at FCC?

The issue of spectrum for concerts and theater is more complex technically because of both high quality audio requirements and requirements for minimum delay (less than 10 ms.). But again this does not seem impossible if FCC stops throwing spectrum at users with outdated technology who don't want to pay for spectrum.

So there may be reasons for keeping the "duplex gap", but the future of local news isn't one of them.

Tags: incentive Auction, Wireless Mic Issue

Two weeks ago we reported the dismal showing of over-the-air DTV programming in the Golden Globe Awards - only one award went to OTA DTV and that was to PBS, not a commercial broadcaster. In this week’s Screen Actors Guild (SAG) Awards, at last a commercial network actually won an award! And OTA DTV broadcasters actually won 2 out of 8 award. Clearly a justification for keeping lots of spectrum for TV broadcasting.

Here are the Television winners:

Outstanding Performance by an Ensemble in a Drama Series
"Downton Abbey" - (PBS)

Outstanding Performance by an Ensemble in a Comedy Series
"Orange is the New Black" - (Netflix)

Outstanding Performance by a Male Actor in a Drama Series
Kevin Spacey - "House of Cards" - (Netflix)

Outstanding Performance by a Female Actor in a Drama Series
Viola Davis - "How to Get Away with Murder" - (ABC)

Outstanding Performance by a Male Actor in a Comedy Series
William H. Macy - "Shameless" - (Showtime)

Outstanding Performance by a Female Actor in a Comedy Series
Uzo Aduba - "Orange is the New Black" - (Netflix)

Outstanding Performance by a Male Actor in a Television Movie or Miniseries
Mark Ruffalo - "The Normal Heart" - (HBO)

Outstanding Performance by a Female Actor in a Television Movie or Miniseries
Frances McDormand - "Olive Kitteridge" - (HBO)

Tags: broadcasting, incentive Auction

Notice something spectrum-related in last night’s Golden Globe awards? All the commercial over-the-air (OTA) TV broadcasters got skunked! The only OTA channel/network that got an award was PBS for Downton Abbey .

PRIME-TIME TELEVISION

Drama
The Winner: The Affair - Showtime

Actor, drama series
Winner: Kevin Spacey, House of Cards - Netflix

Actress, drama series
Winner: Ruth Wilson, The Affair - Showtime

Comedy
Winner: Transparent - Amazon

Actor, comedy series
Winner: Jeffrey Tambor, Transparent - Amazon

Actress, comedy series
Winner: Gina Rodriguez, Jane the Virgin - The CW

Miniseries or TV movie
Winner: Fargo - FX

Actor, miniseries or TV movie
Winner: Billy Bob Thornton, Fargo - FX

Supporting actor, series, miniseries or TV movie
Winner: Matt Bomer, The Normal Heart - HBO

Actress, miniseries or TV movie
Winner: Maggie Gyllenhaal, The Honorable Woman - SundanceTV

Supporting actress, series, miniseries or TV movie
Winner: Joanne Froggatt, Downton Abbey - PBS

So as the TV broadcast establishment thinks the solution to their problems is giving away free TV antennas to wean people from nonspectrum alternatives, maybe when they gather in Las Vegas in April for the annual NAB Show, which all FCC commissioners must attend (just like for CTIA) and genuflect at, they should discuss if they really have a product that the public wants to view? Or perhaps in this day and age they should consider the Incentive Auction as a positive option? Maybe they should heed the advice of Justice Alito -- who has life tenure and doesn’t have to be as obsequious as FCC commissioners and members of Congress:

Tags: broadcasting, incentive Auction

From Scott Baxter’s AFCCE presentation 10/13


On June 25, 2013 our friends at CommLawBlog published a surprising post that has not received much attention. It was entitled “Harmonic Convergence? FM Interference to 700 MHz LTE Service” and was authored by Peter Tannenwald.

The post starts:

The introduction of different species into an established ecosystem tends to be a dicey proposition. Almost invariably, co-habitation requires the sharing of scarce resources. And more often than not, the different species approach the whole sharing thing in different, not entirely compatible, ways. The result: occasional dissatisfactions and frustrations – leading to occasional inter-species frictions and fisticuffs.

Take the RF spectrum ecosystem, for example.

Most inhabitants of the spectrum have historically figured out ways to coexist in relative peace (at least for the most part) – thanks largely to the fact that the potential impact of one service on another has been taken into account in the frequency allocation process. But as the demand for spectrum increases, and every little niche is filled up, it is becoming more difficult to avoid inter-service conflicts. And sure enough, the introduction of a recent new species – 700 MHz wireless systems using LTE equipment – seems to be causing some unexpected problems.

The post goes on to describe an emerging problem of interference from FM broadcast stations to 700 MHz cellular base stations nearby. A search of the FCC website on this issue found no public documents on the FCC’s voluminous website dealing with this issue. Fortunately Google found several non-FCC documents published after Mr. Tannenwald’s breaking post.

Barry Mishkind at The Broadcasters' Desktop Resource (BDR) published a report on June 28, 2013 that is linked to a detailed technical discussion of the issue. The public trail of this event appears to begin on 6/19/13 with the issuance of a Notice of Violation* by the FCC’s Enforcement Bureau’s New York District Office to WKZE-FM in Salisbury CT. The NOV alleges that their signal on 98.1 MHz had an 8th harmonic at 784.8 MHz that was causing interference to a VZW base station located approximately 500 feet away. The NOV cited 73.317(a):

(a) FM broadcast stations employing transmitters authorized after January 1, 1960, must maintain the bandwidth occupied by their emissions in accordance with the specification detailed below. FM broadcast stations employing transmitters installed or type accepted before January 1, 1960, must achieve the highest degree of compliance with these specifications practicable with their existing equipment. In either case, should harmful interference to other authorized stations occur, the licensee shall correct the problem promptly or cease operation. (Emphasis added.)

A major issue here is whether the above clear rule take precedent over the Commission’s general “first in time, first in right philosophy”** that is stated neither in the law nor as a general codified rule. We will leave it to our legal friends to parse case law on this issue.

Clearly the NAB crowd and the CTIA crowd have a major difference in viewpoint here. NAB’s past quixotic attempts to require all cell phones to have FM receivers certainly is not helping these industry giants’ mutual relationship, especially at this time of incentive auction focus by all.

We have not seen any public statements from the cellular community on this issue, so Scott Baxter’s comprehensive 10/13 presentation to the Association of Federal Communications Consulting Engineers, a mainly broadcast engineering group, is the most definitive discussion of the technical issue on the public record. (Scott’s usual clients appear to be mostly wireless firms.)

It is unclear what the technical problem here really is, although there seems no controversy that the FM transmitter in question meets the numeric out of band emission limits of § 73.317(d):

(d) Any emission appearing on a frequency removed from the carrier by more than 600 kHz must be attenuated at least 43 + 10 Log10 (Power, in watts) dB below the level of the unmodulated carrier, or 80 dB, whichever is the lesser attenuation.

Several possible hypotheses:

1. This out of band emission level of § 73.317(d) is not adequate to protect 700 MHz LTE base stations x meters away.
2. The usual measurement procedure for determining this emission limit may focus too much on the power that goes to the antenna and not enough on incidental leakage from the transmitter cabinets that might have inadequate shielding in some models. (This is consistent with observations in the Baxter briefing.)
3. The emission limit is adequate, but loose metal connections in or near the cellular antenna structure generate harmonics from the strong FM signal a few hundred feet away just as intermodulation products are generated in strong electromagnetic fields when there is a dense concentration of transmitters such as Mt. Wilson, CA and Sandia Ridge, NM.
4. The cellular base station receivers may be inadequately filtered/shielded and subject to desensitization in strong fields from the FM transmitter hundreds of MHz away. Despite years of talk, FCC still has no general policy on receiver performance issues.

Some observations:

• The IEEE-USA harmful interference white paper, released in July 2012, urges FCC to clarify the issue of “minimum protection distance” with respect to all interference issues since generally any receiver will get interference if it gets too close to a transmitter. While there are clear precedents for a few cases such as personal computers near TV receivers and UWB devices near PCS cell phones, FCC has no general position on this issue or even a process to determine minimum protection distance. Thus the cellular interests will say there is should be no interference at 500 feet and the broadcaster will disagree.
• Rather than keeping this issue off the public agenda, as it has so far except for the difficult to find NOV, FCC should be engaging industry experts in an open and transparent way. This highlights one of the problems of the FCC’s Technological Advisory Committee (TAC): it is not set up to handle this type of problem as it consists mostly of technical policy managers of key players, not the technical experts in the area (National Academy of Engineering members and IEEE Fellows are rare) and meets infrequently. Thus there is no indication of any TAC involvement to date as this problem threatens LTE roll outs. Note that another IEEE-USA 2012 product, “Position Statement on Improving U.S. Spectrum Policy Deliberations in the Period 2013-2017” addressed the issue of improving advisory function based on best practices of other regulatory agencies with technical jurisdiction:

  FCC and NTIA should supplement their existing Technological Advisory Council (TAC) and Commerce Spectrum Management Advisory Committee (CSMAC), which consist mainly of representatives of major communications firms, with a new advisory committee that serves both agencies and focuses on independent review of options for resolving spectrum conflicts and identifying outdated policies. The new group should be modeled on the EPA Science Advisory Board and the NRC Advisory Committee on Reactor Safeguards and members should have the necessary security clearances to deal with issues involving classified federal government spectrum users, if so requested.

• “Emerging interference” has been a recurring topic in this blog. In our dynamic wireless industry it is not surprising the new and unexpected interference mechanism appear in practice and need timely attention, for the bigger they become they usually become harder to solve. But for decades FCC has had no mechanism for dealing with emerging interference issues. Thus the police radar detector interference to VSAT receivers took more than a decade to resolve (the official FCC records “fuzzify” the starting date of the problem) and the “cellular booster” issue took 6+ years. FCC needs a generic and transparent problem for identifying such issues promptly and for engaging the public on which need urgent attention and which deserve “benign neglect”. For example, home TV antennas with built-in amplifiers, rare prior to DTV, are a recurring source of interference to TV and other services at a modest rate and it is marginal whether the issue needs regulatory attention at this time. But how many top FCC managers and 8th Floor residents are aware of this and other emerging issues?
• This is closely related to the reason why the Commission’s Spectrum Policy Task Force originally raised the issue of “interference temperature” a decade ago. The goal was to define better what environment systems should expect in practical operation. It may well be that the designers of these base station never considered an environment with a strong FM signal present from a nearby transmitters. But the NOI/NPRM in Docket No. 03-237 was so poorly and confusingly written that FCC closed the docket in 2007 and has never expressed any further interest in the issue. Whether or not interference temperature is ever used as a basis for allowing more unlicensed use, quantifying expectation really would help incumbents and would allow timely resolution of controversies such as this FM/LTE one.

Your blogger has filed a FOIA request with FCC seeking all correspondence on this issue with outside parties relating to the NOV. It does not seek internal FCC documents that have various FOIA exemptions. These documents will be posted here as soon as they are available. However, unless they embarrass Rupert Murdoch, that probably won’t be soon.

* The NOV URL given is from the FCC website, BUT we have found no way to get there unless you happen to have bookmarked the URL for Notices of Violation and Notices of Unlicensed Operation issued by Field Offices or the Enforcement Bureau’s old home page - no longer linked to the main FCC website.

** - The “newcomer” policy dates back to Midnight Sun Broadcasting Co., Memorandum Opinion and Order, 11 FCC 1119 (1947), in which the Commission held a broadcaster responsible for resolving interference caused by its new facilities to other preexisting facilities in close proximity. See FCC 13-115 at para. 4 and fn. 7

UPDATE

In a tweet responding to this post, Brett Glass hypothesized “FM could be hitting inadequately shielded IF stages in LTE equipment.”

Tags: spectrum management, FCC Reform, incentive Auction, interference management

They can’t both be right!

Remember a few years ago when CEA and NAB were cooperating in 2008-9 with each other to facilitate the DTV transition? Wasn’t that nice? Two industries sharing their toys like nice little children. Only a little earlier in 2005 they were accusing each other of things like “Perpetuating a Fraud on Consumers”. Well, they are back at each others’ throats again! The telecom bloggers of the USA thank both for this gift. Now that Jon Stewart is back, we hope he can benefit from it also.

On June 21, 2013 NAB announced that

New research from GfK Media & Entertainment shows that the estimated number of Americans now relying exclusively on over-the-air (OTA) television broadcasting increased to 59.7 million, up from 54 million just a year ago. The percentage of TV households currently OTA reliant has now grown from 14% in 2010 to 19.3% in the current survey, a 38% increase in just four years. The recently completed survey also found that the demographics of broadcast-only households continue to skew toward younger adults, minorities and lower-income families.

Who is GfK? They humbly say that

We're one of the world’s leading research companies. Every day, our 12,000+ experts discover new insights into the way people live, think and shop in over 100 countries. We use the latest technologies and smartest methodologies to help our clients deeply understand the most important people in the world: their customers.

Sounds a lot more credible than some blogger, doesn’t it?

But then only 9 days later, NAB’s former partner in DTV transition, CEA, announced

New research released today from the Consumer Electronics Association (CEA) ® found that just seven percent of American TV households rely solely on an antenna for their television programming. The findings of the new study, U.S. Household Television Usage Update, are consistent with CEA’s 2010 research which found eight percent of TV households reported using an antenna only for television programming. According to historical CEA research, there has been a gradual decline in the percentage of TV households using antennas since 2005. The phone survey of 1,009 U.S. adults is comparable to a 2012 Nielsen study indicating nine percent of all U.S. TV households are broadcast TV/over-the-air only, a decrease from 16 percent in 2003.

The CEA report was designed and formulated by CEA Market Research, “the most comprehensive source of sales data, forecasts, consumer research and historical trends for the consumer electronics industry” with “90+ years of research history” - GfK is only 79 years old, founded in Nuremberg, Germany in 1934. (Perhaps it isn’t fair to say so, but Leni Riefenstahl’s Triumph of the Will was filmed in Nuremberg in 1934 -- in case the date and location sound familiar. “By general consent [one] of the best documentaries ever made.” -- Roger Ebert)

The only publicly available details on the study cited by NAB in an entry in the GfK blog entitled “Confessions of a Cord Cutter Skeptic Revisited”. By contrast, CEA would be glad to sell you a copy of their whole study ($399 if costs matter, no cost to CEA members).

But the issue here is critical to the pending incentive auction and the whole question of the spectrum needs of TV broadcasting. So this is too important a question to leave to CEA/NAB finger pointing! So in the interest of closure on this issue here is:

A Suggestion to Resolve This Key Disagreement: For at least 2 decades FCC has been paying Census Bureau for quarterly telephone penetration surveys which have been noncontroversial since Census is viewed by all as unbiased on this issue. This data collection is now part of the he Current Population Survey (CPS), sponsored jointly by the U.S. Census Bureau and the U.S. Bureau of Labor Statistics (BLS). Just last Thursday, WSJ reported on the the latest survey and found that “more than a quarter of U.S. households have ditched landline phones”. Significant changes in consumer behavior result from pricing changes and technology changes.

Since the issue of OTA market share is critical for the incentive auction, why doesn’t FCC pay Census to track both OTA home penetration as well as telephone penetration? I suspect that the cost would be allowable as part of the expenditures to support the incentive auctions and thus need not come from the very limited FCC appropriated budget.

Tags: broadcasting, incentive Auction, National Broadband Plan

As the moguls of the broadcasting industry gather in Las Vegas for the annual NAB Show this week and the FCC commissioners travel west despite the sequester (no doubt remembering what happened when Reed Hundt had the chutzpah to go to a conflicting major ITU conference rather than genuflect before NAB in Las Vegas), the news shown at right is appearing in media outlets across the country. We have chosen the screenshot from CBS News to show that this is not the imagination of antibroadcasting forces at CTIA. But the same content is appearing in numerous news outlets, including today’s Washington Post.

On March 11, Nielsen (“We study consumers in more than 100 countries to give you the most complete view of trends and habits worldwide”) announced

“It’s true. Most people watch TV in their living rooms using traditional cable or satellite options. In fact, more than 95 percent of Americans get their information and entertainment that way. But as we explored what the other 5 percent are doing, we found some interesting consumer behaviors that we want to keep an eye on.This small group of video enthusiasts is tuning out traditional TV—and the trend is growing. This “Zero-TV” group, which makes up less than 5 percent of U.S. households, has bucked tradition by opting to get the information they need and want from non-traditional TV devices and services.”

While the Zero TV homes are only 5% of US households, the number has increased by a factor of 2.5 in the past 6 years and Nielsen found that “these video homes tend to be younger with almost half under the age of 35” - the same prime demographic that advertisers, other than AARP and Republican candidates, seek.

Bloomberg reported today

Together, the major broadcasters account for more than 21 percent of prime-time viewing in the current TV season, down from almost 75 percent in the early 1950s, before cable programmers emerged, according to Nielsen data.

So as the mechanism of the incentive auction slowly moves on to the 2014 deadline maybe TV broadcasters should think more about whether their business model should be pumping hundreds of kilowatts of RF power into the ether when it is rarely received by anyone other than headends of cable and other non broadcast video distributors, or should it be putting together packages of compelling programming and distributing it by whatever mechanism is appropriate for our era.

For good news about broadcasting, click below:

Tags: broadcasting, incentive Auction

As part of its continuing disinformation campaign about the FCC’s incentive auction that was approved by Congress over NAB’s strenuous objection (impossible a decade ago when NAB was much more powerful at FCC and on the Hill - sic transit gloria mundi), NAB’s Dennis Wharton just sent out the above message. The message deals with a letter from California congressmen, no doubt instigated by NAB.

The letter basically says that the FCC incentive auction NPRM did not ask enough questions. For the record, the 189 page NPRM (not counting statements by commissioners) has 260 poorly organized questions.

(This is a general problem of FCC NPRMs and results from the internal coordination process where all sorts of people from the 8th Floor down can add questions or can be “bought off” with adding a question to silence some concern. I note that procurement requests for proposals (RFPs) by military agencies are as thick as NPRMs. ask for replies by outside parties, but have much better organized questions. However FCC is so insular and believing in its own exceptionalism that it has no interest to organize its questions better or to even number them!)

So will the NAB disinformation campaign continue? Of course just as NAB’s first response to Hurricane Sandy was not to brag, rightfully, about broadcaster performance during the storm but rather “dis” the cellular industry. Below are some recent NAB tweets from @AirWharton on their ongoing battle with the cellular industry.

Note that NAB has been so technically unsavvy and behind the times that they use @AirWharton on Twitter because they don’t have any Twitter accounts using “NAB”, which belongs to National Australia Bank, whereas the more technically savvy and up to date CTIA certainly has @CTIA.

Tags: incentive Auction, NAB/CTIA feud