The author is immediate past president and chair of the Government Relations Committee of the SBE.
The Society of Broadcast Engineers has as one of its chief purposes “to represent the needs of members before regulators and the industry.” One of the most visible ways we’ve done that is through our relations with the government, the Federal Communications Commission.
The SBE secured an invitation to take part in the FCC’s recent Broadcast Engineering Forum, shown here on the commission’s website. The society has a long history of representing issues of technical interest of broadcast engineers. During the past few years the efforts of the Government Relations Committee have been refined, with a renewed focus on having a positive and direct impact on the individual SBE member. As part of that, the SBE Board of Directors ratifies an annual list of legislative goals to ensure the society’s efforts reflect SBE member needs and priorities.
The current legislative goals are posted on the SBE website; see sbe.org/gov_index.php. The ratified goals for the 2009/2010 SBE Board term are:
- To protect the designation and capabilities of “broadcast engineers” from encroachment or abridgment by state and local governments. Resist state and local government restrictions of the term “broadcast engineer” and the practice of “broadcast engineers.” To also resist local and state infringement of broadcast engineers’ authority to perform the work necessary to operate and maintain federally licensed broadcast facilities.
- To protect the integrity of broadcaster access to frequencies designated as broadcast auxiliary service (BAS) spectrum; the principal that the FCC’s real role in spectrum matters is to mitigate interference; and the unfettered access to public information provided by broadcasters (especially during emergencies and disasters) who rely heavily on broadcast auxiliary spectrum to transmit relevant images, audio and data. SBE resists the re-farming of BAS frequencies and encroachment of secondary users.
- To promote the maintenance or increase of technical expertise within the FCC to ensure that decision-making by the FCC is based on technical investigation, studies and evaluation rather than political expenditures.
During times like these of extensive and creative new technology development, the FCC must have impartial and exceptionally trained engineering and RF experts on staff to ensure applicant claims are reasonable and substantiated based on sound technical principals and commonly accepted good practices of experimentation and engineering. As opposed to typical legal issues, the reliance simply upon the adversarial process while ignoring technical facts is an insufficient and inefficient method of determining in an unbiased way the veracity and accuracy of new technical concepts and complex physics.
- To promote a comprehensive and uniform federal preemption policy to all types of FCC regulated communication facilities.
- To pursue the federal preemption of local and state RF exposure standards.
- To pursue such other matters that are brought to the attention of the Government Relations Committee by members, the board or partners SBE is working with on its legislative agenda.
As you might imagine with this comprehensive list, the society is busy. Here are some of the issues we’ve been working with recently:
FCC Commissioners Technical Resource Act
This issue relates to the third SBE legislative goal, “to promote the maintenance or increase of technical expertise within the FCC.”
You may remember the days when FCC commissioners were required to have engineers on their staff. This limitation was eliminated in the 1980s to improve the flexibility of the commissioners to organize their own staffs. Unfortunately, the result has been that the commissioners are now surrounded almost exclusively by lawyers and economists.
This has created a severe disconnect in two ways: Policy decisions may be made based on political expediency, economic opportunity or mathematical reasoning but lacking an understanding of the harsh reality and physics of RF or the experience to ascertain the veracity of a proponent’s technical claims. There is also a wide chasm between the decision-making policy branch of the commissioners’ offices and the vast institutional and engineering knowledge and expertise at the FCC bureaus.
The SBE has noted a number of FCC policy decisions that were made against the recommendation of the FCC bureau experts and that seemed to have been based on political rather than technical grounds.
Engineers at the policy level of the FCC would help ensure that commissioners have valid technical guidance but could also provide a valuable communications conduit between the FCC bureaus and the commissioners.
In December the SBE was approached by the staff of Sen. Olympia Snowe (R-Maine) to support S.2881, a bill that would allow each FCC commissioner to add a member to their staff but would require that the new member be an engineer or computer scientist. The society has fully engaged with this effort through press and education efforts and even visits to Capitol Hill to speak to prospective co-sponsors.
Initial efforts were very promising. The Senate bill was scheduled for markup very quickly and, immediately following our Washington visit, a companion bill in the House, H.R.4809, was introduced.
Unfortunately, the window of opportunity for this session of Congress may be closing due to the congressional summer recess, the fall mid-term elections and the end of this session of Congress, which comes early this year. Though the Senate version of our bill has been favorably reported out of committee with a recommendation that the bill pass the Senate, the House bill has not gained a significant number of co-sponsors and time is running out for activity. The majority and minority in the House have not been able to come to agreement on a “package” of FCC reform bills, and ours is swept up in that dispute. If the bills do not pass in the few legislative days left in this session, we are optimistic that they will be reintroduced in January. We urge you to contact your senators and representatives about this important legislation. Everything you might want to know about this issue is at the SBE website at sbe.org/gov_issues.php.
Broadcast Auxiliary, BAS
As part of government relations, in conjunction with our unique program of frequency coordination, we are coming to the end of the landmark 2 GHz relocation plan. Sprint/Nextel partnered with MSTV and the SBE to make this almost-insurmountable task a reality. There are lots of thank-yous to go around with this program, not the least of which are for SBE frequency coordinators and TV stations across the U.S. who helped make this an orderly transition.
Individual SBE chapters continue to wrestle with the thorny issues related to dwindling frequencies for wireless microphone operations and expanded operation of AWS operations near broadcast 2 GHz frequencies. Frequency Coordination Chair Joe Snelson has a big handful of issues to work with.
The SBE’s government relations efforts include participation in the ongoing Emergency Alert System improvements although the heavy lifting is being done by the EAS Committee itself.
This includes participation in OASIS ratification of the CAP standard by EAS Committee member Gary Timm of SBE Chapter 28.
The SBE presented a free Webinar on Aug. 19 to provide some of the critical information for broadcast engineers to prepare their operations for changes. Keep an eye out for e-mail and SBE website announcements for a follow-up webinar on this important educational opportunity.
FCC Broadband Plan
Although this issue may have an immediate impact on our brethren in television, it is the proverbial broadcast “elephant in the room.”
The current FCC and presidential administration have committed to wide deployment of broadband services to Americans. This is truly a laudable objective but the FCC has taken aim at broadcasting to help satisfy the need for RF bandwidth.
Specifically the FCC wishes to obtain 120 MHz of spectrum currently used for free over-the-air TV and reallocate it by auction for broadband delivery services.
On June 25, the FCC convened a “Broadcast Engineering Forum.” The purpose of the meeting was to discuss four specific considerations of accommodating television broadcasters: cellular-type signal distribution; methods to repack TV band so the current number of TV channels could be delivered using less spectrum; advances in VHF reception; and video compression technologies.
The forum was composed of two parts, a morning meeting of workgroups followed by a public session in the afternoon where the results of the workgroups’ efforts would we announced.
When the forum was announced, the SBE felt our members should be represented at this important meeting. Although many skilled and influential broadcast engineers were invited to participate, the society was disturbed that there seemed to be resistance to participation by the singular organization chartered to represent broadcast engineers. SBE President Vinny Lopez released an open letter to FCC Chairman Julius Genachowski protesting the society’s exclusion from the meeting and articulating concern that the study process lacked transparency.
Shortly afterward, the FCC extended invitations to the SBE. Vice President Ralph Hogan and Frequency Coordination Chair Joe Snelson participated in the workgroup sessions and attended the public afternoon session.
A playback of the public session is available at the FCC Video Archives at reboot.fcc.gov/video-archives. Other information from the meeting is posted at the FCC website for the event, reboot.fcc.gov/workshops/broadcast-engineering-forum.
The SBE has not taken an official position on the TV channel reallocation issue, but as with issues like frequency coordination and EAS, our members have core competence with technical issues and can provide reason and technical direction to complex issues.
While the society expects to be involved with further discussions on this issue, the SBE’s primary commitment is to provide education and information to our members so broadcast engineers can respond appropriately. Suffice it to say, this is an issue we’ll be watching closely.
There is always more to learn about these issues and the many others the SBE works with. We encourage you to visit www.sbe.org for more details on the society’s legislative and government relations efforts, updates on the current issues and educational opportunities.
Barry Thomas, CPBE, CBNT, is vice president of engineering for Lincoln Financial Media.