STATEMENT OF
COMMISSIONER MICHAEL J. COPPS
Re: Innovation in the Broadcast Television Bands:  Allocations, Channel Sharing and 
Improvements to VHF,  ET Docket No. 10-xx, Notice of Proposed Rulemaking.
I approach today’s Notice with cautious optimism as we begin to contemplate spectrum 
innovation and how to make the best use of the spectrum we have. I agree that we need to act in 
a forward-looking manner to realize the tremendous promise of wireless broadband. There are a 
number of ways to help accomplish this, but we are going to be called upon to think really 
creatively—and outside the proverbial box—in order to make it a success. I think of this item as 
contingency planning for the better allocation of spectrum, and that applies to the concept of 
channel sharing.  We don’t yet know whether legislative action or economic conditions will allow 
for implementation of the full range of spectrum recommendations put forth in the National 
Broadband Plan, but we do know that we need to be smarter about spectrum utilization and that 
we need to maximize spectrum performance so that it may better serve the many communications 
needs of the American people.
I am, of course, mightily interested in the future of broadcasting. At the outset, I 
commend the Notice’s recognition of the public value that free-to-all, over-the-air television can 
bring to American citizens. Many broadcasters have worked hard to turn this value into reality. I 
believe in the power of broadcasting and the potential for broadcasters to not only survive, but to 
thrive, if they will but recognize their strengths and the advantages that localism and the public-
spirited administration of the airwaves bring to them. It’s an advantage that not all—in fact, not 
nearly enough—broadcasters have pursued. It is no secret that I have been disappointed that so 
much of the spectrum dividend that accrued to broadcasters as a result of the DTV transition goes 
dramatically under-utilized. I am not interested in pushing broadcasters somewhere else or in 
discouraging their enhanced public interest stewardship of the airwaves. But public interest 
multi-casting remains, all too often, a concept—not a reality. I speak only for myself in saying 
that had this spectrum been put to such positive use, I would have little interest in contemplating 
other uses of it. But here we are, trying to divine how scarce and sometimes under-utilized 
spectrum can best serve consumers and citizens. Between now and such time as channel sharing 
and incentive auctions and all the rest come our way, maybe more broadcasters will come to see 
the wisdom of harvesting greater public benefits from the spectrum they are licensed to use.
One of the greatest challenges facing us, as we work to identify spectrum for wireless 
broadband and other uses, is to make sure that we have a comprehensive understanding of the 
current spectrum landscape. Surely our future success will depend not only on an understanding 
of our current spectrum allocations and assignments, but also on its actual use. That’s why I am 
so glad that we continue to make progress on our Spectrum Dashboard—which will require 
ongoing commitment and resources to achieve its full potential. I know from my experience 
during the Digital TV transition that major changes in spectrum use can raise many issues, some 
unforeseen, and require concerted outreach to, and work with, consumers and industry.
Consumers generally don’t concern themselves much about the arcane details of spectrum 
allocation, nor should they have to, but they do rightly care that when they turn on a TV or make 
a call on a smart-phone, it works. And so we must begin a balancing act, weighing the needs and 
requirements of today and tomorrow.
I am pleased that we ask some difficult questions in this Notice. We need to understand 
the regulatory framework under which channel sharing would be allowed, the technical 
implications for broadcasters and viewers, and how any changes would affect over-the-air 
broadcasting. We also examine ways to improve TV reception in the VHF spectrum. This latter 
won’t be easy, believe me—we looked everywhere we could during the DTV transition, and real 
remedies were few and far between. Let’s hope the months ahead lead us to some genuine 
innovation.
We do seem to have a consensus that some considerable new amount of spectrum will be 
required in the wireless world.  Without additional spectrum, wireless consumers could face 
degraded service and/or higher prices. This concerns me.  But it also concerns me that—without 
other safeguards—auctioning off massive amounts of spectrum to incumbent wireless providers 
may not necessarily result in more consumer-friendly pricing and service. Additional spectrum 
is, to be sure, an important part of the wireless solution. The whole solution it isn’t. I suppose 
that’s the difference between physical spectrum and spectrum policy.
So, this is a good and necessary item. We are teeing up questions that need to be 
answered, and if there are questions we don’t ask, I hope commenters will answer them anyhow.  
We’ll all pay attention! Thank you to Julie Knapp and the team at the Office of Engineering and 
Technology for the thorough job they did on a very complicated item. Their work continues to 
amaze me.