Federal Communications Commission	"FCC  XX-XXX"


STATEMENT OF
COMMISSIONER JESSICA ROSENWORCEL,
APPROVING IN PART, DISSENTING IN PART

Re: 	Rules Governing the Use of Distributed Transmission System Technologies, MB Docket No. 20-74; Authorizing Permissive Use of the “Next Generation” Broadcast Television Standard, GN Docket No. 16-142.

I continue to support moving forward to clarify rules of the road that will enable broadcasters to migrate to the next generation broadcast television standard (ATSC 3.0).  But we need to proceed with caution to avoid potentially harmful effects to other Commission priorities, including our efforts to authorize and encourage other services in the TV Band such as unlicensed white space operations.  For the millions of Americans who live in areas without any form of broadband service, the use of white spaces as a broadband service option is among the most promising.  This Commission has worked long and hard promoting policies to enable the white space community and broadcasters to co-exist in the same spectrum while minimizing the risk of harmful interference from either side.  Today’s decision threatens to disrupt that careful balance by moving too quickly to adopt expanded signal spillover limits for full power television stations before it is known whether they will be compatible with other operations in the TV band.

Although the majority asserts that the revised spillover allowances pose less of an interference risk than what was proposed by Petitioners, several stakeholders believe that any increase in signal spillover allowance, without additional safeguards, will impede the significant progress made to facilitate white spaces and other TV band operations.  I therefore proposed, with support from Commissioner Rosenworcel, a more measured solution that would have streamlined the current approach under which a licensee would need to seek a waiver for signal spillover that exceeds a “minimal amount.”  This proposal would have provided the predictability and flexibility that broadcasters have asked for but it was rejected, which means that licensees will no longer have to demonstrate that DTS operations extending more than a minimal amount beyond their authorized service areas are in the public interest.  For that reason, I dissent in part.  I thank the staff for their work on this technically complex proceeding.
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