The Office of Advocacy of the US Small Business Administration met with FCC officials and urged that the Commission not only address the concerns of the LPTV community, but also that it protect LPTV service.
SBAOA said that its job under the Regulatory Flexibility Act was to assure that endeavors such as the incentive auction do not squash the rights of small businesses.
The agency said that it has heard the concerns of the LPTV community, and that its concerns are valid, and further, that its underserved audience needs protection as well.
SBAOA detailed the value of LPTV: “LPTV presents a less expensive and very flexible way of delivering programming tailored to the interests of viewers in small localized areas, providing a means of local self-expression. In addition, LPTV has created abundant opportunities for new entry into television broadcasting and has permitted fuller use of the broadcast spectrum.
Advocacy has heard from stakeholders that that LPTV stations provide content that may simply be unaffordable and thus unavailable without LPTV broadcasting. These stakeholders have stressed that broadcast television is unique in its ability to reach everyone, especially underserved and minority communities that lack access to broadband. Furthermore, these stakeholders explained to Advocacy that broadband is not a perfect substitute for the content that LPTV stations provide; while it is easy to create and post content online, it is much harder to reach underserved communities with it, and niche content creators lack the same financial incentives and opportunities to provide that content on the internet.”
It noted that:
* the FCC has an obligation to preserve localism and diversity and has failed to assure LPTV stations providing these things of their post-auction existence.
* although it is generally in favor of spectrum for unlicensed devices, it should not be at the expense of LPTV service;
* the investments of LPTV licensees in their business must be protected;
* vacant channels should be made available for displaced LPTVs;
* channel sharing should be optional;
* coverage areas should be maintained.
