REC takes positions on 5G broadcasting by UHF LPTV stations

REC supports the new 5G technology, but not at the expense of essential TV services in rural and underserved areas; and without departing from the traditional role of free-to-air broadcasting.

REC Networks has established various positions and has filed comments with the FCC in response to the Petition for Rulemaking filed by HC2 Broadcasting to permit Low Power TV (LPTV) stations to be able to operate using the 5G Broadcast standard as opposed to the standards currently authorized, including ATSC 1.0 and ATSC 3.0 (also known as “NextGen TV”). The FCC assigned docket number MB 25-168 to the proceeding and put it up on public notice for comments.

About 5G Broadcast and the petitioner, HC2

HC2 Broadcasting is currently the largest owner of LPTV stations in the nation with over 250 stations in 40 states. HC2’s programming mainly consists of smaller networks such as Comet, Cozi, Buzzr and MeTV, as well as shopping channels.

5G Broadcast is a worldwide standard as established and maintained by the Third Generation Partnership Project (3GPP) and the 5G Broadcast Collective. 5G Broadcast uses the same technologies that are used by mobile devices in the mobile spectrum to transfer data. 5G Broadcast utilizes the television spectrum and operates only one way (base to mobile). A station equipped with 5G Broadcast can deliver video and audio programming services as well as one-way point to multipoint datacasting. The 5G Broadcast standard only applies to UHF (Channels 14~36) and there is no standard for VHF spectrum (Channels 2~6, 7~13).

While in the United States, HC2 is hoping to adopt 5G Broadcast for standalone LPTV stations, the European Broadcast Union is studying the technology for nationwide and regional coverage utilizing single frequency networks in television spectrum.

REC positions taken

Overall, REC filed comments with the FCC in general support of the technology concept, but does have concerns that need to be addressed first, including the outcome of experiments that HC2 is currently conducting in Fort Wayne, IN. Overall, REC recommends that 5G Broadcast first go to a Notice of Inquiry prior to going to a Notice of Proposed Rulemaking.

The definition of “broadcasting”

The Commission has previously interpreted the Communications Act to define broadcasting that is receivable on a conventional receiving device, does not require a program provider specific antenna or converted box, can be encrypted in a way that makes the signal usable by the public and where there is no contractual relationship between the programmer and the viewer.

While HC2 recognized that in order for a station to be considered as “broadcasting”, it must provide at least one free-to-air service; they have alternatively suggested that LPTV stations should be permitted to use their entire 6 MHz TV channel for subscription 5G services and not provide any free-to-air services.

It is REC’s position that spectrum belongs to the citizens and they have the right to access it (whether for transmitting or receiving). The past precedence that the FCC has taken on this subject makes it clear that if a LPTV station wishes to operate 5G Broadcast, they must continue to provide at least one standard definition free to air video program service.

Methods to receive free-to-air broadcasts

While it may be some time before a 5G TV receiver may be available, the ability to receive 5G broadcasts would be more likely on mobile devices using installed apps. REC’s position is that those apps must remain free to download and should not convey any one time or “subscription” fee for the app, especially one provided by the programmer.

Consumer privacy

As FCC licensed broadcast stations that are received using non-traditional methods (mobile apps), there may be concerns in regards to privacy, information collection and dissemination by the broadcaster or a third party provider.

While REC is not proposing any specific privacy practices, it is our position that the Commission must take consumer privacy into consideration in its decision making process for 5G Broadcast.

Preventing the loss of baseline OTA television service in rural and terrain impacted areas

When a LPTV station converts to 5G Broadcast, it would no longer be viewable on existing TV receivers designed for ATSC 1.0. Even ATSC 3.0 receivers, unless they also include specifically include 5G technology, would also not be able to receive the broadcasts.

While full-service and Class A TV stations cover a considerable part of the country with over the air (OTA) television services, there are many areas of the country that are unable to receive these stations, either due to distance or intervening terrain. These areas depend on these LPTV and TV translator stations for emergency alerts and educational programming.

While REC finds value in the 5G Broadcast technology, that technology should not come at the expense of losing essential television services in these underserved areas.

It is REC’s position that before an LPTV station can convert to 5G Broadcast operation, they must include a technical study, utilizing a terrain-based model (not contours), demonstrating that in the entire service area of the 5G LPTV station, that there are at least three full-service and/or Class A TV stations that provide a usable ATSC 1.0 or 3.0 signal. This would prevent the loss of basic essential television services in areas where they are most desperately needed.

Interference to other services

It is REC’s position that during the rulemaking process, there must be additional technical studies performed to assure that the interference potential from 5G Broadcast stations does not exceed those from ATSC 1.0 and ATSC 3.0 broadcast stations. This includes protections to land mobile services operating in major cities in the Channel 14~20 (470~512 MHz) spectrum, adjacent-channel interference by Channel 14 (470~476 MHz) stations to land mobile services in the 460~470 MHz band, as well as cross border interference in Mexico and Canada.

Impacts to FM radio broadcasting

An evaluation of the proposal and the underlying technologies has determined that there are no impacts to FM broadcast stations of any service class. There may be impacts for wireless microphones and white space devices operating in the UHF TV band, but those impacts should be extremely minimal. Since the international 5G Broadcast standard does not specify VHF spectrum, including Channel 6 (82~88 MHz), which must be protected by certain FM broadcast stations; there are no risks of reduced availability to LPFM and FM translator stations proposing operation in the 88~92 MHz reserved band.

REC’s overall position on 5G Broadcast

REC supports the implementation of 5G Broadcast technology as we see it as a cutting edge technology that could give struggling LPTV operators new revenue opportunities through subsidiary and ancillary services that can be provided on the data stream. However, rules need to be put into place to assure that essential ATSC 1.0 and 3.0 television services in underserved areas are not jeopardized, 5G Broadcast stations provide at least one standard-definition free-to-air video programming service, apps to receive 5G Broadcast are made available free to viewers without one time or sustaining payments, consumer privacy is protected and that all interference to other broadcast and non-broadcast facilities are taken into consideration during the rulemaking process. The Commission should first conduct a Notice of Inquiry on the technology as not all testing results are on the record and once there is a sufficient record, the Commission should move forward with a Notice of Proposed Rulemaking.

Comments in MB Docket 25-168 are due on June 2, 2025. Reply comments are due on July 1, 2025.

A copy of REC’s comment filing in this proceeding can be found by clicking here.

Collected technical documents from 3GPP and EBU can be found on our ITU and International Documents page (recnet.com/itu) at the REC website.