5GBC Responds to FCC's HC2 Petition for Comment
In Re: Petition for Rulemaking
Filed by HC2 Broadcasting Holdings To Allow LPTV to Use 5G Broadcast Standard
MB Docket 25-168
DA 25-382
COMMENTS OF
5G Broadcast Collective
The 5G Broadcast Collective, an international non-profit organization dedicated to promoting and deploying 5G broadcasting worldwide, submits these comments in response to the Federal Communications Commission’s (FCC) Public Notice seeking comment on the Petition for Rulemaking filed by HC2 Broadcasting Holdings, Inc. (HC2) on March 28, 2025. The Petition requests that the FCC amend Part 74 of its rules to permit low-power television (LPTV) stations to voluntarily adopt the 5G Broadcast transmission standard as an alternative to the currently authorized ATSC 1.0 and ATSC 3.0 standards. The 5G Broadcast Collective strongly supports HC2’s Petition, as it represents a forward-thinking opportunity to enhance spectrum efficiency, deliver innovative services to the public, and provide a sustainable path for the LPTV industry.
1. Public Interest Benefits of 5G Broadcast for LPTV Stations
The adoption of 5G Broadcast for LPTV stations aligns with the FCC’s mission to promote the public interest by expanding access to innovative communication services. The 3rd Generation Partnership Project (3GPP)-approved 5G Broadcast standard enables LPTV stations to deliver high-quality video, datacasting, and emergency alerts directly to 5G-compatible mobile devices without congesting cellular networks. This one-to-many transmission model is particularly valuable in scenarios such as live event streaming, emergency communications, and datacasting for software updates or traffic information.
For example, HC2’s petition highlights the potential for 5G Broadcast to deliver high-definition content at stadium events without overloading nearby cell towers and providing local emergency alerts. This capability enhances the viewer experience and ensures reliable access to critical information during high-demand situations. Additionally, the successful experimental deployment of 5G Broadcast by Milachi Media’s WWOO-LD in Boston demonstrated the delivery of a streaming channel and emergency alerts to smartphones within 0.5 seconds, showcasing the technology’s reliability and immediacy.
2. Technical Feasibility and Compatibility with Existing Infrastructure
The 5G Broadcast standard is technically feasible for LPTV stations, requiring minimal changes to existing infrastructure at reasonable cost. As noted in HC2’s petition, broadcasters can implement 5G Broadcast by replacing their current exciter with a 5G Broadcast exciter, modulator, and core software, without impacting transmitters or antennas. This cost-effective approach makes the technology accessible to LPTV stations, which often operate as small businesses with limited budgets.
Moreover, 5G Broadcast leverages existing mobile communications technology, ensuring compatibility with 5G-enabled devices equipped with Qualcomm chips and appropriate antennas. HC2’s testing of WODP-LD in Fort Wayne, Indiana, demonstrated strong signal reception up to 20 miles from the transmission site and stable performance at highway speeds, underscoring the robustness of the technology. The 3GPP’s designation of the UHF spectrum band (470 MHz–608 MHz) as Band 112 (effective Release 19) for 5G terrestrial broadcast further ensures that LPTV stations can deploy the standard within their allocated spectrum.
3. Economic and Competitive Benefits for the LPTV Industry
The LPTV sector faces significant challenges in transitioning to ATSC 3.0. Many LPTV stations continue to operate in ATSC 1.0, limiting their ability to compete in a rapidly evolving media landscape. Allowing voluntary adoption of 5G Broadcast provides a lifeline for these stations by enabling them to deliver innovative services such as direct-to-mobile video, datacasting, and enhanced emergency alerting.
By repurposing spectrum for ancillary services, LPTV stations can generate new revenue streams, subject to the FCC’s existing 5% fee on gross revenues from such services. This flexibility supports the financial viability of LPTV stations while maintaining their role as a testbed for broadcast innovation. The 5G Broadcast Collective believes that this proposal will foster competition and encourage investment in the LPTV sector without imposing mandates on broadcasters or device manufacturers.
4. Flexibility in Free-to-Air Requirements
The 5G Broadcast Collective cautiously supports HC2’s request for the FCC to seek comment on whether LPTV stations should be permitted to devote their entire 6 MHz spectrum to datacasting, potentially eliminating the requirement to provide one free-to-air standard-definition signal. Given the widespread adoption of 5G-capable devices, this change would maximize spectrum efficiency and allow LPTV stations to fully embrace datacasting opportunities. However, we also recognize the importance of maintaining public access to broadcast services and support a balanced approach that preserves an unencrypted SD signal unless the FCC determines that such a requirement is no longer necessary.
5. No Adverse Impact on ATSC 3.0 or Full-Power Stations
HC2’s petition is limited to LPTV stations, ensuring no disruption to the ongoing rollout of ATSC 3.0 by full-power stations. The proposal explicitly excludes LPTV stations with must-carry status to avoid imposing new burdens on cable systems. This targeted approach allows LPTV stations to serve as a testing ground for 5G Broadcast while preserving the existing framework for full-power broadcasters. The 5G Broadcast Collective believes that this flexibility will encourage innovation without undermining the broader broadcast ecosystem.
6. Conclusion
The 5G Broadcast Collective urges the FCC to grant HC2’s Petition for Rulemaking and initiate a proceeding to amend Part 74 to allow LPTV stations to voluntarily adopt the 5G Broadcast standard. This proposal will enhance spectrum efficiency, deliver innovative services to the public, and provide economic opportunities for the LPTV industry. By supporting 5G Broadcast, the FCC can position LPTV stations at the forefront of direct-to-mobile video delivery and datacasting, ensuring that they remain relevant in a mobile-first world.
Respectfully submitted,
5G BROADCAST COLLECTIVE
Date: May 29, 202