Whether television broadcast spectrum would be better used for licensed wireless broadband services is the subject of an FCC public notice issued yesterday that seeks input on the subject during the next three weeks.

The public notice is part of the agency’s effort to develop a national broadband plan that must be delivered to Congress by Feb. 17, so comments are due by Dec. 21 and there will be no reply comment period, FCC spokesman Mark Wigfield said. Blair Levin, executive director of the FCC’s broadband task force, has said that all licensee will need to justify their spectrum holdings as the federal government seeks available airwaves to support wireless services, but yesterday’s public notice addresses only spectrum used for over-the-air television broadcasts.

“We’re looking at everything, but this public notice is focused on the broadcast spectrum,” Wigfield said.

Currently, all television stations have 6 MHz of spectrum that can be used to deliver free over-the-air programming within their geographic coverage areas. With more than 80% of the nation’s households subscribing to cable or satellite services, many have questioned whether using hundreds of MHz of spectrum to serve a dwindling population of over-the-air television viewers is the best use of the airwaves.

Yesterday’s public notice was issued less than five months after television broadcasters relinquished 700 MHz spectrum as part of the digital-television transition for channels 52 to 69, most of which the FCC auctioned to commercial operators early in 2008. The idea of repeating the process does not appeal to broadcasters, said Dennis Wharton, executive vice president of the National Association of Broadcasters (NAB).

“I don’t want to sound flip, but we essentially gave at the office,” Wharton said. “For us to now — six months later — be asked to return more spectrum to the government, there seem to be a fundamental question of fairness here. We support broadband deployment, but does it have to be at the expense of the millions of people who rely every day on local TV for news, information, emergency weather alerts and sporting events? We would hope not.”

Just the fact that the FCC is considering the notion of reallocating TV spectrum threatens to “freeze” broadcasters’ future business models that require existing spectrum to deliver full high-definition programming, multicasting and free mobile digital television, Wharton said.

In addition, relocating broadcasters using channels below channel 52 would be much more difficult than the relocation completed this year, because many more stations use those frequencies than used the 700 MHz band, Wharton said.

“It would be a Herculean effort,” he said. “We just went through an incredibly complex transition from analog to digital, which took 10 to 12 years. This would be even more complex, because of the difficulties finding spectrum in urban markets, if you were to preserve the same number of TV stations in all of those markets.”

Wharton also questioned whether commercial wireless operators really need additional spectrum.

“There is a debate whether there truly is a spectrum crisis,” he said. “Some of the FCC folks make that claim. Others say that, with increased compression technology, maybe that’s just not so.”

But CTIA — the trade association representing cellular carriers — asserts that more spectrum is needed quickly. According to a study conducted by the International Telecommunications Union, wireless carriers in the United States need an additional 800 MHz spectrum by 2015 to meet the demand for broadband services, according to Scott Bergmann, CTIA’s assistant vice president for regulatory affairs.

“The other countries that we compete with globally have significantly more spectrum coming online in the pipeline than we do,” Bergmann said during an interview conducted before the public notice was issued. “Knowing what a difficult and involved process it is to bring spectrum to market, we’re really trying to encourage the FCC to kickstart that now. It’s been encouraging that the FCC is focusing on that to keep the ball moving.”

Bergmann said the growth rate for mobile data usage in the United States is exceeding expectations, noting that AT&T Mobility has seen a 5000% increase in its mobile-data traffic during the past year as consumers have flocked to its iPhone device. Such increased data usage cannot be address merely with better compression schemes, he said.

“The growth is so explosive right now that it’s a challenge to figure out what we’re going to need in the future,” Bergmann said.

With this in mind, CTIA has supported legislation requiring a spectrum inventory to identify underutilized spectrum. In addition to TV broadcast spectrum, CTIA advocates the review of spectrum currently licensed to the federal government, fixed-wireless companies and satellite service providers, Bergmann said.

“We know from history that the process to identify spectrum, bring it to market and get it cleared can take anywhere between four to 13 years, depending on what’s involved in the process,” he said. “The key is getting started now and making sure that policy-makers understand that the rate of growth of usage is far outstripping what increases in efficiency with the existing spectrum are going to be able to permit.”