It’s a long technical document released as part of a series of measures billed as supporting competition in Canada’s wireless industry, but the Canadian government is laying the groundwork for decisions that could radically alter the future of over-the-air television broadcasting … again.

It’s called “Consultation on Repurposing the 600 MHz Band“, and is a document seeking public comments on joining a U.S. plan to repurpose more television channels for use as commercial wireless frequencies, forcing remaining television stations to be packed into fewer available channels.

Re-allocation could affect as many as 24 channels used for television.

Depending on how the U.S. moves, it could mean as many as half of the remaining channels used for over-the-air television could disappear by 2017.

The U.S. is undergoing a two-step auction process to recapture frequency in the 600 MHz band, which is used by the higher-end television channels (up to channel 51). The first step is an “incentive auction”, in which TV stations using those channels name the price they have to be paid to move off of them and give up the spectrum — a figure that could be millions or even hundreds of millions, depending on the value of that spectrum. Then, based on how many stations participate, the government re-allocates the frequencies and auctions them off to wireless companies.

Industry Canada is basically proposing that Canada join that process, though the details are unclear.

What we do know is that if the maximum re-allocation plan is used, all TV channels above 26 would disappear, and stations on those channels, whether they’re full-power stations or low-power ones, would have to move off of them as new licensees begin deploying their networks. (Channel 37 is reserved for radio astronomy, and would remain so under the new plan.)

Canada and the U.S. went through a similar process a few years ago, reallocating channels 52-69 for mobile use (the 700 MHz spectrum) during the digital television transition. The subsequent auction gave Canada more than $5 billion in revenue.

Industry Canada points out that the number of television transmitters in Canada has been stable over the past few years. With over-the-air stations relying on advertising alone for revenue, there has been little growth there. Instead, anyone with a new idea has been pushing subscription cable channels instead.

Coordination issues

But squeezing existing stations into a smaller space will still present significant coordination problems. Stations on channels 27 and above would need to be moved over, and that would mean packing stations in tighter than was proposed in the DTV transition plan. Industry Canada has proposed basing coordination on existing transmission parameters instead of maximum parameters to help that a bit, which would mean stations that aren’t taking full advantage of the coverage of their class might lose the chance to expand later.

The ministry predicts most stations — even those not currently using those higher channels — would need to change frequency as a result of this new plan, though it predicts most stations would at least be able to stay in the same range of frequencies, and use the same antennas they do now.

In Montreal, for example, Canal Savoir (CFTU-DT 29), V (CFJP-DT 35), ICI (CFHD-DT 47) and City (CJNT-DT 49) might need to change channels under a new plan. And while there are channels available (Montreal has 10 over-the-air stations), it might mean being on the same channel as a station in a nearby market like Trois-Rivières, Sherbrooke or Burlington. Over-the-air TV viewers who count on receiving U.S. stations would probably find it very difficult as they too would have to move to lower channels and either be on the same channel or immediately adjacent to a Montreal station.

Industry Canada says it would coordinate with the U.S. to make avoiding interference problems easier.

Low-power stations, and stations in remote communities, who were largely exempt from the DTV transition rules, could also be forced to change channels and/or replace their analog transmitters with digital ones. Industry Canada says there are 551 low-power stations in Canada. Most of them wouldn’t need to change channel.

Moratorium

In light of this, Industry Canada has imposed a moratorium on all new television transmitter applications and applications to modify existing stations so that they increase their coverage or change their channel.

An appendix lists only 11 applications for full-power stations and six for low-power stations that were in progress in October. Most of those are related to a promise Shaw made when it purchased Global TV to convert all its transmitters to digital by 2015 (and Global BC has a lot of transmitters to convert).

The fact that such a moratorium could be imposed without causing much disruption should say a lot about the future of over-the-air television. This policy change would make it much more difficult to start new stations, particularly in large markets. But as we’ve seen, there’s very little demand for that.

Industry Canada is accepting comments on the proposal until Jan. 26. People interested in making them can follow the procedure outlined on this page. All comments form part of the public record.

UPDATE (Jan. 15): If you have complaints, comments or other information you want to offer to Industry Canada on this subject, the department has asked that you email spectrum.auctions@ic.gc.ca.