The European Broadcasting Union believes the auction of spare radio spectrum will reduce original TV programming, and damage society as a whole, without even providing the expected boost to rural broadband.
The report (pdf) argues that digital terrestrial TV should receive special treatment as broadcasters can't make money from the frequencies as easily as, say, mobile phone operators, but that the €19bn they invest in original programming each year is of value to society as a whole, and won't be sustainable if they're required to compete in an open market.
We've heard this argument before: London's theatre crowd lobbied to get some spectrum reserved for PMSE (Programme Making & Special Events) use on the grounds of their contribution to society, though all they eventually managed was a stay of execution. The report points out that the loss of PMSE will be another blow to broadcasters wanting to make TV programmes as "...the limited economic viability of PMSE services means that any exposure to market forces for spectrum allocation may make such services unviable for users such as TV production companies and theatres."
If broadcasters are required to spend their money on spectrum then there'll be less original programming, leading to a less well-educated population and the general collapse of society as we know it.
"...television services are possibly the most important instrument for delivering public service through the promotion of cultural understanding." explains the report "By contrast, alternative uses of UHF spectrum, such as mobile telephony, are likely to make little impact in this area."
Mobile operators can realise the value of their spectrum directly, by charging punters to use it, while "TVs and radios will never be able to compete with mobile operators; they cannot offer billions like mobile operators can", Philip Laven, adviser on spectrum policy issues for EBU, told the Policy Tracker web site.
The argument that releasing all this spectrum will create a new broadband infrastructure is also attacked in the report, which calls this the "Mobile Myth" and explains that operators already have unused spectrum, and are about to get another chunk at 2.6GHz which will have much greater capacity than down in the UHF spectrum where broadcast TV lurks.
Wireless broadband is more restricted by roll-out plans than any shortage of spectrum, deploying broadband at UHF frequencies (the 400 - 800 MHz band) would be cheap as fewer base stations would be required, but the report agues that at such low frequencies it would be impossible to provide true broadband speeds (defined as >2Mb/sec) to more than few customers.
The EU has a plan to divide up the digital dividend into terrestrial TV, mobile TV and other services, which would reserve some bandwidth for terrestrial but would also see a chunk of spectrum allocated to mobile TV that no-one seems to be interested in watching.
Ofcom, meanwhile, would like to see the whole electromagnetic spectrum opened up to the highest bidder, on the basis that he who is prepared to pay most will make most efficient use of the bandwidth. But when the value is to society as a whole, rather than just money, then the calculation gets more complicated.