Religious broadcasters have asked the Federal Communications Commission not to reallocate any broadcast spectrum for wireless, saying it will disproportionately impact Christian TV broadcasters. Responding to an FCC request for input on how the public’s welfare would be impacted were the commission to “diminish” over-the-air TV coverage in order to recover spectrum, the National Religious Broadcasters told the agency that it thinks that spectrum reassignment might be illegal.

“NRB presumes that the term ‘public welfare,’ includes such things as compliance by the FCC. with existing legal and constitutional standards,” said the group in its filing, “and believes that violation of those standards would be contrary to ‘public welfare.'”

Pointing to the writings of FCC Distinguished Scholar in Residence Stuart Benjamin that spectrum could be reallocated from “lower value” uses like broadcasting to “higher value” uses, NRB says it is afraid it could be relegated to the lower of that low due to its noncommercial model.

Our Christian television broadcasters rely on current ‘must carry’ regulations to gain optimal coverage, and do not, as a general rule, enter into retransmission agreements,” NRB pointed out. “As a result, there is no standard market index for the economic “value” of Christian television programming from a macro-broadcasting viewpoint. Does that mean, therefore, that Christian stations would be more susceptible to being viewed as being of lower ‘value,’ and therefore more likely to lose spectrum?”