Broadcaster stepped up their opposition to the idea of reallocating TV spectrum for wireless broadband use in comments filed today at the FCC.

They said the FCC should ignore the proposals by the wireless telephone industry and others suggesting that the best way to achieve a "world-class broadband ecosystem," is to curtail or eliminate consumer access to a "free and robust over-the-air digital television service."

The broadcasters also argued that digital broadcasting is an efficient use of spectrum and that "significant swaths of the spectrum already available for wireless use remains underutilized."

The National Association of Broadcasters  and the Association for Maximum Service Television (MSTV) filed joint comments in the FCC's  proceeding aimed at making  broadband access more affordable and accessible.

NAB and MSTV are responding to earlier comments filed by CTIA, T-Mobile and a study submitted by the Consumer Electronics Association calling  on the commission to consider reallocating  the 300 Mhz of TV broadcast spectrum to wireless broadband.

Broadcasters have been on the defensive, especially since FCC broadband czar Blair Levin last month floated the idea of broadcasters relinquishing most of their spectrum to meet the nation's urgent need for spectrum.

Levin even suggested broadcasters who return their spectrum might receives a share of any revenues from the auction of their spectrum to the wireless industry.

But the NAB and MSTV are not interested.

The broadcaster comments suggested the FCC not take a "Wall Street-centric approach to spectrum management."

The "cold financial calculations" of the market valuation of spectrum ignore the core public interest goals that broadcasting serves.

"These public interest goals include the advancement of local journalism, universal service, diversity, local economic activity, the widespread availability of children's and other educational programming, the timely and reliable provision of emergency information, and competition in the areas of pay-TV and mobile video services. These are important public goods and positive externalities which cannot be easily measured or factored into a purely economic analysis," wrote NAB and MSTV.

The broadcasters also said the CTIA proposal fails to recognize the number of households with second and third television sets that are not hooked up to a pay service and rely solely on broadcast television for life-saving information.

And, they insist that the growth of mobile DTV will result in the effiecint delivery of video programming to a mass audience through a variety of mobile wireless devices.

"Therefore, broadcasting in coming years will serve as an important means to offload traffic from broadband networks and to ease network congestion," wrote NAB and MSTV.

NAB's full comments are available in PDF format here.