The FCC recently released a Notice of Inquiry related to the proper measurement and testing procedures for distant digital television signals. This inquiry was initiated as a result of the passage of the Satellite Home Viewer Extension and Reauthorization Act of 2004.
In particular, the commission wants to determine whether the current signal strength standard and testing procedures remain accurate or whether revisions are necessary. The standards are used to determine if a household is entitled to receive distant network programming from satellite services. The commission seeks comment on the following questions:
- Antenna placement: Should the commission modify the procedures for determining if a digital signal is available to a particular household based on different antenna installations and orientation? In particular, the FCC asks whether a digital signal can be received in light of the various placement locations for receiving antennas and the variety of different receiving antennas available in the marketplace.
- Signal strength measurement: Should the commission revise the measurement procedures for DTV signal strength? The current rules rely on the measurement of the television visual carrier, but the DTV signal does not contain a visual carrier. Therefore, should the measurement of the DTV signal be based on the pilot signal or the center of the DTV channel?
- Signal strength standard: Currently, to determine whether a household is eligible to receive a distant signal, the commission measures the Grade B analog signal at that particular household. Should the commission's use of a particular signal strength at a certain household continue to be used? The FCC is interested in identifying any alternative methods that might better establish whether a household is capable of receiving a high-quality DTV signal.
- Development of predictive model: In developing the DTV Table of Allotments, the commission used the OET 69 predictive method for measuring signal strength. In response to the passage of the Satellite Home Viewer Act of 1999, the commission developed a new predictive model for determining whether a household was eligible to receive a distant signal from a satellite service provider. Is there a different methodology that could be developed to better determine a household's eligibility?
- DTV receiver standards: How does the quality of a consumer's DTV receiver affect its ability to receive a local signal? Should this be a factor in establishing a household's eligibility?
- DTV receiver interference: How should a DTV receiver's ability to sift through interference and find a usable DTV signal be factored into this analysis? More specifically, how should the FCC account for factors such as foliage and man-made sources of interference?
Resolution of these issues will establish the standards that will govern the outcomes of future battles between broadcasters and satellite carriers. But for now, the delivery of distant signals to individual households at the periphery of broadcast station local service areas still remains in conflict.
Harry C. Martin is the immediate-past president of the Federal Communications Bar Association and a member of Fletcher, Heald & Hildreth PLC, Arlington, VA.
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