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If public response is a metric, the digital transition remains a long, hard slog.
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If public response is a metric, the digital transition remains a long, hard slog.

The National Telecommunications and Information Administration, the agency in charge of the federal government's plan to distribute coupons for digital-to-analog converters, received nearly 100 comments on its proposed implementation. The comment period ran from July, when the NTIA issued its Notice of Proposed Rulemaking on the plan, through the end of September. Responses ranged from confusion to objection.

Richard Dabney and Scott Donaldson said converters should be free, since the digital transition wasn't the public's idea. D. Spencer Pope and Charles Soper thought the whole coupon scheme was wasteful.

"Last time I checked," Soper's filing said, "you could run down to your local Worst Buy and get a digital TV for less than $300," he wrote. "I have to personally think that if you can't afford even a modest digital TV, that maybe you shouldn't be spending so much time in front of an analog TV."

Robert Ferguson asked the NTIA to "please send a coupon for HDTV conversion to Robert Ferguson" in Illinois, and Sophie Manion requested the "necessary form for the converter boxes for HDTV use."

The boxes are designed to convert digital broadcast signals-hi-def and otherwise-to an analog format, so TVs will continue working after Feb. 17, 2009, when broadcast signals become all digital.

When Congress established that 2009 deadline last year in the Deficit Reduction Act, it directed the NTIA to develop a program for distributing $40 coupons for converter boxes. The law lays out basic parameters: The application period is Jan. 1, 2008 through March 31, 2009. Coupons are limited to two per household. They are to be distributed via U.S. mail, and all coupons must expire three months after issuance. Congress also ruled that coupons apply only to standalone devices that allow analog TVs to display digital signals. A total of $1.5 billion was designated for the effort, including $160 million for administrative costs.

The NTIA was left with figuring out details, including how to determine eligibility. The funding is enough to supply two coupons to around 16.8 million households-roughly the number of American households that rely exclusively on over-the-air TV. The NTIA proposed coupons be available only to those households.

The agency was summarily challenged by the Consumer Union, which said the NTIA didn't have the statutory authority to restrict eligibility. The NAB, Consumer Electronics Association, Association for Maximum Service Television and Association for Public TV Stations also opposed eligibility restrictions.

"The goal of the program is to ensure continuity of service for any unconnected television set, including those that may be in cable or satellite households," the APTS wrote.

Another proposed eligibility criteria was a means test. The NTIA asked if it should distribute coupons only to households with annual income of less than $19,806, the poverty level for a family of four. The TV lobbies once again opposed. In a joint filing, the NAB, MSTV and the CEA said income restrictions would drive people to subscription services.

Two more filers, Garden City Group, a rebate firm in Weston, Fla., and concessions giant Sodexho suggested a means test would cost more than it was worth.

"NTIA should not spend $50 to give away $40 in coupons," GCG wrote.

The NTIA's main impetus for suggesting eligibility limitations was concern about not meeting demand. Solix Inc., a Whippany, N.J. firm that administers public funds, told the NTIA to consider establishing an eligibility threshold after a three-month application period. In doing so, the agency would at least have a clue if demand exceeded the slush fund.


A major concern for the broadcast interests is how well the boxes work. The NTIA proposed using ATSC A/74 Recommended Practice on Receiver Performance. Several filers beseeched the NTIA to go further, including the TV lobby alliance.

"It has... been more than two years since A/74 was published by ATSC," the NAB/CEA/MSTV filing read. "During that period, significant progress has been made... the state-of-the-art has moved forward significantly in some important receiver performance areas."

The group offered specific performance criteria, including improvements on multipath, range of equalizer and signal overload performance.

The media professional division of the AFL-CIO advocated for the performance requirements outlined by NAB/CEA/MSTV, and even the New America Foundation weighed in. The NAF has been clamoring to open taboo TV channels for unlicensed devices, claiming such devices would not interfere with TV signals. The DC think tank asked the NTIA to establish converter specs that would reject interference from unlicensed devices.

Many other parties implored the NTIA to allow electronic program guide, PSIP and smart antenna capabilities. At least one company, DTV chip maker Zoran of Haifa, Israel, said the box should have only basic functionality due to "cost sensitivity." Additional features like an EPG incur royalty fees, the company said.

Other proposed features included downloadable upgrades, NTSC pass-through and power consumption standards. The National Translator Association asked for analog pass-through, since translators are not under the same 2009 deadline as full-power TV stations. The Community Broadcasters Association of Marietta, Ga., made a similar plea, along with Island Broadcasting Co. of Roslyn, N.Y., licensee of five low-power TV stations. LPTVs, like translators, are not subject to the 2009 deadline.

UpdateLogic, the Southborough, Mass. firm that makes ATSC-transmittable software, said the converters ought to be compatible with their technology. PBS subsidiary National Datacast supported downloadable upgrades, as did the NAF.

The Environmental Protection Agency, which is establishing Energy Star requirements for converters, favored an automatic power-down feature. San Jose, Calif. firm Power Integrations offered up a branded algorithm that it says would achieve a highly efficient 740 mW standby mode.


Much of the NTIA's proposal focused on the coupons themselves, and how to prevent fraud. Mindful of the debacle that was the federal response to Hurricane Katrina, one NTIA official said, "we don't want anyone telling us we did a heckuva job."

Several filings addressed whether the coupons should be paper or plastic.

Sodexho recommended using paper with bar codes, holograms, serial numbers, thermo-reactive inks or some other counterfoil. It said there would be no way to tie the product to an electronic coupon card.

Sodexho also said counterfeit fraud was unlikely given the modest value of the coupons. During the three decades that food stamps were paper, Sodexo said counterfeiting was "never a problem" because the coupon denominations didn't exceed $10.

Radio Shack advocated the use of electronic coupon cards, which the food stamp program now uses.

The Garden City Group said paper may be cheaper initially, but it's more likely to get lost or destroyed than plastic, which people tend to value more.

Best Buy favors cards, but it noted that its electronic processing systems currently aren't able to limit them to one purchase. Best Buy said it would require "significant upfront costs" for participating retailers to implement a single-purchase coupon card program, and it asked the NTIA to pay for those necessary upgrades.

The retailer also asked that NTIA not require participating stores to upgrade between October and January, when they're swamped for the holidays.

A final rulemaking is expected before the end of the year.