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Commission, not just broadcasters, face obligation under new DTV R&O

The FCC Third Period Review and Report and Order (R&O) on the DTV transition released New Year’s Eve is a sweeping document outlining the deadlines and procedures TV broadcasters must follow in making their final preparations for the shutoff of analog service and commencement of DTV transmission in February 2009.

Few seem better positioned to discuss the inner workings of the document and its impact on broadcasters than David Donovan, president of the Association of Maximum Service Television (MSTV). Since March 2007, the MSTV and Donovan have made a significant effort to assist TV stations to coordinate their analog shutoff, migrate to permanent DTV channel assignments and take their DTV service to full power.

Crisscrossing the country to meet with station engineers, the MSTV has also advanced the cause by encouraging broadcasters to secure the technology and services they need early. HD Technology Update caught up with Donovan last week to discuss whether the R&O will advance the goal of a smooth transition as well as other important issues facing broadcasters during this time of change.

HD Technology Update: What are your overall impressions of the FCC’s latest DTV R&O?

David Donovan: We are examining it in great detail right now. It’s a fairly complicated document.

There are two issues: One, whether the commission provided sufficient flexibility to allow stations to complete the transition, and secondly, whether the processes they’ve adopted will allow this to be done in an expedient fashion. Our fundamental concern, of course, is decisions have to be made in time for stations to purchase equipment. We’ve been working with the commission, and we are going through this report very, very carefully to make sure it will help facilitate the transition.

HD Technology Update: You, and by extension the MSTV, have made a large effort through your DTV Rubber Meets the Road slideshow and tour to coordinate the analog shutoff and DTV service launch. Could you briefly describe the situation you have been working to prevent in terms of interference related to a disorderly transition, and does this R&O take the industry in the direction you’ve been working to go?

David Donovan: There are a couple of key things. First of all, part of this Rubber Meets the Road tour was to make sure stations understood the relationships they have with each other, particularly when stations shift channels. Because of potential interference, these channel shifts have to be coordinated. For example, in order for a station to move to its final DTV channel, it may need another station to vacate its channel. That coordination has to be done, and it has to be done at the local level. We have been pleased with the reception we have received, and I feel fairly confident that the stations have a very good handle on who’s moving where. Certainly that coordination is going on.

Second, stations must not delay in ordering equipment. With time ticking away and essentially a limited number of suppliers, be it tower rigging crews, transmitter manufacturers or antenna manufacturers, they need to order now. Unfortunately, some stations don’t know what to purchase until the FCC rules come out. Accordingly, we have been pushing the commission for quite sometime to get out the third biannual report. Now that it is out, we are examining it closely to make sure stations have the flexibility to complete the transition and that FCC decisions will be made in a timely fashion so stations can go out and purchase whatever additional equipment they need.

HD Technology Update: I know this R&O is more than 150 pages with appendixes and commissioner comments, but I was wondering if you’ve had enough time to get an impression of whether there’s enough flexibility for broadcasters.

David Donovan: I think, as with most commission documents that are rather lengthy, there are some questions. We’re in the process of trying to scope that out. I know the FCC staff worked hard. They worked over the Christmas break to try to get this out by New Year’s. In general, a lot of the relief that is going to be needed will be done through the waiver process.

Waivers always take time, and the question is whether the commission will be able to move forward and accelerate this on an expedited basis.

Two other things are absolutely critical for this transition to happen. There must be coordination between the cable industry and broadcasters. In particular, there needs to be coordination in regards to headends. If cable systems are receiving signals off the air and stations are changing channels, cable systems may have to acquire new receive antennas. That coordination is critically important.

The same thing will have to happen with the satellite industry as well. We have been working with the satellite industry to get steps to make sure that the system works in February 2009.

HD Technology Update: What do regulators and lawmakers need to understand about the simultaneous unfolding of the unlicensed white space device issue and its impact on broadcast television that they don’t get?

David Donovan: I think the key thing they have to understand is that interference in the digital world is far more significant than it was in the analog world. Even the smallest amounts of interference will make a perfect picture pixelate and freeze; therefore, you have to be inordinately careful with any plans to share those frequencies.

As we are rolling out DTV — and even after the transition occurs — the last thing you want after consumers spend billions of dollars on new digital equipment is to suddenly have that equipment not work because you have simultaneously placed new interfering devices in that band. It’s not just getting the word out about the transition date in February 2009, it’s about consumer acceptance of the digital system. That can grind to a halt if suddenly you have interference coming from your next door neighbor’s unlicensed device.

I think you have to connect the dots here. No one has said that post-transition you can’t use broadcast spectrum, particularly in rural areas for additional services. That’s not the debate. The debate isn’t trying to hold onto spectrum and not do anything with it. The debate is what types of services and devices you want to have share that band.

The real problem with an unlicensed device based on sensing is that when the interference occurs, there really is no way to control it and no way to police it.

I think it’s also important to understand that what the FCC has before it right now are not devices for the consumer market.

They are at best-concept pieces and not complete devices. Most are just sensing mechanisms and don’t have a transmit function. These devices will not provide you with sufficient information to craft rules that will avoid interference with TV receivers and wireless microphones. For example, many of the devices sense down to -114dBm. However, the FCC has done no analysis to determine if this is the appropriate sensing level to avoid interference. Rather, the FCC is simply testing what has been submitted to it.

However, there is not evidence in the record that even if the devices work and sense at -114dBm that this level will protect against interference. Moreover, if you will have different propagation scenarios and different terrains, you better field test even the prototypes across the country. It’s not clear at all if the commission intends to do that with its field tests. We have submitted a list of suggestions to the FCC as to how the testing should be conducted. We will see if they adopt some or all of our proposals.

HD Technology Update: It just seems so odd that this issue is coming up now as the DTV transition is in its final stages.

David Donovan: Well, I think what happens is that everyone say, “OK, the digital transition is here. There must be lots of spectrum we can use.” This is not necessarily true. You must remember that channels 52-69 will no longer be used for broadcasting after Feb. 17, 2009. All of the full-power, low-power and translator stations on these channels must be relocated to channels 2-51. Thus, in major markets, there will be very little spectrum for unlicensed devices.

Most importantly, those promoting unlicensed devices believe you can operate these devices on the “first adjacent channel.” The FCC’s own data demonstrate conclusively, however, that operating these devices on the first adjacent channel will cause significant interference. Post-transition, there will be spectrum — particularly in rural areas — that can be used if done right.

For example, Canada is using TV spectrum in rural areas for a licensed, fixed rural broadband service. The irony here is that this debate has been wrapped up in rural broadband discussions. However, Microsoft and the others do not care about rural broadband services. They want to sell all kinds of unlicensed devices in large markets. We have urged the FCC to move forward with fixed rural broadband systems as envisioned by IEEE 802.22. That is not good enough, however, to satisfy Microsoft and the White Space Coalition.

HD Technology Update: Various research organizations have pegged the number of HDTV viewers who receive their programming via over-the-air reception in the single digits — 4 to 6 percent. At the same time, some research shows that as many and 50 percent of the households buying HDTVs don’t receive HD programming. What should broadcasters be doing as the DTV transition occurs to inform this large pool of HDTV owners without HD service that HD programming is available for free over the air?

David Donovan: That is a terrific question. I think it is incumbent upon the broadcast industry to explain the antenna function. With digital, viewers will be able to get not only HD but also multicast offerings for free with just an antenna. Indeed, the quality of broadcast HD is superior to cable and satellite because we are not compressing the signal.

It’s time for the TV industry to trumpet it’s own horn in that regard. We have a terrific wireless product. And when we see statistics about antenna sales starting to peak again, and we see that nearly 1.9 million homes filed for converter boxes from the NTIA, it’s clear there is a vast reservoir of folks who want to remain wireless and use the antenna. It’s up to us to push it, and it’s also up to the retailers to make that an offering when folks go to the store.

Unfortunately, today, you have many retailers that do not adequately explain or even understand the off-air option when people come in to buy a DTV. So, the idea of selling the off-air antenna or even display an antenna so consumers get it is a hard path. I think it’s incumbent for us to do it.

But the numbers that you cited about the number of folks who buy new sets but don’t have HD do not surprise me, and I think that is a market that broadcasters can and should tap.

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