D-to-A Converter Comments Trickle In

Less than a month remains to comment on the government's game plan for subsidizing the gizmos intended to quell a riot come Feb. 17, 2009.

The deadline for filing comments on the Notice of Proposed Rulemaking about subsidy coupons for the digital-to-analog converter is Sept. 25. The devices are intended to keep millions of existing TV sets from becoming landfill once analog TV transmitters are shut down two-and-a-half years from now. Earlier this year, Congress designated up to $1.5 billion for the subsidy program and told the National Telecommunication and Information Administration to go out and git 'er done.

The proposed rulemaking, issued by the NTIA in July, seeks feedback on who should get a converter coupon, how they should get it, and what should determine if a converter qualifies for the subsidy.

Thus far, a grand total of two comments have reached the light of day on the NTIA Web site.

The first hand in the air belonged to a senior scientist with the Natural Resources Defense Council. Noah Horowitz wrote urging the NTIA to impose energy standards on converters.

"We think it would be ill-advised for the government to spend more than a billion dollars in taxpayer money to offer a D-to-A consumer rebate program that does not include minimum energy efficiency requirements," Horowitz wrote.

Just how much power converters will consume remains a matter of debate, since they're still in the prototype phase, and the full feature set is yet to be determined. Congress mandated that only a basic converter, with an optional remote control, would be subsidized. However, that doesn't preclude the NTIA from authorizing closed-captioning, PSIP, EAS capabilities and performance standards.

The California Energy Commission has proposed setting energy consumption limits on converters at 8 watts powered up and 1 watt in standby. A similar proposal was shot down in the House last year because manufacturers said it was too restrictive.

The NAB and the Consumer Electronics Association objected to the CEC proposal because they said it would boost the cost of the converter. Congress wants devices in the $50 to $60 range, but getting to 1 watt in standby would potentially double that, according to chipmakers. The Environmental Protection Agency is also looking into the matter and is expected to release a draft policy on this month.

Horowitz, writing for the NRDC, proposed imposing a standby energy limit of 1 to 2 watts, in part based on a standard working its way though the CEA (according to the NRDC filing). Horowitz goes on to say qualifying converters should be able to shut themselves off, since most users presumably won't bother.

"Anecdotal evidence based on cable and satellite set-top box viewing habits suggests that the majority of D-to-As may stay in 'on' ode and never enter the much lower power-consuming standby mode," it states. "This is because many users typically do not turn off set-top boxes when they are finished viewing TV."

Assuming that around 30 million converters get plugged in and use a rather hefty 17 watts on/8 standby, the EPA estimates annual power usage of more than 3 billion kilowatt/hours. The NRDC said auto power-down coupled with a little less juice-use could reduce power plant carbon belching by the equivalent of "300,000 cars."

"The key to industry acceptance of this concept is to spell out the specific requirements and leave the industry with the flexibility on how to implement it," the NRDC suggested.

Energy standards weren't a foremost concern for Ralph Mlaska of Laurel, Md. Mlaska was more concerned about the NTIA's proposal to limit the subsidy to households relying exclusively on over-the-air television, and possibly only to those below poverty level.

"The boxes should be provided to all who desire them," Mlaska wrote, "two to a household--unless a family can prove that their income is below $19,806," the poverty level for a family of four. "Then the box should be free."

Mlaska went on to say the proposed three-month lifespan of the coupons was a bit brief. He also said the feature set limitation was unnecessary, and making retailers track coupons was unreasonable.

"It would not be fair to expect the retailer to police the purchasing of converter set-top boxes," Mlaska wrote. "This is a federal responsibility, and cannot be delegated to the seller."

Comments must be submitted to the NTIA by 5 p.m. Eastern Sept. 25. They can be mailed to Milton Brown, Office of the Chief Counsel, National Telecommunications and Information Administration, 1401 Constitution Ave., Room 4713, Washington, D.C. 20230; faxed to 202-501-8013; or e-mailed to coupon@ntia.doc.gov.