The National Association of Broadcasters this week told the FCC that satellite broadcasters should be required to carry the standard def and hi-def signals of all local TV stations to ensure that all viewers, including those without HD sets, will be able to access those signals.
NAB’s comments came in response to the commission’s Second Further Notice of Proposed Rulemaking addressing carriage of DTV signals on satellite and cable systems. In the Notice, the FCC asked whether satellite carriers should be required to carry the signals of all local broadcast stations in HD and SD if they carry the signals of any station in both HD and SD so that subscribers without HD-capable equipment will be able to view all stations.
“From the Court’s holdings in SBCA, it is clear that the carry-one, carry-all provisions of Section 338 justify a viewability requirement,” the NAB argued. “Absent such a requirement, independent stations can be discriminated against and will suffer harm. Moreover, at first, the universe of analog television set owners not able to receive some station signals, but ultimately all viewers in a market, will be deprived of the ‘widespread dissemination of information from a multiplicity of sources.’”
NAB points out that analog SD TV channels are carried on DirecTV’s Ku-band satellites using MPEG-2 while HD signals are carried on the satellite operator’s Ka-band satellites using MPEG-4 technology. While MPEG-4 set-top boxes will downconvert the HD signal to SD, the association said that consumers with analog TV sets have received MPEG-2 set-top boxes and would need an additional MPEG-4 box to receive the HD signal. “Accordingly, there are and will be a universe of satellite subscribers with analog sets that will not be able to view some local station signals for want of the appropriate set-top box,” NAB said.
NAB’s comments provide more detail on the legal and technical aspects of the proceeding. DirecTV and Dish Network, as well as at least two TV broadcasters, have filed comments. DirecTV said it “believes that such a dual carriage requirement would impose an inordinate burden on satellite carriers, preempting carriage of other programming and mandating an extremely inefficient use of valuable spectrum resources. The Commission should not adopt such a constitutionally suspect regime.”
View all comments using the FCC ECFS Search for Filed Comments Web page. Enter “00-96” in box 1, Proceeding.
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Doug Lung is one of America's foremost authorities on broadcast RF technology. As vice president of Broadcast Technology for NBCUniversal Local, H. Douglas Lung leads NBC and Telemundo-owned stations’ RF and transmission affairs, including microwave, radars, satellite uplinks, and FCC technical filings. Beginning his career in 1976 at KSCI in Los Angeles, Lung has nearly 50 years of experience in broadcast television engineering. Beginning in 1985, he led the engineering department for what was to become the Telemundo network and station group, assisting in the design, construction and installation of the company’s broadcast and cable facilities. Other projects include work on the launch of Hawaii’s first UHF TV station, the rollout and testing of the ATSC mobile-handheld standard, and software development related to the incentive auction TV spectrum repack.
A longtime columnist for TV Technology, Doug is also a regular contributor to IEEE Broadcast Technology. He is the recipient of the 2023 NAB Television Engineering Award. He also received a Tech Leadership Award from TV Tech publisher Future plc in 2021 and is a member of the IEEE Broadcast Technology Society and the Society of Broadcast Engineers.