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Sinclair gains support in fight for minimum DTV tuner requirements

San Francisco, Calif.-based engineering firm Hammett & Edison (H&E) has joined with the Sinclair Broadcast Group in its fight to win government-defined digital television tuner requirements that ensure reliable over-the-air reception of broadcasters' digital signals. Thus far the commission has not been receptive and, although a spokesman declined to comment, does not appear to be ready to act on the issue anytime soon.

Citing the lack of reception capability in much early-generation consumer equipment, last fall Sinclair filed comments with the FCC requesting the agency to mandate that electronics manufacturers include the improved circuitry necessary to achieve reliable reception of over-the-air DT signals. In an effort to save money, CE companies have resisted the request.

After conducting a series of reception field tests in January 2002 in San Francisco, Calif., and the northern San Francisco peninsula, H&E senior engineer Dane Ericksen said his company provided the Commission with a comprehensive engineering report last week, in support of the Sinclair Petition for Partial Reconsideration of the August 9, 2002, Second R&O and Second MO&O to MM Docket 00-39.

In that August ruling the FCC decided that beginning in 2004, large-screen TVs sold or imported into the U.S. must include a DTV tuner capable of receiving an over-the-air 8-VSB signal. This phased-in requirement will apply to TVs as small as 13 inches by 2007. However, the FCC declined to adopt any minimum performance requirements for the DTV tuner.

Thus, in November 2002, Sinclair filed a petition for partial reconsideration, asking the FCC to adopt minimum DTV tuner standards. The filing cites the All Channel Receiver Act (ACRA), which grants the Commission the authority to require TV receivers to be "capable of adequately receiving" all TV channels. Sinclair said in its communications with the FCC that relying on the marketplace to ensure that DTV tuners provide adequate over-the-air reception would "jeopardize the digital transition and the future of free, over-the-air DTV."

The petition, which was signed by independent broadcasters such as Pappas Broadcasting at the time, also stated that "If the Commission does not act to protect the interests of those millions of viewers who cannot afford or simply do not wish to subscribe to cable or satellite, it is risking the disenfranchisement of a large segment of the American population."

Ericksen said H&E agreed with the Sinclair petition, but found it in need of additional engineering documentation to make its case. Last week H&E filed its comments in support of the Sinclair petition, attaching engineering documentation of recent measurements showing that Sinclair was correct in its claim that minimum performance standards for DTV tuners are needed.

Ericksen explained that H&E has no affiliation with Sinclair, although they have provided engineering services to some Sinclair stations.

Ericksen said H&E first filed electronically using the FCC's Electronic Comment Filing System (ECFS) on January 16, 2003, then sent a copy to numerous people within the industry, including Sinclair executives Nat Ostroff and Mark Aitken.

"Sinclair did not see a copy of our comments prior to its filing, nor do I believe that they were even aware we were planning to file," he said.

Sinclair's Ostroff called H&E's filing "a pleasant surprise."

The field measurements were made in northern California using a measurement van equipped with custom monitoring gear. Ericksen said his company found adequate DTV signal strength at two locations, but that a consumer-grade DTV receiver would not achieve signal lock on the measured DTV channel at some points, even though there was ample signal strength. He said H&E has determined that an improved DTV tuner could solve all of the observed interference problems.

"Our comments document that we were not able to achieve [channel] lock, due to brute force overload from FM stations and also from KQED-TV (NTSC Channel 9) three channels removed," he said. "We also documented an apparent case of image interference between KTVU-DT, [channel 56], transmitting from the Sutro Tower in San Francisco, and KKPX-DT [channel 41], transmitting from San Bruno Mountain, at Millbrae, Calif., on the San Francisco peninsula."

Ericksen said H&E's motives are designed to help move the DTV transition along by ensuring that consumers will be able to receive broadcasters' digital signals with an outdoor antenna. "Hammett & Edison took the time and effort to prepare and file these comments, which were not paid for by any client, because we think the DTV rollout will be affected if the current situation is not resolved," he said. "We cannot think of a worse ‘poison pill’ to the success of DTV than to allow bare-bones, marginally performing DTV tuners to be marketed; ones that only work in benign RF environments uncharacteristic of over-the-air, free TV signals."

Across the country the situation is not helped by the fact that many stations now on-the-air in digital are doing so at reduced power levels, which require the digital tuner to work harder. The option for temporary reduced DTV ERP levels does not apply to the top four networks in the top 30 DMAs, however, which includes San Francisco, so neither KNTV-DT, KTVU-DT nor KKPX-DT--all stations addressed in the H&E filing--were operating at reduced power.

"Because the FCC created a DTV table of allotments that only protects against co-channel and first-adjacent channel interference," he continued, "but not against intermodulation products and image interference, the RF environment that a DTV tuner must face is far more challenging than that required for an NTSC tuner."

"We think the Sinclair petition for partial reconsideration was right on the money and we applaud their initiative in making such a filing," Ericksen said.

Ericksen said H&E hopes that its filing in support of the Sinclair petition will cause other parties to file their own comments, with the goal being an Order on Reconsideration and Further Notice of Proposed Rulemaking, proposing minimum standards for DTV tuners.

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