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SOMEWHERE OUT THEREYou might not have noticed that advertising and education are two different fields. But, even if you don't care about either, stick around a wee mite longer. I promise to reveal by the end of this month's rant the answer to that most burning of questions: Is HDTV really necessary?

First allow me to delve briefly into today's oxymoron: commercial education. I pity the person who relied on TV ads to learn grammar ("Winston tastes good like a cigarette should"), biology ("This nasograph shows no air passing through victim's left nostril"), or sociology ("Ring around the collar!"). And it ain't just television.

Open your newspaper to the section that carries ads for things that get reviewed – movies, books, TV shows, and other stuff like that there. Notice all the dots?

"...amazing..." - The Washingtoon Tribune. The original might have been "It's amazing to think that anyone would pay money for this crap."

"...magnificent..." - The Quint-Cities Citizen. Mayhap the critic wrote, "A magnificent idea would be to stay home instead and stare at the wallpaper."

" I've ever seen..." - ABS-TV. Perchance it was "This is so far from the best I've ever seen that I needed an interstellar spacecraft to get back even to 'garbage.'"


Well, that's ads, wherein I refer to the three consecutive periods as the "dot-con." In scholarly discourse, the ellipsis (as those three dots are really known to us cognoscenti) is used to remove material not apposite to the topic at hand. Ergo, if I were to quote from a speech in which someone said, "HDTV, which has been debated for many years and remains a term used by different people to mean different things, is nice to look at," it would be perfectly legit for me to chop that down to "HDTV ... is nice to look at."

So, the question of the month is: Should William Kennard, the Lord Chief High Hoo-Hah of Our Beloved Commish, use the ellipsis more in the nature of a scholar or of an advertising copywriter?

"But, Mario, you promised to answer the question 'Is HDTV really necessary?'" So I did, and so I will, but that's one of the burning questions of the ages, not merely this month's question.

Well, to be honest, the Kennard question ain't exactly this month's question, either. I refer to a letter he sent way back on July 24, not coincidentally the day before the House Telecommunications Subcommittee hearing on HDTV, the one at which broadcasters were told that not airing HDTV would be a "deal-breaker."


The letter was sent to MSTV and the NAB, and it was cautionary. It advised broadcasters not to question 8-VSB too much. Did L.C.H. Hoo-Hah Kennard want to shut down research into modulation methods? Of course not! He indicated that he was all in favor of trials, as long as the outcome was preordained: "I do not oppose efforts to reconfirm that 8-VSB operates as designed to replicate NTSC." English students, please note the use of "reconfirm that" instead of "determine whether."

The letter also cautioned against changing the DTV Table of Allotments and against delaying the DTV transition. And then there was the stuff about HDTV – for instance, this sentence:

"While I have urged broadcasters to develop new business models for digital television, in addition to high-definition television (HDTV) programming, it is wrong to read into my comments that broadcasters should abandon their core business of television."

Hmmm. Gee, you could surely interpret that as a mandate for HDTV, eh? Is there anything else in the letter that might make it clearer? How about this paragraph coming up?

"Congress and the commission gave each broadcaster temporary use of an extra 6 MHz for the DTV transition and intended that stations use this resource principally for television broadcasting. Section 336(b)(2) of the Communications Act, 47 U.S.C. 336(b)(2), directed the Commission to permit flexible use of the digital licenses but to 'limit the broadcasting of ancillary or supplementary services ... so as to avoid derogation of any advanced television services, including high-definition television broadcasts ... .' It is the mandate of Congress and the desire of the American people that the principal service of broadcast television remain the provision of video programming to television viewers. Broadcasters need to plan for the digital transition in accordance with this purpose."


Wow! That sure seems to make it clear! You'd better not do so much datacasting that you can't carry HDTV. It's not just an FCC regulation, it's the law – "the mandate of Congress and the desire of the American people"! Wow!

Well, now, I hate to admit it, but among my many character defects is an inability to let an ellipsis go by without a peek at the missing words – not that I have any mistrust of L.C.H. Hoo-Hah Kennard, of course. So I called up a copy of Section 336(b)(2) of the Communications Act, 47 U.S.C. 336(b)(2) on Ol' Bossie, and I took a look for myself.

The first ellipsis, budding grammarians please note, is used absolutely perfectly. The missing words are "on designated frequencies." They are irrelevant to the discussion, and, therefore, appropriately removed by those three dots. And the four dots at the end?

First, I suppose it's worth noting that an ellipsis doesn't end a sentence; a period does. That's the fourth dot.

"So, Mario, what are the missing words?" What? Oh, yeah.

Prospective advertising copywriters please take note. The missing words are "that the Commission may require using such frequencies."

Let me try to clarify this. L.C.H. Hoo-Hah Kennard tried to paint a word picture wherein Our Beloved Commish was forced by Congress to do something ("the Communications Act ... directed the Commission ... to 'limit the broadcasting of ancillary or supplementary services ... to avoid derogation of ... high-definition television broadcasts ...'") when, in fact, the words omitted from his letter ("... that the Commission may require ...") left it entirely up to Our Beloved Commish! I am not making this up.


So, did the commission require HDTV broadcasts? The answer to this one goes way back into ancient history. A long, long, long time ago, on April 3, 1997, Our Beloved Commish issued its DTV rules. Here is what FCC Report No. MM 97-8 said in the third paragraph on page 2:

"The Commission will not require broadcasters to air 'high-definition' programming or initially to simulcast their analog programming on the digital channel." Whoa! That seems to be something completely different from what L.C.H. Hoo-Hah Kennard implied in his letter.

Now, then, what else was it that he wrote? Oh, yeah, "Congress and the Commission gave each broadcaster temporary use of an extra 6 MHz for the DTV transition and intended that stations use this resource principally for television broadcasting." And he followed that with this: "It is the mandate of Congress and the desire of the American people that the principal service of broadcast television remain the provision of video programming to television viewers."

But we now know that Congress left it up to Our Beloved Commish to decide just what had to be transmitted in the way of video programming. And here's what the rules say, from Title 47 of the U.S. Code of Federal regulations, as amended April 3, 1997, Part 73.624 Digital Television Broadcast Stations, paragraph (a):

"The DTV program service provided pursuant to this paragraph must be at least comparable in resolution to the analog television station programming transmitted to viewers on the analog channel but, subject to paragraph 73.624(f), DTV broadcast stations are not required to simulcast the analog programming." In case you care, paragraph 73.624(f) is about the simulcasting schedule.


If you want to get really weird about it, I can't even find anything in the DTV rules that says you have to transmit any audio (but, if you do, the rules tell you how you have to). But it's pretty clear that there's no requirement for multicasting. There's also no requirement for interactively enhanced programming. There's no requirement for datacasting. And there's no requirement for HDTV.

Congress left it up to Our Beloved Commish, and OBC ruled that all you have to do is be no worse than existing analog transmissions, the best of which could be roughly characterized as a lot less than 3:1:1 in component-digital-speak. So, allocate 4 Mbps for that, and you're being generous; DVDs average 3 Mbps for higher quality.

That leaves you a good 15 Mbps to play with for whatever you want – until such time as Congress decides differently (they have nothing better to do?) or L.C.H. Hoo-Hah Kennard gets three commissioners to change the rules. Given that it took Our Beloved Commish 10 years to come out with the first set of rules and that it has yet to decide whether there should be cable/DTV must carry, I think I can safely answer the burning question of whether HDTV is really necessary.