[opendtv] Re: Dueling Statutes?
----- Original Message ----- From: "John Willkie" <johnwillkie@xxxxxxxxxxxxx> 



This isn't a case of dueling statutes. The CECB statute didn't require
analog (failure of advocacy on the part of CBA), but it didn't forbid it.
I disagree that it was a failure of advocacy on the part of the CBA. It was a failure of understanding by the NTIA.
CBA made their case, the NTIA acknowledged their points, but (incorrectly) felt that ATSC receiver sensitivity and cost would suffer for the majority of users. A simple bypass relay would not cause 3 dB of signal loss, or add much to the cost of a CECB. 

http://www.ntia.doc.gov/ntiahome/frnotices/2007/DTVFinalRule_2e.htm

c.         Analog Signal Pass Through
49. The National Translator Association recommended that the CECBs pass analog signals directly through without processing or modification.[ 91 ] The CBA also requested that NTIA require that CECBs pass through an analog signal, either actively or passively. CBA noted that Class A and LPTV stations are not subject to the February 17, 2009 end-of-transition deadline, applicable to full-power stations. It indicated that it was important that the converter box not block the analog signal.[ 92 ] LPTV licensee Island Broadcasting noted that thousands of LPTV stations in the United States will remain analog after the transition and are not carried on a cable system or other multi-channel video delivery service. Island recommended that the converter box contain a feature to pass through the analog signal from the antenna to the TV receiver, either when the box is shut off, the signal is passed, or by means of a built in by-pass switch.[ 93 ] Funai, however, noted that "[a]n analog pass through, while conveniently retaining legacy analog TV support, would degrade the RF noise performance of all so-equipped DTA tuners by 3dB - a penalty that could not be recovered by any consumer with such a unit." Funai recommended that a consumer purchase a separate switch and/or external splitter to receive analog television.[ 94 ]
50. NTIA is sensitive to the needs of consumers who will wish to continue to view over-the-air analog television during and after the digital transition. Not only will many consumers continue to rely on analog television reception of Class A stations, LPTV stations and translators after the transition, many consumers who purchase the CECB will require the ability to receive analog television signals during the transition period as not all full-power television stations in the United States have completed their digital build-out. NTIA, however, is reluctant to require an analog pass through feature because it will result in a reduction in received signal level and in increased cost to all consumers who purchase a CECB. The amount of reduction in receiver sensitivity and increased cost is dependent on how the analog pass through feature is implemented. This reduction may not be noticeable to consumers who receive strong signals in urban areas, but may mean that consumers who receive marginal digital and analog signals will be unable to receive television signals via the CECB. NTIA notes that switches and external splitters are commonly available where television sets are sold. A single A/B switch will not fully bypass a CECB, however, creating a difficult wiring scenario for the consumers. Splitters and their inherent loss as well as additional cabling makes their use less than optimal in fringe reception areas. NTIA strongly urges manufacturers to take into consideration the needs of consumers to receive analog television along with digital television in the development of CECBs and to investigate minimal signal loss solutions that would ensure an acceptable analog signal pass-through. In the Final Rule, NTIA permits that the converter box to pass through the analog signal from the antenna to the TV receiver. 






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