[opendtv] Re: Dueling Statutes?

If a reglatory agency doesn't understand something, it is the advocates
before it that are responsible for correcting that.  If the agency thought
rf sensitivity, then the advocates need to do tests to show that isn't the
case.

If the legislation doesn't require analog pass-through, that isn't an agency
failure; it was a failure of advocacy before Congress.

I'm not saying that NTIA didn't make a mistake.  

What is telling is how long it took the CBA to try to do something about
this.  They waited until the coupons were already in people's hands.  That
wasn't a mistake on the NTIA's part, and it shows that CBA is actually
interested in something else besides analog pass-through.

They could have filed a court challenge more than a year ago.  They did not.


John Willkie

-----Mensaje original-----
De: opendtv-bounce@xxxxxxxxxxxxx [mailto:opendtv-bounce@xxxxxxxxxxxxx] En
nombre de John Shutt
Enviado el: Friday, March 28, 2008 11:29 AM
Para: opendtv@xxxxxxxxxxxxx
Asunto: [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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