[opendtv] Re: Letter to TV Technology

So, "views of the FCC" are contained in OET reports?  

I'm sorry, but the "views of the FCC" -- that is, the Commissioners and
staff, the latter only when pursuant to delegated authority -- is expressed
in Memoranda, Memoranda Opionions and Order(s), or (the decision but not the
details) in Orders, sometimes as a "Report and Order."  Never as a 'staff
report.'

Indeed, were one to care, one can investigate -- using the "delegations of
authority" or actions by the Commissioners in the wake of a staff report --
whether a particular report actually represents a view of the Commission.

One doesn't have to think back all that far to reference a discussion on
this list about an idiot who charged that the FCC didn't like the "views"
contained in his attempt at a staff report, and "suppressed" it.  The actual
facts bear out that the report was incomplete, didn't meet simple standards
for completeness and relevance, and was actually published by the
Commission, just not with as much emphasis as the author thought his
inchoate report deserved.

So, the FCC issues reports that don't necessarily reflect the "views" of the
Commission, and in some cases, reports that may be hostile to the "views" of
the Commission.  Anybody who has watched the FCC for more than about 30
seconds picks this up continuously.  However, you have to actually visit the
FCC and talk with people who also work in and out of the building to pickup
this kind of "soft lesson."

As explained atop every FCC public notice and press release, the only thing
that counts is "texts" of decisions.  Reports ain't "texts."  All one need
do is to review just about any copy of the FCC "Daily Digest" of
freshly-released documents to see that "Reports" are a separate category,
and when the Commission releases a report (as opposed to a 'staff report')
that status is mentioned.

John Willkie

<standard 'big-dog" rant />

-----Mensaje original-----
De: opendtv-bounce@xxxxxxxxxxxxx [mailto:opendtv-bounce@xxxxxxxxxxxxx] En
nombre de Manfredi, Albert E
Enviado el: Sunday, October 21, 2007 4:42 PM
Para: opendtv@xxxxxxxxxxxxx
Asunto: [opendtv] Re: Letter to TV Technology

Craig Birkmaier wrote:

>> The FCC correctly said, in 2001, that the reception problems
>> were going to be resolved before too long. We saw proof of
>> that in March 2002.
>
> They said no such thing. They said that a change would be
> disruptive to the transition.

In case you're obsessing about the mention of 2001, that view of the FCC
was stated in FCC/OET TRB-00-2, dated 9 April 2001:

"The Commission was petitioned to allow COFDM as an alternative to
8-VSB, with proponents of this position offering field demonstrations
purporting to show the relative superiority of COFDM in difficult
reception conditions and emphasizing anecdotal failures of early 8-VSB
consumer receivers.1 This controversy has, however, spurred the
continued development of the 8-VSB receivers, particularly the channel
equalizers, and also focused the attention of the Commission on the need
for an objective and scientific analysis of the state of 8-VSB receiver
performance."

And:

"To the extent that newly improved prototype or consumer-model receivers
can be provided by manufacturers for testing and can be accommodated in
the test bed, such additional receivers will be added to the test sample
to allow a continuing assessment of progress in receiver performance."

It was at about this time that the FCC decided to stay with 8-VSB.
Although they might possibly have agreed to switch to COFDM had the NAB
pressured them to do so, I do believe.

By March and then April of 2002, the 4th gen Linx equalizer had been
demoed at NAB and had been tested by the CRC, showing the ability of the
equalizer to make use of reflections to increase signal power (in
situations where the limiting C/(N+I) was less than 15 dB).

Linx field-tested their 4th gen now-miniaturized demod in March 2003 and
the CRC tested the Zenith 5th gen in September 2003. So in fact, what
the FCC said came to pass.

Bert


 
 
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