[opendtv] Testimony
- From: Bob Miller <bob@xxxxxxxxxx>
- To: opendtv@xxxxxxxxxxxxx
- Date: Thu, 26 May 2005 11:26:42 -0400
Key issue. But he does not ask for a standard for receivers.
From the testimony below....
"To preserve this access and mitigate the disruption for consumers with
analog sets, digital-to-analog converters must be widely available at a
reasonable price. In this regard, it is important to keep in mind not
only the cost of such converters, but the capabilities of those
converters. At a
minimum, digital converters should be capable of receiving all digital
broadcast formats, both HD and SD, on any VHF or UHF broadcast channel,
and provide connection to an existing analog TV receiver via a channel 3
(or 4) RF interface. Thus, in conjunction with any analog receiver, the
digital
converter box should be able to receive, render and display usable
pictures and sound from high definition as well as standard definition
broadcasts,
but would not be required to render pictures and sound at more than
standard definition quality.
In order not to disenfranchise current OTA-only television viewers,
digital converter boxes should be designed so as to maximize the likelihood
that they will work with digital broadcast signals in the same receiving
configuration (same antenna, location, etc.) as used for current analog NTSC
reception. Thus, the digital converters should be able to receive and
display signals under the most challenging receiving conditions, including
low signal level, severe multipath and adjacent channel interference
conditions. While marginal NTSC pictures are often comprehensible and
accepted by TV viewers, the digital “cliff effect” cleanly separates
digital TV viewers into those with watchable pictures and those without
pictures at
all. Thus, because viewers with poor digital reception would be
essentially eliminated as television viewers, allowing less than
excellent RF receiver
performance in digital converters may sacrifice much of the
broadcast-only viewing audience when analog transmissions cease."
Testimony of
K. James Yager
CEO
Barrington Broadcasting Company
On behalf of the
Hearing on the Staff Draft of the
DTV Transition Act of 2005
U.S. House of Representatives
Subcommittee on Telecommunications and the Internet
May 26, 2005
Thank you, Mr. Chairman, for the opportunity to appear today before the
Subcommittee to discuss the staff draft of a bill aimed at advancing the
digital television transition, while helping consumers to continue to
use their analog televisions. My name is K. James Yager. I am CEO of
Barrington Broadcasting Company. I appear before you today on behalf of
the National Association of Broadcasters,
First of all, I must say that I could not agree more with the purpose of
the bill. Advancing the DTV transition while preserving television reception
for consumers, particularly those reliant on free-over-the-air
television for news, entertainment, local information and critical
emergency warnings,
has long been the goal of Congress, and of us all. Crafting a plan that
also helps consumers to continue to use their analog televisions until they
are ready to join the full digital television experience by purchasing a
digital set will respond to consumer needs and expectations in a forward
thinking way. I support your efforts in this regard.
It is, after all, the consumer for whom the DTV transition was launched.
The American consumer, long the beneficiary of the finest television service
in the world – in fact the “envy of the world,” must continue to receive
the best television today’s technology can provide. The American consumer
deserves the best technical picture quality achievable, the greatest
array of programming and information choices, the most varied supplemental
services and the surest emergency warning capability. The DTV
transition, long underway, will provide this to America’s populace – and
for free.
Consumers deserve and will demand nothing less.
Consumers deserve and will demand as well that their television
reception not be interrupted in the midst of this transition to the
amazing world of
digital television. Which is why a DTV transition bill must contain
provisions for continued use of both analog and digital receivers by the
vast majority of consumers while they make the transition and buy new
sets. Thus, the staff draft wisely includes provisions for cable
subscribers, the
largest segment of the viewing audience, to continue to use their analog
sets after analog broadcasting ceases but at the same time have ready access
to the digital version available to their cable-subscribing neighbors
whohave purchased HDTV receivers.
We are confident that, as the Subcommittee works on the draft bill, it
will also work to help free over-the-air consumers continue to watch
their analog televisions while they taste true digital television and
make their plans to join the digital television revolution. In this
regard, it is essential
that Congress have a plan to ensure that all households can get
television reception. This plan is necessary to meet consumers
expectations and
prevent widespread outcry. Consumers expect their televisions to work,
and they will continue to expect – and demand – this, until they are given
advance and clear information to the contrary. The staff draft already
includes provisions to give advance warning to the public. Without
sufficient warnings, the public will rebel and will blame all in sight
for newly or recently purchased sets going dark. If, on the other hand,
consumers are given lead time, adequate explanation and clear consumer
information about new digitally-capable sets as well as help equipping
OTA-only households, they will embrace the digital television future
with enthusiasm and excitement rather than with dismay and outrage.
Broadcasters are ready to serve the public with brand new digital
facilities and beefed up digital signals, high definition and high
quality digital
versions of their favorite shows, specials and sporting events including
current and coming plans for multicasts like Final Four basketball and zoned
newscasts. We are designing new news sets, purchasing digital cameras
and seeking to exploit digital capabilities at every turn. Cable too has
readied their digital plants, expanded capacity far beyond expectations
and planned for advanced digital services. Set manufacturers have deployed
increasingly cost-effective digital sets and sets at various size and
price points with glorious high definition picture capability. They are
adding
digital tuning capability to analog sets, extending those “second tier”
sets ’ lives beyond the analog turn off and providing popular “cable ready”
versions of digital sets.
The FCC has adopted measures designed to advance consumer take-up of
digital sets, such as mandatory broadcaster build-out deadlines,
jaw-boned voluntary measures for broadcasters, programmers, cable and
manufacturers, encouraged and approved cable/DTV inter-operability
specifications (including tuners in “cable ready” sets) and the
all-important tuner mandate. (That measure alone, once it is fully in
place, will speed consumer penetration of digital reception capability
in the course of normal replacement of televisions and do it in short
order.)
Now, this Subcommittee has taken the reins and is moving boldly to
advance the digital television transition, encouraging consumers to
cross the
digital finish line while preserving use of the majority of analog sets
for a reasonable period and setting a deadline and measures that will
provide
consumers with warning, information and education. NAB applauds your
efforts to grapple with critical consumer issues, speed up the digital
television transition and recover spectrum for national security and
public safety use.
We believe and hope that the Subcommittee, as it continues to work on
the staff draft will keep consumers at the forefront and meet all the
goals set
out for the digital transition by Congress in 1997.
Congress sought to achieve three overarching goals in the DTV transition:
(1) Bring the benefits of digital technology with its potential for more
programming options and advanced services to
consumers;
(2) Avoid the loss of free television to large numbers of consumers
stranded with analog-only receivers; and
(3) Reclaim channels 52-69 to be reallocated for other purposes.[1]
The staff draft now before you would achieve Congress’ goal of
reclaiming spectrum for re-use. It would help advance the digital
transition, and
hence help advance goal number one, by providing for cable carriage of
digital broadcast signals, as broadcast and without material degradation, to
entice the largest segment of the public to buy digital sets and by
requiring advance warning and consumer education and information, which
should incent consumers to buy digital sets. And it would begin to
address goal number two by advancing the all-important Tuner mandate so
that all televisions 13” and larger sold after July 2006 will receive
digital signals and thus many OTA-only consumers will sooner have free,
digital reception by normal replacement of television receivers and not
be stranded by the analog cut-off.
As it is worked on by the Subcommittee the staff draft bill can and
should make clear that cable carriage of broadcasters’ digital “primary
video”
service includes the free multicast programming services that would
advance Congress’ goal number one of bringing the benefits of digital
technology with its potential for more programming options and advanced
services to consumers.
And of course yet to be added to the staff draft is the missing critical
piece necessary for the accomplishment of Congress’ goal number two, namely
enabling OTA consumers (over 20 million households) to continue to watch
their analog televisions after the analog cut-off until they have purchased
DTV sets. This critical piece of the puzzle that Congress has already
identified (avoiding stranding OTA viewers) will necessarily involve a plan
to make digital-to-analog converters accessible to OTA households
without digital reception capability. As I have testified previously,
many of those
OTA viewers are not in a position to purchase new equipment – even a
converter box. We must not disenfranchise those citizens.
We do believe that the wise step of moving up the tuner mandate
suggested in the draft will naturally equip many OTA households with
digital reception. Other OTA consumers will have taken the plunge on
their own and bought a HDTV or digital receiver, particularly after the
consumer education and warnings the bill will require. But for a
majority of OTA households, Congress must devise a solution to avoid
loss of television service and its emergency warnings to millions of OTA
households. This, the OTA viewing public will demand, and deserve. We
expect the Subcommittee will be able to fashion a converter plan that
will meet the basic needs and expectations of consumers, including those
less well off financially, in the 20 million OTA-only households that
they will continue to receive television service without subscribing to
a pay television service.
NAB believes that the draft bill can provide a useful framework for
advancing the digital television transition, avoiding stranding OTA
households, reclaiming spectrum for re-use and meet consumers’
expectations that their existing televisions will continue working for a
reasonable time.
Before turning to each of the provisions of the draft bill in turn for
more specific comment, I would like to describe for the Subcommittee the
progress broadcasters have made in the DTV transition to date. After
addressing the draft bill's specifics, I will lay out for the
Subcommittee the challenge it faces as it seeks to grapple with the OTA
households/digital-to-analog converter issues, as well as some comments
about the converters consumers need.
Broadcasters Are Ready For the End Game of the Transition
Even without the final pieces of the puzzle in place, evidence of the
remarkable progress made so far can be found everywhere, due in no small
measure to broadcasters’ commitment and actions. Our industry has spent
enormous sums of money and undertaken extraordinary steps to implement
the transition, and I am pleased to report that these efforts are paying
off. Broadcasters have built – and are on air with – DTV facilities in
211 markets that include 99.69% of all U.S. TV households.[2] At this
point in the transition, over four-fifths – 84.2% - of U.S. television
households
have access to at least six free, over-the-air digital television
signals, per NAB database figures. According to the FCC, nationwide, at
least 1497
television stations in 211 markets are delivering free, over-the-air
digital signals today.[3] Currently, more than 92 million households
receive six or
more DTV signals; 71 million households receive nine or more DTV
signals; and a full 30 million households receive 12 or more DTV
signals, per NAB database figures. More and more digital stations are
overcoming their unique obstacles and going on air almost daily. The
digital transition is
working and moving ahead quickly, and any claims to the contrary are
simply untrue.
In the top ten markets, covering 30% of U.S. households, all top four
network affiliates are on-air with digital signals,[4] and in markets 11-30
(24% of U.S. households), all 79 top four affiliated stations are
on-air. Thus, all ABC, CBS, Fox, and NBC affiliates in the top 30 markets,
representing 53.5% of all U.S. households, are on air with DTV. Even
smaller stations in these markets and stations in smaller markets are making
terrific progress, with at least 1378 out of a total 1603 stations
currently on air in digital,[5]/ despite the far fewer resources of
these stations.
In fact, many firms have been forced to mortgage their stations to
afford the equipment needed to implement the transition, and without any
immediate prospect of revenues to offset these huge investments.
On the programming side, both networks and local stations are providing
an extraordinary amount of high-quality DTV and HDTV programming, as
well as a growing number of valuable multicast channels, to entice
viewers to join the digital television transition and purchase DTV sets.
For example, the four top networks currently offer virtually all their
prime time programming in HDTV, along with high-profile specials and
sporting events like the Academy Awards and the Grammy’s, the Masters,
and playoff games in all the major professional sports leagues. The WB
network also is offering ten or more prime time programs in HD. And this
continues to grow.
Local stations are also doing more all the time to supplement the
network HDTV and multicast fare, despite the enormous cost for full
local HD production facilities. Examples of local HDTV programming
abound. Stations that have begun to produce and broadcast their daily local
newscasts in HD include WRAL-TV (Raleigh, NC), KOMO-TV (Seattle, WA),
KUSA-TV (Denver, CO), WUSA-TV (Washington, D.C.), and WJW-TV (Cleveland,
OH). HD broadcasts of local special events are numerous, like KTLA’s
(Los Angeles, CA) broadcast of the Rose Parade in a commercial-free HD
broadcast that was simulcast in Spanish and closed captioned and
distributed on many Tribune and other stations. Raycon Media this summer
will roll-out a new 24-hour TV music video channel on 30 of its
stations, which includes coverage of local music artists and local
concerts. NBC Universal has signed up enough affiliates for its Weather
Plus digital channel to reach 60% of the U.S. Gray Television and UPN
are partnering to expand DTV program options.
All of these developments demonstrate that broadcasters are more anxious
than anyone to get the transition over and done with. Broadcasters
have no interest in shouldering the enormous costs of operating dual
facilities any longer than absolutely necessary to avoid disruption to
consumers. Building a second transmitter, and then maintaining and
powering two transmitters for any period of time is extremely expensive,
especially since there will be no opportunity to recover much of these
costs. Similarly, any need to repair or replace analog equipment now is
little more than wasted resources. Indeed, by the time the transition is
over, broadcasters will spend between $10 and $16 billion to fully
convert to
digital, and we simply cannot afford to strand this investment, or
accept any further delays in our ability to provide new digital services
to recoup
at least some of this investment.
STAFF DRAFT – SECTION BY SECTION DISCUSSION
Sec. 3 Analog Spectrum Recovery: Hard Deadline
The 85 percent DTV penetration test contained in Congress’ 1997 Balanced
Budget Act, which would be replaced with a hard deadline in the
draft bill, was devised to protect the vast majority of consumers from
an early end to the DTV transition and the need to replace hundreds of
millions
of televisions overnight. It would allow consumers to trade-out their
analog sets and upgrade to digital sets over time, and in the normal course
of replacing televisions. With the hard deadline in the staff draft,
consumers will face the prospect of replacing at least their main television
sooner than they may have expected.
We believe, however, that other provisions of the draft bill, namely
advancing the Tuner mandate and permitting cable downconversion of
digital broadcast signals to analog for cable subscribers (who would
still mreceive digital broadcast signals as broadcast), ameliorate much
of this
concern. We expect that there will be further discussion within the
Subcommittee as to whether the specific date in the staff draft is the
optimal hard cut-off deadline. And, of course, the major unresolved
issue is provision in the bill for OTA households to continue to receive
television service after the analog cut-off.
One of Congress’ objectives when it authorized the transition to digital
beginning in 1996 was to strengthen the over-the-air broadcasting
system. A premature end to analog broadcasting before consumers are
ready may have the opposite effect of reducing the audience of local
stations and thus reducing their ability to provide attractive
programming and local public service. If consumers are driven to cable
and satellite programming, that would increase those monopoly providers’
power and frustrate Congress’ goal of improving local broadcasting. This
then, continued preservation of free local broadcasting, is another
reason that the Subcommittee should make provision for converters for
OTA-only households without digital reception capability, including some
solution for the less well-off.
The provision of Sec. 3 of the staff draft that directs the FCC to make
final DTV channel assignments within the core by December 2006 and
conclude any reconsideration of these assignments by July 31, 2007
appears reasonable, given the FCC’s current DTV channel assignment plan, and
necessary to stations’ ability to construct and move to new digital
facilities before the analog cut-off. There may however be appeals of final
channel assignments that would complicate completing final construction
for some stations and consumers. This is all the more reason for the
Commission to continue its diligent work to accommodate the channel
changes needed by many stations.
We are pleased to see in Sec. 3 of the draft bill six month “status
reports” by the Commission on progress in completing Canadian and Mexican
coordination of outstanding DTV channel assignments. This coordination,
of course, is necessary for all stations to complete DTV facilities
construction and be on-air before analog broadcasting is to cease.
NAB notes that, once the channel repacking plan is complete, the FCC
must turn to the issue of channels within the core and licenses for digital
translators. These “repeaters” of full power stations provide critical
television service to thousands in rural and mountainous areas, which must
be preserved in the digital switch-over. We urge the Subcommittee to
consult with the FCC as to the most efficient way to protect translator
service in light of this newly developing DTV transition plan.
Sec. 5. Consumer Education Regarding Analog Televisions
NAB agrees that consumer education about the coming end of analog
broadcasting and the need for converters and warnings on analog sets
and in-store displays alerting consumers to the limited useful life of
these sets is important for consumers and important to the transition.
Promotion
and education for consumers about DTV can encourage consumers to
purchase DTVs, thereby reducing the number of households needing
converters to continue receiving television service. NAB in fact urged
provision of these measures in our February 2005 testimony to this
Subcommittee. We agree that the Commission should undertake a
substantial public outreach program for consumers, and that the various
industry parties should participate in alerting consumers to the end of
analog broadcasting.
NAB supports the provision in Sec. 5 directing the FCC to preserve and
expedite the all-important Tuner mandate schedule. This
provision, once fully effectuated, will, on its own, result in sizeable
numbers of households becoming digital capable, by dint of consumer
replacement of analog televisions in the normal course. Extrapolating
from the conclusions of an A.D. Little, Inc. report prepared for NAB and
MSTV and submitted to the FCC on the cost of adding DTV reception
capability to television sets and timeline scenarios for achieving 85%
digital
penetration,[6] we estimate that the tuner mandate alone could result in
reaching 85% digital penetration by 2009. This powerful provision can
reduce the number of digitally-incapable households and thus the number
of households needing converters.
NAB supports expediting the turner schedule as the staff draft does, but
we suggest that a provision be added to similarly advance the
"cable ready" tuner schedule, which mirrors the tuner mandate.
Sec. 6 Digital-to-Analog Conversion and Tiering
The draft bill provision permitting cable operators to downconvert
digital broadcast signals to analog at the headend (or in subscribers’
homes) for delivery to cable households with analog sets, coupled as it
is with mandatory provision of the primary video of the digital signal
to subscribers’ homes, seeks to achieve the purposes of, advancing the
(true) DTV transition for cable consumers (enticing them to buy DTV
sets), not obsoleting the tens of millions of analog sets connected to
cable systems and providing digital broadcast service to cable
subscribers with DTV sets. This provision addresses the fundamental flaw
of the DTV transition plan previously discussed by the former Chief of
the FCC's Media Bureau. The Media Bureau plan allowed only for
downconversion and thus would have thwarted the many benefits that
undegraded digital service would deliver to cable consumers. We urge the
Subcommittee to carefully consider the language of the staff draft to
ensure that it achieves the objective of ensuring carriage for all stations.
This provision should also make clear that carriage of the digital
“primary video” includes all free broadcast programming, as the
Cable Act must carry provision intended.[7] Cable carriage of all
multicast digital programming will accomplish for the 65% plus of
consumers who are cable subscribers the goal number one of Congress for
the DTV transition: bringing the benefits of digital technology with its
potential for more
programming options and advanced service to consumers. The opportunity
for new universal free services was one of the key reasons that Congress
authorized the DTV transition, and it is simple economics that the
consumer appeal of the HDTV/multicast mix will help drive purchase of
digital sets, to the benefit of the consumer. This tremendous consumer
benefit, redounding as it will to the benefit and strengthening of the free
over-the-air television service as the Cable Act intended, would come at
scant cost to cable systems, with their vast complement of cable channel
capacity.
Cable operators can no longer claim channel-locked capacity. The
enormous growth in cable carrying capacity has been revealed by data
submitted by the cable operators themselves, in response to a formal
survey request by the Commission. NAB/MSTV/ALTV retained the Merrill
Weiss Group to summarize and analyze this data.[8] Some specific
conclusions of the Weiss Report are:
· Overall bandwidth delivered to the average subscriber increases from
622 MHz to 752.2 MHz over the period from yearend 1999 to yearend 2003.
· Subscribers receiving 750 MHz or greater total bandwidth service
increase from 56.1 to 86 percent over the period of the survey.
· Calculations show a capacity range of 261.8 to 295.7 total program
services to the average subscriber at yearend 2003, with capacity continuing
to increase as cable completes upgrades currently underway.
· Calculations show a capacity range of 298.7 to 399.9 total program
services to the 86 percent of subscribers receiving 750 MHz or more total
bandwidth service at yearend 2003.
Cable parties agree the problem is that innovative and diverse program
offerings as well as new advanced non-video services would be
squeezed out by DTV must carry. But as seen in the Weiss Report, in 2003
the average cable subscriber will have delivered to it 725.2 MHz of
bandwidth, with somewhere between 261.8 to 295.7 total program services,
in addition to a full allocation of channels for non-video services.
The Weiss Report also includes a chart utilizing the new cable data that
shows that the relative burden of carrying both DTV and NTSC
signals will be less than the initial must carry burden (13.42 percent
for analog commercial stations in 1993 and 8.43 percent for both DTV and
NTSC at
yearend 2003).[9] In addition to the explosion in cable capacity, this
is also due to the fact that two digital broadcast television signals can be
carried on one six MHz channel.[10] In short, cable cannot properly
argue that capacity constraints preclude temporary inclusion of all
broadcast
signals.
The provision in this section of the draft bill that authorizes the FCC
to sunset this “carry-one-carry-all” requirement after five years,
depending on
penetration of digital capability further limits the miniscule burden on
cable operators. Moreover, this sunset feature of the provision limits the
small burden on cable to achievement of the benefits of downconversion
to consumers, to the transition and to the free local television service.
This provision gives cable consumers the opportunity to trade out their
analog sets and upgrade to DTV in a more normal course and thus avoids
consumer frustration and outcry.
The Need for a Converter Solution for OTA Households
NAB has recognized that, while the DTV transition was designed to afford
consumers the opportunity to trade out their analog receivers for digital
sets on their own timetable, the transition must come to a conclusion at
some reasonable point. Nonetheless, we remain convinced that any transition
plan must protect OTA consumers from the loss of television service and
preserves local broadcast service for all cable subscribers. We also
believe that consumers will demand a cost-effective solution for analog
OTA sets in all homes. We thus believe that the staff draft should
include an
accommodation for OTA only households and present a solution for analog
OTA sets in general. The numbers of sets and consumers at issue here
speak for themselves and for the expected public reaction if some real
solutions are not included in the Subcommittee DTV plan.
At the time of the conversion to all digital, consumers in 20.5 million
households that rely solely on over-the-air (“OTA”) broadcast television
will lose all television service if they have not procured digital
television-capable receivers or converters. This situation has the sure
signs of significant disruption, and the Subcommittee is wise to begin
to plan for that time, in order to minimize disruption.
NAB believes that protecting consumer’s access to their favorite
television programming and channels, as well as to news, information and
emergency
alerts, will be critical to a successful conclusion to our digital
television transition. We must not forget that there are millions of
unwired television sets in cable and satellite homes as well.
Approximately 18.3 million MVPD households have one or more television
sets that rely
solely on over-the-air television reception. There are today
approximately 280.5 million analog sets in use.[11] Consumers may not
readily dispose of
these sets, even if they have purchased a new digital television receiver.
Congress must take the steps necessary to protect OTA sets from
obsolescence. Clearly, the free, universal OTA broadcast service must be
preserved and the 20.5 million households that rely on it must be
protected against loss of television service.
Many OTA households will likely have purchased DTV-capable receivers by
the time analog broadcasting ends. But for the remaining OTA households
(and for analog sets in all households), there must be a solution, or
rather, a series of solutions. One measure already included in the draft
bill is promotion and education about DTV, to encourage consumers to
purchase DTVs. A near term measure, also included in the draft bill, is
to require warning labels on analog-only sets, alerting consumers to the
limited useful life of these sets.
The needed key to avoiding disenfranchising large numbers of consumers
and to mitigating the disruption for consumers with analog sets, will be
making digital-to-analog converters widely available at a reasonable
price. Without the widespread availability of low cost digital-to-analog
down-converters, Congress risks disenfranchising millions of viewers and
rendering useless the analog sets they rely on and, in many cases, just
recently bought. Not only is the OTA analog set population enormous (73
million) and the number of OTA-only homes huge (20.3 million
households), as I have previously testified, the importance of OTA
service cannot be overstated in terms of the OTA viewing public’s
reliance on the free, over-the-air service for news and information and
emergency alerts.
To evaluate the stake the public has in this transition (and to assess
the damage that various proposals affecting the digital transition may
inflict
on the public), Congress must take into account three components of the
public interest served by over-the-air television. The first component is
the 18.9 percent of viewers that rely solely on over-the-air service,
whether because they cannot afford to subscribe to cable or DBS, because
cable or DBS service is not available to them or does not provide local
broadcast signals, or because they believe in the universal availability of
free, over-the-air broadcast service. The second component is the owners
of the 28 million of television sets in MVPD homes that are OTA-only
analog sets. The third component consists of all viewers, because all
viewers rely on over-the-air service in times of weather, terrorist or
other emergencies when cable or satellite service may not be available
and because broadcast television service provides an effective
competitive check on cable and DBS services in terms of price, service,
and diversity.
Many of the 18.9 percent of U.S. households that receive television
service solely over the air do so by choice, not because economics
dictates it. For
example, a survey conducted by the Consumer Electronics Association
found that “[l]ess than 30 percent [of households that have chosen not to
subscribe to cable or DBS] indicate that insufficient funds play a role
in their decision not to subscribe.”[12] Many Spanish-speaking viewers
choose
not to subscribe to cable or DBS because these services offer primarily
English-language programming.[13]
But there are also a large number of viewers who cannot afford pay
television. Twelve percent of American households fall below the poverty
line.[14] They should not be forced by government policy into paying
subscriber fees that only escalate over time and that they can’t afford.
They deserve as an option -- the preferred and responsible option -- a
vibrant, over-the-air service that provides the benefits of new digital
technologies.
Over-the-air viewers have important, well thought out and legitimate
reasons for relying on over-the-air reception, e.g., they believe in the
value of
free, over-the-air television; they do not want to be locked into the
ever-increasing costs of pay television service; they view primarily
alternative-language programming; they have additional sets that are not
hooked up to cable or satellite, among others. They feel well-served by the
locally-oriented and public interest programming they receive over the
air and do not see the need nor do they want to be pushed to ever more
expensive pay television services. Because broadcast television is
universally available and is the only service used by millions of
Americans, Congress
should ensure that these viewers are not shut out or marginalized, but
continue to have the option to rely on over-the-air reception and still
receive meaningful local broadcast service.
To preserve this access and mitigate the disruption for consumers with
analog sets, digital-to-analog converters must be widely available at a
reasonable price. In this regard, it is important to keep in mind not
only the cost of such converters, but the capabilities of those
converters. At a
minimum, digital converters should be capable of receiving all digital
broadcast formats, both HD and SD, on any VHF or UHF broadcast channel,
and provide connection to an existing analog TV receiver via a channel 3
(or 4) RF interface. Thus, in conjunction with any analog receiver, the
digital
converter box should be able to receive, render and display usable
pictures and sound from high definition as well as standard definition
broadcasts,
but would not be required to render pictures and sound at more than
standard definition quality.
In order not to disenfranchise current OTA-only television viewers,
digital converter boxes should be designed so as to maximize the likelihood
that they will work with digital broadcast signals in the same receiving
configuration (same antenna, location, etc.) as used for current analog NTSC
reception. Thus, the digital converters should be able to receive and
display signals under the most challenging receiving conditions, including
low signal level, severe multipath and adjacent channel interference
conditions. While marginal NTSC pictures are often comprehensible and
accepted by TV viewers, the digital “cliff effect” cleanly separates
digital TV viewers into those with watchable pictures and those without
pictures at
all. Thus, because viewers with poor digital reception would be
essentially eliminated as television viewers, allowing less than
excellent RF receiver
performance in digital converters may sacrifice much of the
broadcast-only viewing audience when analog transmissions cease.
Current DTV converters are available from about $200 and up, although
none are presently available with SD-only outputs. Like all other electronic
components, the manufacturing cost of a digital converter box is closely
related to the manufacturing volume. NAB and MSTV previously studied the
cost of adding DTV capability to television receivers as well as the
likely cost of set top boxes.[15] The Arthur D. Little study noted that
by the
year 2006 digital converter boxes could be expected to sell at retail
for under $200, with a manufacturing cost near $100, composed mostly of the
fixed recurring costs of manufacturing (a physical box with a TV tuner,
power supply, cabinet, remote control, switches, knobs, jacks, etc.) and
only slightly impacted by the cost of the integrated circuits required
to receive and process digital broadcasts.
Motorola’s 2004 testimony before this Subcommittee[16] that a digital
converter box with a retail price of $67 is possible in 2007 would indicate
that further price reductions from large volume production are possible.
Similarly, LG Electronics indicated in FCC filings last summer that the
retail price of a simple digital-to-analog converter box could be under
$100 by late 2005, assuming production volumes in the millions of units
and that they believe that digital-analog TV converter prices may be as
low as $50 by 2008, assuming industry-wide demand of tens of millions of
units by
then.[17]
Conclusion
NAB stands ready to work with the Subcommittee as it continues to refine
the draft bill on the DTV transition that is the subject of this
hearing. We believe that the DTV transition is progressing and the full
effect of the tuner mandate coupled with the growing awareness of DTV’s
amazing improvement to television viewing will move the transition
across the finish line in the next few years. But we appreciate the
Subcommittee’s desire to bring a certain end to the transition and its
efforts to date to accomplish that goal. Our abiding belief in the
necessity to preserve television service for OTA households without
digital capability and the wisdom of devising a cost-effective solution
for all OTA analog sets leads us to urge the Subcommittee to focus on
this critical remaining piece for its plan to conclude the DTV transition.
----------------------------------------------------------------------------
----
[1] 47 U.S.C. § 309(j)(14)(B).
[2] National Association of Broadcasters, DTV Stations in Operation,
http://www.nab.org/Newsroom/issues/digitaltv/DTVStations.asp (as of May 25,
2005).
[3] See www.fcc.gov/mb/video/dtvstatus.html (“Commission statistics”).
[4] This includes 38 with licensed full-power digital facilities and two
New York City stations with Special Temporary Authority (“STA”) currently
covering a significant chunk of their service areas and with plans to
expand even more.
[5]/ See Commission statistics.
[6] “Assessment of the Impact of DTV on the Cost of Consumer Television
Receivers,” Final Report to MSTV and NAB, Arthur D. Little, Inc.,
September 10, 2001.
[7] See NAB/MSTV/ALTV Petition for Reconsideration and Clarification,
FCC CS Docket No. 98-120, filed April 25, 2001; Petition for
Reconsideration of the National Association of Broadcasters and the
Association for Maximum Service Television, Inc., FCC CS Docket No.
98-120, filed April 21, 2005.
[8] Merrill Weiss Group, Analysis of Cable Operator Responses to FCC
Survey of Cable MSOs, Attachment A to the Reply Comments of
NAB/MSTV/ALTV, CS Docket No. 98-120 (filed Aug. 16, 2001)("Weiss Study").
[9] Weiss Study at 15.
[10] Id. at 12.
[11] NAB appends hereto, as Attachment A, a series of charts constructed
for the FCC’s proceeding inquiring about options for minimizing the
disruption to consumers when the switch-over to digital broadcasting
occurs. See Public Notice, MB Docket No. 04-210, DA 04-1497, May 27,
2004. In that proceeding, the FCC asked for quantitative data on viewers
and receivers. See also Comments and Reply Comments of the National
Association of Broadcasters and the Association for Maximum Service
Television, Inc. in that docket. The estimates used in this testimony
are from Attachment A.
[12] Comments of the Consumer Electronics Association, FCC MB Docket No.
04-210, August 11, 2004 (“CEA”) at 4.
[13] Comments of Entravision Holdings, LLC, FCC MB Docket No. 04-210,
August 11, 2004, at 2.
[14] See Census Bureau says 1.3 million more slipped into poverty last
year; health care coverage also drops, CNN Money (Aug. 26, 2004),
available at
http://money.cnn.com/2004/08/26/news/economy/poverty_survey.
[15] “Assessment of the Impact of DTV on the Cost of Consumer Television
Receivers,” Final Report to MSTV and NAB, Arthur D. Little, Inc.,
September 10, 2001.
[16] “Motorola Broadband CTO to Speak Before House Subcommittee on
Telecommunications Regarding DTV Transition,” Motorola press release,
July 21, 2004.
[17] Comments of LG Electronics filed in FCC MB Docket, 04-210, August 11,
2004 at 3.
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