[opendtv] Re: 20040719 Mark's Monday Memo

  • From: "Manfredi, Albert E" <albert.e.manfredi@xxxxxxxxxx>
  • To: <opendtv@xxxxxxxxxxxxx>
  • Date: Tue, 20 Jul 2004 11:07:43 -0400

> - Despite noting that it would result in a loss of analog-TV service,
> the FCC allowed WRNN in Kingston, NY to transmit DTT only because,
> "according to Nielsen Media Research, there was no reportable
> over-the-air viewing for the station for the month of April 2004":
> <http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-04-2039A1.pdf>

An excerpt of which is:

WRNN-TV Limited acknowledges that the early return of its NTSC channel
will result in loss of an over-the-air analog service, but contends
that the impact on the public will be imperceptible since, according
to Nielsen Media Research, there was no reportable over-the-air
viewing for the station for the month of April 2004. According to
WRNN-TV Limited, the New York City DMA has a cable penetration rate of
77.6% and a direct broadcast satellite (DBS) penetration rate of 10.9%.
WRNN-TV Limited represents that it will demand that the cable operators
initially carry WRNN-DT's over-the air digital signal in an analog
format, and provide the cable operators with the conversion equipment
necessary to translate the station's over-the-air signal from digital
to analog.

[ ... ]

In addition, the staff's engineering analysis using Longley-Rice
methodology shows that the area which will receive less than five
over-the-air signals is terrain blocked. Accordingly, these viewers do
not presently receive Grade B coverage from WRNN-TV. Finally, while
early return of WRNN-TV Limited's NTSC channel will result in the loss
of the sole analog service licensed to Kingston, WRNN-DT is presently
operating pursuant to an STA and viewers in Kingston will continue to
be able to view that signal with the necessary DTV reception equipment,
as well as at least four alternative over-the-air analog signals.

Isn't WRNN-TV's argument exactly the same as "Ferree's plan"?

Anyway, I would take the rationale used by WRNN-TV as a good reason
to take *all* of their OTA spectrum back. There's no indication
that they intend to make their DTT viewership any greater than the
(supposedly) zero viewership of their analog OTA signal.

Isn't this spectrum supposed to be "too valuable"?

Based upon the foregoing, while WRNN-TV Limited has not met all of
the factors necessary to come within the rebuttable presumption,
we believe the public interest would be served by permitting
WRNN-TV Limited to surrender its license for NTSC Channel 62 and
commence digital operations on DTV Channel 48. Accordingly,
WRNN-TV Limited's request IS GRANTED.

I'm not sure what condition they haven't met to allow for
analog shutdown, if there's no viewership. But the FCC isn't
going far enough.

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