[opendtv] Re: Community Broadcaster's Association wants converter boxes to handle analog, too!

  • From: "John Willkie" <johnwillkie@xxxxxxxxxxxxx>
  • To: <opendtv@xxxxxxxxxxxxx>
  • Date: Sat, 17 Nov 2007 14:26:42 -0800

Bob miller said:

"Met with the FCC LPTV person in 1999 with the request that LPTV
stations be allowed to use DVB-T and was told first that digital rules
for LPTV would be issued by Christmas of that year and that there was
no reason that he could see not to allow other modulations like DVB-T
on LPTV stations. Since by definition LPTV stations cannot interfere
with FPTV stations that seemed reasonable at the time. Within a few
months, as I remember it, the Sinclair controversy erupted and all
chance of LPTV stations being allowed to use COFDM vanished."

1999 was perhaps too early, and in the heat of the battle, but you didn't
need any interpretation from Hossein (an engineer, not an FCC attorney) to
read Part 74, subpart G (LPTV and TV translator rules).  

They provided then, only slightly modified 6 years later, that as long as
envelope limits were met, one could employ any "modulation technique
permitted by the commission" in LPTV/Tv Translator service.

Once the commission approved the first use in any service of OFDM
modulation, you could use it in part 74 without EVEN NOTIFYING THE
COMMISSION.  You chose to ask permission. Years ago, I told you that was
foolish, because in 1999 was the heat of the battle, and the FCC KNEW that
this loophole existed. (or, would exist, I'm not sure when BAS and other
services were permitted to use OFDM.)

Within it's rules and practice and procedure, the FCC could do nothing to
stop your usage of OFDM once it was approved in any service.  I suspect that
getting financing would be an issue, but not one that pertains to the FCC,
but the courage of your investors (a class never known for courage.)

Now, you work with Richard Bogner, and I believe that his hybrid 8-VSB/FM
operation on channel 6 in NYC (with the FM on 87.9) seems to comport with
FCC rules (not necessarily interference issues) at the present time.
However, I am not prepared to say that is the case after the sunset of
analog.  (I'll be fuzzy about whether this pertains to the sunset of analog
for FSTV or LPTV.)  I do believe that the interference issue is likely to
come to the forefront first.  The interference issue doesn't seem to apply
to 87.7, but not all radios tune in that frequency.

The only conclusion I can draw from your meetings with FCC commissioners and
staff is that you only hear what you want to hear.  There was no rational
reason to keep NTSC alive after PAL was adopted, except for the installed
base of receivers and the off-shore aspects of PAL.

John Willkie

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