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 ---------------------------------------------------------------------- You can UNSUBSCRIBE from the OpenDTV list in two ways: - Using the UNSUBSCRIBE command in your user configuration settings at FreeLists.org - By sending a message to: opendtv-request@xxxxxxxxxxxxx with the word unsubscribe in the subject line.