[opendtv] Re: FCC comments on DTT reception

  • From: Mark Aitken <maitken@xxxxxxxxxx>
  • To: opendtv@xxxxxxxxxxxxx
  • Date: Wed, 14 Dec 2005 16:47:04 -0500

Yes, we have been trying to ingest the document for the last several 
days. Our continuing message to Congress (the folks that drive the FCC!) 
is simple. Read this report addressed to you, then make the FCC finish 
its tuner mandate work (namely, specify performance requirements)!
Among other interesting facets of the OET discussion, the graph on page 
34 details a large discrepancy in performance for a large variety of 
receivers/tuners/converters based on multipath performance. While the 
focus of discussion in this report is whether (or not) coverage 
assumptions made by the FCC are relevant (they argue yes), the body of 
data gathered can paint a picture similar to the focus of many previous 

While it is possible to develop/market/sell DTV 
receivers/tuners/converters that work well (at least some prototypes 
show promise!), there is NO MANDATE that they do so, any many fall 
short! The fact that only ~ 1/3 of the tested units (from this report) 
are capable of reception in this stated example (multipath environments) 
adequately is a vivid portrayal of the realities WITHOUT a mandate for a 
minimum performance requirement.

Additionally, while the CEA and most of its members tend to throw up the 
ATSC A/74 "Recommended Practices" document as proof that there is no 
need to specify performance requirements, the facts that the above OET 
document shed light on tend to show otherwise. "Recommended Practices" 
are NOT enough to ensure that the American public have ready access to 
well performing DTV receivers/tuners/converters.

A recent article that has been recently posted here 
puts into perspective the need to go /*beyond*/ the ATSC A/74 
"Recommended Practices" document. While it is argued that the ATSC A/74 
"Recommended Practices" is the baseline, issues such as real world 
ability to perform well with multiple high power signals present are not 
even spelled out in the recommended practices.

The whole body of evidence available today suggests that, YES!, it is 
/*possible*/ to develop/market/sell DTV receivers/tuners/converters that 
works reasonably well! The experience of the Broadcast community is 
that, while possible, there is no reasonable expectation that the few 
products put into the hands of Americans today /_will_/ work in the 
majority of locations, most of the time, with simple antennas.

If the expectation of Congress is that DTV receivers/tuners/converters 
WILL work for most Americans (a requirement to complete an ill-guided 
transition), it is my opinionated suggestion that performance 
requirements be placed on ALL such products, not simply the "digital to 
analog converters" being looked at for subsidy. The future ability to 
reach into American homes with "Over-The-Air" television under any 
circumstances is surely at risk otherwise.

Mark Schubin wrote:

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><>   ><>   ><>   ><>   ><>   ><>   ><>

Mark A. Aitken
Director, Advanced Technology

<><   <><   <><   <><   <><   <><   <><

Sinclair Broadcast Group
10706 Beaver Dam Road
Hunt Valley, MD 21030
Business TEL: (410) 568-1535
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If mankind were to resolve to agree
in no institution of government,
until every part of it had been
adjusted to the most exact standard
of perfection, society would soon
become a general scene of anarchy,
and the world a desert.

~ ~ ~ Alexander Hamilton ~ ~ ~


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