[opendtv] Re: FCC rules for cable after the OTA TV digital transition

  • From: "Manfredi, Albert E" <albert.e.manfredi@xxxxxxxxxx>
  • To: <opendtv@xxxxxxxxxxxxx>
  • Date: Wed, 12 Sep 2007 18:40:56 -0400

John Shutt wrote:

> I didn't see anywhere in the admittedly brief press release
> where the FCC mandated digital carriage of anything.

Ah yes, another stretching of logic, like the time years ago when you
said that the FCC was not mandating any sort of OTA broadcasting after
analog shutoff. Remember that? Clearly, that wasn't the case then, nor
is it now.

The "no material degradation" means that any HD broadcast must be
transmitted as HD on cable, which is impossible in a 6 MHz analog cable
channel. Therefore, the FCC is mandating that the digital OTA channel be
retransmitted as digital over cable (main program only).

Conceivably, you might argue that stations that only transmit in digital
SD might meet the "no material degradation" by being repeated as
analog-only on cable. But I think that is really trying hard to twist
the meaning of this order.

Quote:

   The FCC's ruling today allows cable operators
   to comply with the viewability requirement by
   choosing to either: (1) carry the digital signal in
   analog format, or (2) carry the signal only in
   digital format, provided that all subscribers have
   the necessary equipment to view the broadcast
   content.

Notice that in (2) they say "only in digital format." Since they didn't
include the word "only" in (1), one must conclude that they mean "also
in analog format." Which I'll bet you a whole heap of money is exactly
their intent. Ask them, John. You can ask for clarification.

> There was no mandatory simulcasting of analog and digital
> in the order, hence no burden. If the cable operator
> chooses to carry the digital, that's their prerogative,
> and if they do then they are required to not degrade the
> digital quality beyond what they do to other digital
> channels.

Not what it says. There must be no material degradation, but they are
also saying that for example, any OTA HD can be carried at the same
quality level as other cable HD channels. This is not to say that OTA HD
can be carried as SD over cable. Again, read the actual words with the
intended emphasis on "HD":

Quote:

   While the item provides cable operators with
   flexibility, the FCC reaffirmed the requirement that
   cable systems must carry high definition ("HD")
   broadcast signals in HD format and reaffirmed its
   current material degradation standard. Cable operators
   must carry broadcast signals so that the picture
   quality is at least as good as the quality of any
   other programming carried on the system.

Go ahead and ask them. I'm sure you already know what the answer will
be.

> So if is a cable system that requires every subscriber to
> have a digital STB, then they can carry the primary in digital.
> Otherwise, if even one subscriber receives just an analog
> lifeline basic tier service, then the cable system must carry
> the primary of all broadcasters in analog.

That would be degrading all the OTA HD channels. You can only make that
argument in markets in which broadcasters only transmit SDTV, and
PERHAPS get away with it.

The clearly intended reading is that digital OTA signal must be carried
in digital format over cable, main channel only, but that this is not
necessarily meant to be bit-for-bit identical to the OTA signal. And
that analog may either be simulcast or D/A conversion provided locally
for analog subscribers. Adelstein's comments also reinforce this
reading, by the way, when he explains that bits that humans can't
possibly discern don't need to be replicated.

Any bets on this?

Bert
 
 
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