On Jan 28, 2015, at 6:10 PM, Manfredi, Albert E <albert.e.manfredi@xxxxxxxxxx> wrote: > > What does this have to do with the fact that the FCC puts a cap on the > national footprint of OTA station groups, not on DBS, and not on the TV > networks either? You cannot assume a correlation between TV networks and OTA > station groups, Craig. TV networks have huge coverage because they make use > of multiple distribution media, which shows even more why the national > coverage cap on station groups is so silly. The cap on TV station ownership was put in place to prevent the broadcast networks from controlling the distribution of TV. The network O&O stations have run at or slightly above the cap for decades. Station groups are a more recent phenomenon, but are limited by the same ownership cap. It is relevant that the FCC issues licenses for TV stations - that is one of their primary jobs. They do not directly regulate MVPDs, nor are there ownership caps on MVPDs. TV stations have huge coverage because it is required. No other content is required to be carried on any distribution infrastructure. > > Using the "voices heard" argument: Is it logical to get antsy if a station > group has more than 39 percent theoretical coverage, when opinion pieces > aired from the TV networks can reach 100 percent of the population > regardless? More precisely, does anyone really believe that Sinclair and > Gannett generate more political opinion programs than do Fox, ABC, and the > other TV networks, so that it's most important to rein in the station groups > wrt nationwide coverage, but not the TV networks? I agree the logic behind the caps is no longer relevant. > > "Huge percentage market share" not on their OTA signal, and not content > generated by the stations either. These audiences are after **TV network > programming**, Craig, using many distribution media. Just the same as > audiences are after ESPN, HBO, or any other MVPD-only content source. It's > silly to keep rules which pretend the local broadcasters are creating all > this content. Their role is mostly distribution, and also local news/weather > for a small percentage of air time. The rules never expected stations to be major content creators. They were put in place to balance the power of the three major networks. And it was not just ownership caps. The FYN SYN and prime access rule were created to encourage a competitive content creation marketplace from which stations could license content. The prime access rules gave syndicators access to time slots with relatively large audiences that had been controlled by the broadcast networks. The more important issue to discuss is whether we need to allocate any spectrum for TV broadcasting? > > Again, broadcast stations are not TV networks. (And OTT or TVE might help > with "anywhere," PERHAPS, but MVPD on demand schemes, i.e. in-network DVR > service, predate the availability of OTT service to the vast majority of > households. Once again.) The discussion was not about the stations. The discussion was about the changing technology that is causing a large decrease in the number if homes that watch live linear streams from the broadcast networks. Stations are only relevant in that their only business is delivering the live linear streams - they could have moved into the data broadcast business and created platforms to which they could deliver programs to local storage for anytime consumption, but did not (in retrospect this was probably a short term opportunity). > > Again, that's network content, not OTA broadcaster content. The same exact > content whether the viewer gets it from cable, DBS, OTA, or potentially even > online (although as of now, the networks don't stream in "live"). The > pretense that the TV networks content is created by the broadcast stations, > and that coverage limit rules must be applied to broadcast stations, is pure > silliness. The rules were put in place to limit the power of the networks Bert. Yes they are antiquated. The question now is how to best use the spectrum to serve the public interest. Me thinks the politicians and regulators have lost interest in TV, seeing big dollar signs in wireless broadband. > > First point is, 20 percent isn't such a small number. There is something to be said for maintaining a FOTA option. But FOTI is also an option. > Second point is, the OTA model is apparently self-sustaining, with ad > revenues, so it's not like it's a big burden. This is questionable. It is only viable as long as stations have high quality content like network shows and sports. Take that away and the ad revenues dry up. Independent stations and LPTV stations are mostly struggling. > Third point is, the TV networks are also using FOTI distribution, which > emulates the linear FOTA distribution, but provides VOD. I have to conclude > that these extra options, to maximize household coverage for TV network > programming, in addition to walled garden distribution, is worth its cost to > the networks. It is not a question of cost, it is a question of eyeballs, which drive ad revenues. The networks now must accumulate their audiences across multiple distribution media. > A bit of a distinction without a difference, though, Craig. These TVE > programs are not always available to all MVPD subscribers, right? They are not available if you do not subscribe to the linear service. Hence you cannot access HBO Go unless you subscribe to the HBO premium tier, and you cannot access Watch ESPN, unless you subscribe to the extended basic bundle. Also, the MVPD that you buy your content from must have a license and interconnection agreement with the TVE site. This allows the TVE site to verify your authentication credentials. > The list of optional MVPD credentials is different, for different shows. So > in effect, you are artificially tied to your particular > neighborhood/county/whatever, even though this makes no sense at all for > Internet access of content. This is an industry initiative involving both the content owners and the distributors. It is their migration strategy to OTT delivery of today's linear channels. I am not aware of TVE being "show based." It is based on what the content owner makes available via their TVE sites - usually all of the shows from that channel. The only geographic limitation is the MVPD providers in any geographic market; the TVE sites are part of the Internet, and are generally not limited geographically, other than for content with geographic restriction like many sporting events that have associated blackout rules. > >> It is not a legacy impediment, > > What do you call it, when access to Internet content is limited by the owner > of the legacy TV coax cable that may or may not exist in your neighborhood? A subscription. And it is not limited by a coax. I can get TVE credentials from Cox, DirecTV, Dish, and soon Sling. Regards Craig ---------------------------------------------------------------------- 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.