As explained in the attached position paper, ATSC firmly believes that there is no need to reconsider the VSB transmission system. ATSC VSB Transmission: The Right Choice for U.S. DTV Broadcasters Dissenting Position: Sinclair Broadcasting is lobbying broadcasters to reject the ATSC 8-VSB digital transmission system in favor of an alternative developed in Europe, COFDM. Sinclair argues that VSB is inadequate, that COFDM is better, that broadcasters should effect a change in technology as soon as possible, and that such a change would represent only a minimum disruption to DTV implementation. ATSC Position: The Sinclair position is unwarranted and irresponsible.

It is unwarranted because a growing body of evidence supports the performance of the VSB transmission system, and there is no clear evidence that COFDM is better. It is irresponsible because it seriously understates the impact of a change. U.S. broadcasters and manufacturers have already made a very substantial commitment to VSB. VSB transmission has been deployed by about 70 broadcast stations to date, the signals of which reach about 50% of the nation's television viewers, and those numbers continue to increase rapidly. A growing body of measurements reinforces the wisdom of the selection of VSB for U.S. DTV. Are there problems? Sure. Are the problems being addressed.

Yes. Can we do better? Yes we can. Is there a basis to give up on VSB? Absolutely not. The best path is to continue to put our energy into improving and optimizing the overall VSB transmission system, to ensure the success of the DTV transition. VSB Reception: Extensive test documentation shows that VSB has performed better than expected with respect to outdoor reception. More questions surround indoor reception, however. Indoor reception has always provided a challenge, for both analog and digital television services.

To date, indoor reception performance for VSB has been less well documented, but increasing attention is being paid to it. While the data taken is promising, there is much work to do, and improvement is needed and expected. Some observed indoor reception problems can be tied to performance limitations of early DTV receivers. We are observing a substantial spread in performance of receivers, with some performing better than the benchmark Grand Alliance prototype, as anticipated, but others performing worse. As the products mature, improved receiver performance, coupled with improvements in indoor antennas, will go a long way towards addressing indoor reception concerns.

We emphasize that there is no concrete information to suggest that COFDM indoor reception would be better. There is substantial information to show that VSB provides superior outdoor reception. We believe it will be shown that VSB provides superior indoor performance as well. Analog vs. Digital: As a rule, whenever analog reception in a given channel is reasonably good, VSB reception in that channel is perfect. As the analog signal degrades, VSB will continue to provide perfect pictures. But there are some situations where consumers watch very marginal analog signals, and in some of those situations VSB is not receivable. Once again, there is no concrete information to suggest that COFDM reception would be better.