Arlington, Va., October 14, 1999 - The Consumer Electronics Manufacturers Association (CEMA) today filed a Motion for Immediate Dismissal with the Federal Communications Commission (FCC) in response to a proposal submitted earlier this week by Sinclair Broadcasting. CEMA's Motion urged the Commission to avoid a "costly, dead-end path" of reopening the digital television (DTV) standard approved in 1996.
"The standard has been in place for nearly three years and the transition to DTV is well underway. To revisit the standard now would cause delay DTV," said CEMA President Gary Shapiro.
According to CEMA's Motion, the Sinclair petition is repetitive and raises technology issues already addressed in the ten-year standard development process. Regulatory intervention at this point, argues CEMA, would cause uncertainty and confusion and would not serve the public interest.
"The standard was established to provide broadcasters and manufacturers with the certainty they needed to move forward with the transition. Billions of dollars have been invested since 1996 to bring the benefits of DTV to consumers -- to consider adding a new standard at this point would put us back to square one," said Shapiro. "Indeed, over 300 million dollars of 8VSB consumer equipment has already been sold."
CEMA indicated that solutions were available to address reception issues outlined by Sinclair. "Recent chip sets from several manufacturers provide excellent reception under many difficult multipath circumstances."
"It is ironic that Sinclair's petition is now calling for the creation of multiple broadcast standards. That directly contradicts Sinclair's position outlined in a white paper during the development process - that multiple standards would drive up consumer costs while causing delay and confusion in the marketplace," stated Michael Petricone, CEMA's director of technology policy. "If a technical problem actually existed with the 8 VSB standard, CEMA would be in the vanguard petitioning for a change," Petricone continued. Our members have every economic incentive to ensure that all Americans can enjoy the benefits of DTV."
The Motion is available in PDF format at www.CEMAcity.org.
CEMA is a sector of the Electronic Industries Alliance (EIA), the 75-year-old Arlington, Virginia-based trade organization representing all facets of electronics manufacturing. CEMA represents more than 500 U.S. manufacturers of audio, video, accessories, mobile electronics, communication, information technology and multimedia products that are sold through consumer channels.
CEMA also sponsors and manages the International CES - Your Source for Workstyle and Lifestyle TechnologySM. All profits from CES are reinvested into industry services, including technical training and education, product promotion, engineering standards development, market research and governmental and legal affairs support. As the first major technology event of the new millennium, the 2000 International CES is the launch pad for 21st century technology.
The following is the Executive Summary portion of the filing with the FCC. The full copy of the comments is available on the CEMA web site in .pdf format at:
FULL PDF COPY - Click Here
Look under Advanced Television and click on Comments to download the file.
EXECUTIVE SUMMARY
CEMA respectfully requests that the Commission decline to accept Sinclair's Petition for Expedited Rulemaking. The Petition fails to assert any valid basis for re- opening the digital television standards proceeding at this late date, and presents only arguments that are repetitive of those previously considered and that otherwise do not warrant consideration in the public interest.
CEMA is not anti-COFDM. Receiver manufacturers would be in the vanguard of parties petitioning the Commission to alter the 8-VSB standard if there existed a technical problem receiving signals using that standard. Rather, CEMA's members, many experienced in supplying both COFDM and 8-VSB television markets, believe in the advantages of 8-VSB in the United States for television broadcasting purposes. Common sense dictates that CEMA's manufacturers have every economic incentive to ensure that all Americans can enjoy the benefits of DTV.
Re-opening the proceeding on a DTV standard years after its adoption by the Commission will benefit no one but the handful of broadcasters desiring to delay the transition to digital broadcasting. No matter how some may attempt to cast the issue, opening a proceeding - particularly a needless proceeding such as is the one requested by Sinclair - would create the type of uncertainty that will inhibit purchasing equipment and financing new and improved products and programs. Such a proceeding also will delay by years the recovery of spectrum mandated by Congress at the end of the digital transition, harm consumers in foregone services, and substantially disadvantage hundreds of companies and tens of thousands of consumers that have committed to digital broadcasting and services.
CEMA concurs with the conclusions of the Commission's expert technical staff in its recent comprehensive DTV survey and analysis. In its report, the Office of Engineering and Technology technical experts concluded that test results indicate that 8-VSB DTV service availability approaches that of NTSC service and will exceed it in the near future. The Office therefore concluded that the 8-VSB DTV standard should be retained.
In its Petition, Sinclair refers only to generic COFDM modulation. It fails to set forth the detailed technical specifications on the level of the DTV standard adopted by the Commission in 1996. The lack of technical detail prevents direct comparisons and precludes interested parties from filing informed comment knowledgeably comparing the attributes of the DTV Standard to those of whatever standard Sinclair would like adopted to supplement the Commission's DTV standard. It also prevents the Commission itself from evaluating the comparative merits of a specific COFDM standard and the DTV standard in any meaningful way.
Not only does Sinclair fail to propose a concrete alternative standard, it also fails to acknowledge new chip developments related to 8-VSB. Recent chipsets from several manufacturers, including Nxtwave and Motorola, provide excellent reception under many difficult multipath circumstances. These actual chips are in the hands of manufacturers and other third parties.
The Sinclair Petition, if accepted, would deprive the public of the benefits of a single and certain DTV standard. A dual standard would harm consumers who already have purchased equipment (all ATSC-only) at a premium, with the expectation that their set be: (a) capable of receiving all of their existing over-the-air channels; (b) transportable to other locations without diminished or complete loss of functionality; and (c) capable of receiving over-the-air broadcasts for many years to come. Moreover, the uncertainty fostered by the Sinclair Petition understandably will dampen any decisions by those who have not purchased equipment - with devastating results for the DTV transition.
Sinclair's proposal would also inevitably lead to a multi-year standards-setting process. Indeed, there does not currently exist any COFDM system designed to operate within 6 MHz channels. Adopting a COFDM transmission standard would require settling on a data transmission standard, exploring impulse noise concerns, and studying interference characteristics. COFDM also is not demonstrated to be conducive to sharing with the incumbent NTSC co-channel and adjacent channel stations in the wide station distribution patterns generally found here in this country. At a minimum, COFDM standardization and testing will take significantly more time than staying the course and perfecting 8-VSB reception.
It is also extremely unlikely that the DTV Table of Allotments could accommodate the introduction of COFDM transmissions. This is a certainty if COFDM broadcasters seek to replicate existing analog service areas by either: (1) increasing power; or (2) constructing, connecting, and operating a single-frequency network consisting of multiple transmitter sites. This second scenario also would also force broadcasters to secure multiple tower cites and deal with the attendant construction and local zoning disputes.
The FCC selected the industry-recommended ATSC 8-VSB transmission standard in 1996 after an extraordinarily open, scientifically rigorous and painstakingly scrutinized peer-reviewed process that took an entire decade to complete. Sinclair raises no issue that was not carefully examined and decided during this process, including specifically, the relative multipath capabilities of both COFDM and 8-VSB. The FCC's exhaustive record on digital television more than fully documents both the industry's (through the ACATS and ATSC organizations) and the Commission's unanimous conclusions to adopt the 8-VSB standard.
In conclusion, as explained in detail below, the public interest requires that Sinclair's Petition be denied or dismissed without further comment or consideration. Doing so will prevent an obstacle being erected to the rapid roll-out of digital television and the concomitant recovery of valuable spectrum for other uses. There is no technical reason to do otherwise.
