ATSC Chairman Robert Graves Defends DTV Standard in Letter to Congressman Billy Tauzin

by Robert Graves, Chairman, ATSC
Sunday, March 29, 1998

The ATSC has come under pressure from various groups contending that the ATSC/FCC standard does not optimally fulfill the needs of both broadcast and computer functions, and, therefore, the public. ATSC Chairman Robert Graves has stepped up to defend his organization's conclusions.

In the letter below he approaches Congressman Billy Tauzin to ward off any Congressional reactions to opposing positions.

His letter to Tauzin is followed by another discussing Sinclair's challenge of the 8VSB terrestiral transmission choice.

Dale Cripps
HDTV News Online

ADVANCED TELEVISION SYSTEMS COMMITTEE

Robert K. Graves
Chairmon

March 9, 1998

The Honorable Billy Tauzin
Chairman, House Telecommunications Subcommittee
United States House of Representatives
2183 Rayburn House Office Building

Washington, DC 20515

Dear Chairman Tauzin:

Recent press reports make clear that a few parties are making misleading statements and raising unfounded concerns regarding the implementation of digital television based on the ATSC Digital Television Standard adopted by the FCC in 1996. These same reports indicate your intention to look into these claims, and this letter is intended to clarify the issues involved and to dispel any concerns these false claims may have raised in your mind regarding the transition to digital TV.

The Advanced Television Systems Committee is a standards body comprised of 136 organizations representing all industry segments with an interest in digital television, including broadcasters, broadcast equipment manufacturers, consumer electronics manufacturers, cable TV organizations, computer companies, telecommunications firms, research institutions, etc. (A current list of our members is attached.) The ATSC includes all of the members of the Digital HDTV Grand Alliance who designed the prototype HDTV system upon which our digital TV standard is based. The ATSC also includes virtually all of the participants in the FCC's Advisory Committee on Advanced Television Service, headed by former FCC Chairman Richard E. Wiley, which recommended adoption of the ATSC Standard to the FCC.

At the direction of the FCC, ATSC documented the work of the Grand Alliance and the Advisory Committee, creating the ATSC Digital Television Standard. The ATSC also forged the industry consensus around the standard-definition television (SDTV) formats that were added (as directed by then FCC Chairman Reed Hundt) to the High-definition television formats already adopted by the Advisory Committee. (Ironically, the Commission later decided not to mandate any specific video formats in the digital television standard, leaving the issue to the marketplace.) In December, 1996 the Commission adopted the ATSC Digital Television Standard, except for one table that lists the specific video formats, leaving those decisions to the marketplace. However, the ATSC Standard in its entirety was adopted as a voluntary industry standard pursuant to our rigorous procedures in 1995, and it is this standard that broadcasters and receiver manufacturers are following as they work at breakneck speed to launch digital television service this fall in the U.S. The FCC's Advisory Committee and the Grand Alliance completed their work and no longer exist but extensive work to address implementation issues and to develop important extensions to the digital television standard continues in the ATSC, which has grown dramatically over the past two years. In light of our past and present work and the technical skills of our members, the ATSC is the best place to go to get authoritative information about the capabilities of the digital television standard now being implemented in the U.S.

The attached briefing sheets address two separate issues that have recently been raised with you and some of your colleagues. The first sheet refutes the false, misleading statement that the 1,080-line interlaced scan HDTV format will not work with computers, and also discusses the differences between HDTV and SDTV formats contained in the Standard. The second sheet refutes the uninformed suggestion that the transmission system adopted as part of the Standard is inadequate and is not performing as expected. It also rebuts the erroneous suggestion that a different system being planned for adoption in Europe would be more suitable for use in the U.S., and refutes the preposterous claim that changing transmission systems at this point would not entail lengthy delays.

Our overriding concern is that some parties appear to be trying to intervene directly with Congress, using false, misleading, and alarming claims, to achieve what they could not accomplish over the last ten years of debate, analysis, testing and industry consensus building using a process of peer review. The nature of such consensus building is that it is impossible to develop a solution that is considered ideal by every participant in the process (not to mention those who didn't fully participate, but show up at the last minute to raise unfounded concerns). After ten years of careful work by the industry and the Advisory Committee, with a thorough public review and rule making process by the FCC, Congress must not allow itself to be used to circumvent the industry consensus and FCC rules that have been adopted.

One other aspect of this latest false controversy bears mentioning. ATSC is currently conducting an active campaign to promote adoption of the ATSC DTV Standard in other countries. Widespread use of a common standard will mean wider availability of professional and consumer equipment at lower prices, thereby hastening the adoption of digital television here and abroad. Moreover, adoption of what is already a North American standard throughout South America, Australia, Asia and beyond, will have a positive impact on U.S. jobs and economic growth as we capitalize on the digital television technology pioneered in this ten-year process. In promoting our Standard, we are competing head-to-head with a European standard based on the digital technology first developed here, and the Japanese are now beginning to promote a third approach. In this international competition we have two great advantages: first, unlike the European standard, our standard is actually being implemented to provide HDTV as well as other digital services; and second, other countries can dramatically reduce their costs of implementing digital TV by aligning themselves with the huge, unfolding North American equipment markets. Thus, suggestions that somehow broadcasters should postpone the offering of true HDTV are troublesome, and the claim that the European @mission system is superior to our transmission system is particularly galling, because it is so untrue and so destructive to our international promotion effort.

We strongly urge you and your colleagues in the Congress to disregard the baseless claims that the Standard will not work with computers or that the transmission system is inadequate. A delegation of ATSC members and I would be delighted to meet with you at your earliest convenience to discuss these matters in more detail and to assuage any concerns you might have regarding the transition to digital television. We are confident that you and your colleagues will not allow yourselves to be homswoggled by false and misleading claims into undoing the careful work of the last decade, just before it begins to bear fruit for the American public.

Sincerely,

Robert Graves

cc:Chairman Tom Bliley
Representative John Dingell
Representative Edward Markey
Senator John McCain
Senator Ernest Hollings

ADVANCED TELEVISION SYSTEMS COMM11TEE

There Is No Need to Reconsider the VSB Transmission System

Robert Graves
Chairman, Advanced Television Systems Committee
March 9,1998

In a February 19 letter to Chairman Bliley and in several news publications, Sinclair Broadcasting Group has voiced great doubt regarding the adequacy of the YSB transmission system included in the A TSC Digital Television Standard and adopted by the FCC, especially as it relates to indoor reception. These concerns are entirely overblown, and there is no basis whatsoever for Congress or the FCC to reconsider the VSB transmission system or to otherwise delay the rapid introduction of digital television service.

Performance of the VSB Transmission System Is Fully Adequate and Exceeds Expectations

Many of Sinclair's misconceptions about the VSB transmission system contained in the ATSC DTV Standard arise because Sinclair chose neither to participate in the Advisory Committee process, nor to help guide, direct and fund the laboratory and field testing processes. In an effort to assuage their concerns, the ATSC has met with Sinclair to explain the results of the extensive tests that have been undertaken, including indoor reception results. Zenith Electronics, the developer of the VSB transmission system, has agreed to cooperate with Sinclair to support further indoor reception tests to help Sinclair satisfy its remaining concerns.

It is true that the extensive tests of the VSB system have focused primarily on outdoor reception, but Sinclair is simply mistaken in claiming that indoor testing was only added lately as an afterthought. Sinclair may have assumed that that recent tests conducted by the Association for Maximum Service Television (MSTV) in Washington, DC were the first and only indoor tests, when if fact, indoor tests were included in the testing conducted by the Advisory Committee in Charlotte, NC, during 1994 and 1995, and by in Raleigh, NC during 1997 with additional data still being collected. There are many reasons why indoor tests did not make up a larger proportion of the Advisory Committee's testing program, but one reason is that the large body of broadcasters who developed the testing process did not have the same vision that Sinclair now has that indoor reception is of paramount importance.

The Advisory Committee testing program and the subsequent tests in Raleigh were essentially aimed at ensuring that broadcasters could replicate their existing analog NTSC service coverage with the new digital signals operating at less than IO% of the NTSC power. Indoor reception with simple antennas is always more difficult, for analog TV, for VSB, or for any transmission system, because of the attenuation of radio frequency signals caused by building materials. With respect to indoor reception, the intent of the tests was to ensure that where viewers today can receive good analog pictures, they will also be able to receive near-perfect digital pictures, and the tests did indeed verify this performance. It is true that there will be some locations where viewers may tolerate terrible analog reception, but will not be able to reliably maintain digital pictures with simple indoor antennas. in these cases, viewers will need to install antennas in attics or on roofs, or take advantage of new, improved set-top antennas that we believe are likely to be introduced soon into the market.

We believe that Sinclair has over-reacted to various rumors about MSTV's additional indoor tests under way but not yet completed in Washington, DC. The DTV transmitter at WHD-TV in Washington is unusually low, only about 560 feet high, or about one-third of the height of the transmitters in North Carolina. This means that a much higher proportion of the test sites were obstructed by terrain. The fact that indoor reception of DTV was impossible for many of these terrain-blocked locations is not surprising, and does not indicate that the VSB system is inadequate. Indeed, the technicians collecting the data have been surprised at the number of locations where satisfactory reception did occur despite these challenging circumstances.

The VSB System Is Superior to Any Known System, Including COFDM

Sinclair's suggestion that the CDFDM system that certain European countries are planning to implement would offer better coverage is especially uninformed and is categorically wrong. Tests of the two systems show that the VSB system has a 4 dB advantage in white noise threshold, which means that the COFDM system would have to operate at 2.5 times the power to reach the same coverage area, and would result in much more interference to existing analog service and to other digital TV transmissions. White noise coverage doesn't necessarily tell the whole story, since a system's ability to handle a variety of transmission impairments could conceivably overcome this baseline advantage that VSB has over COFDM. However, we know of no data to suggest that this is the case. Side-by-side testing of the two systems has been conducted in Australia, but the test results have not yet been made public. We believe that when the results are released by the Australians, they will show a substantial advantage for the VSB system.

COFDM systems were considered at various stages in the FCC's Advisory Committee process, but in every case they were judged to be inferior for the DTV requirements that prevail in the U.S., and were ultimately rejected by the Advisory Committee We know of no reliable data to suggest that a COFDM system would provide better indoor reception, much less provide a superior overall transmission system for the U.S.

There Is No Basis Whatsoever for Changing the ATSC Transmission System

Although more indoor tests will shed further light on this topic, and perhaps guide improvements in receiver and antenna design, there is no basis for a concern that the VSB system will not provide adequate transmission coverage. VSB is by far the world's most thoroughly tested DTV transmission system, and its effective performance has been proven.

In some of its statements, Sinclair has claimed that changing the transmission system would not require lengthy delays in the implementation of DTV. This outrageous claim hardly merits a response. New proposals would have to be sought and evaluated, testing facilities and organizations established and funded, planning parameters and a new spectnirn plan developed, broadcast and consumer equipment designed, etc. All this would take at least three years and probably much longer, given the contentious nature of the process. And at the end of such a ludicrous detour, the nation would undoubtedly adopt the VSB transmission system again, because it has already been proven to be the best solution.

Sinclair's concerns regarding the adequacy of the VSB transmission system are entirely overblown, and there is no basis whatsoever for any delay in implementing the ATSC DTV Standard this fall, including the VSB transmission system.