Sinclair Broadcast Group Response to MSTV/NAB COFDM/8-VSB Test, Recommending Phase Two Testing

0000The following letter is the response from Sinclair Broadcast Group to the MSTV/NAB COFDM/8-VSB Test which we reported on yesterday. In it they call for Phase II--additional testing using more representative receivers from COFDM sources (due to arrive, we hear on Sinclair's doorstep Monday). Behind the scenes deep and divisive criticism over the choice of the COFDM receiver used in the MSTV test has been voiced. There seems to be no-end to the controversy, and broadcasters, thinking they had cause for a decision with the MSTV results, are again faced with going onward on their eternal quest for truth. The idea introduced in this letter from Sinclair that continuing testing will keep a competitive pressure upon the 8-VSB camp would fall upon its own sword if Sinclair becomes successful in achieving COFDM DVB as a single standard that "rules" the world.

0000Is the controversy over, or just beginning? Manufacturers realized $1.5 billion in HDTV sales last year with almost no aid, indeed, much to the opposite, from the U.S. broadcast community. HDTV never did, nor does now, need broadcasting to drive it. It needs outstanding programs fit well to the medium. How those programs are distributed is inconsequential to a public who is interested in HDTV for its sole benefit--quality.

Dale Cripps

To: NAB and MSTV Boards of Directors

From: Sinclair Broadcast Group

Subject: Recommendation to Authorize Phase Two Testing

1. Phase One Effort Raises Questions. The Phase One effort to determine the relative effectiveness of 8VSB and COFDM as broadcast transmission standards has raised as many questions as it answered. While Sinclair has maintained for several years that 8VSB was not replicating our analog service, the test results confirming our assertions have come as a surprise to many members of the Testing Steering Committee. Using the acknowledged best receiver available, 8VSB could not be demonstrated to reach the same UHF audience as today's NTSC-based system. This was painfully clear when a comparison was made between the two standards using simple antennas at a six-foot elevation, inside the City Grade of the stations in the test. 8VSB could only be received at between 35 to 45% of the test locations while COFDM (operating a data rate higher than 8VSB) was received at double that rate. These results were obtained in spite of the fact that the COFDM receiver was suffering from certain "non-linear" distortions that could have had a serious detrimental effect on its ability to perform and were unrelated to the COFDM modulation system.

2. Receiver Front-end Deficiencies. At the thirty-foot test elevation we believe that 8VSB did not perform at a level that could be considered satisfactory as a standard for free over-the-air television, given today's consumer expectations. COFDM at the higher data rate also failed to meet our expectations. Given the 4db advantage that 8VSB may have over the tested configuration of COFDM in carrier-to-noise (C/N) performance, there was an observed advantage of 8VSB over COFDM in the far field. Having observed otherwise in previous experiments, we at Sinclair are concerned that the COFDM receiver's faulty front-end design may have seriously contributed to this outcome. In short, we believe there are legitimate reasons to suspect that the vast majority of the COFDM results are tainted by problems in the COFDM receiver's front-end that have nothing to do with the standard itself.

3. Deficiencies Require Definitive Answers. One of the objectives of this independently funded effort by our industry was to perform a scientifically sound study and publish a report. The questions raised by the late discovery of the COFDM receiver problem demand a further investigation to determine the impact of this problem before any final conclusions or actions can be taken. This fact alone strongly suggests we are not done and cannot close out the option to continue to a Phase Two effort. In fact, the first recommendation of the Engineering Committee is to investigate the impact of this problem, if a Phase Two effort is authorized. The first of a number of set-top boxes which have been manufactured to the requirements of the US market, taking into account the difficult nature of the RF environment, will be delivered in a matter of a few days. To not address this issue immediately and decisively, when solutions are at hand, can be viewed as being willfully negligent to the facts and disingenuous to the intent of this entire process.

4. Some Phase One Efforts Delayed Until Phase Two. The COFDM receiver problem is not the sole reason to authorize the Phase Two efforts. At the time funds were solicited from the industry, the contemplated Phase One effort was to include a test to determine the trade-off of data rate versus robustness of reception (lower data-rate yielding lower C/N requirement) using COFDM at a slightly lower data rate at all sites, including indoors. Unfortunately, in its zeal to evaluate the latest Zenith 8VSB receiver, the Engineering Committee agreed to postpone the lower data rate study until Phase Two. Sinclair and others agreed, at the time, to this "trade off" with the understanding that Phase Two would be undertaken. It is essential for us to fully understand the trade-off between ease-of-reception and data rate in varied conditions. This assumes even greater importance given the poor performance of 8VSB as compared to COFDM, in the area of ease-of-reception by simple antennas.

5. Future Business Options Should Be Preserved. Our industry is under competitive attack from many quarters and our future competitiveness demands that we understand what options we may have in order to respond to these attacks. G3 is an example of future competitive attacks given that that technology will be able to deliver data-rates of 2 million bits-per-second, supporting a wide variety of directly competing programs and services. Portable and mobile applications may become extremely important to us as means to protect our economic health and we should not preclude these as options in the future ñ near or distant. The days of simply delivering a picture to a fixed home receiver connected to an outdoor directional antenna passed us by decades ago. As just one example, there is an emerging industry that is focused on the delivery of data services to automobiles. It is estimated that such applications will be a $50 billion a year business in just five years. Given the broadband delivery capability inherent in our DTV signal, we should not willingly be excluded from this or any other emerging market. A Phase Two effort should be structured to investigate this and other applications for our spectrum. It is generally agreed, even by the ATSC organization, that today's 8VSB is not capable of providing a portable component, let alone a mobile one. Thus, we at Sinclair are strongly committed to investigating these and other reception applications that use simple antennas. We strongly urge the NAB and MSTV Boards to recognize the very real threats to our industry and to authorize a Phase Two effort to flesh out the possibilities that await us in both 8VSB and COFDM.

6. Principle of Maximization Not Yet Considered. Another and equally compelling reason to proceed with the Phase Two effort is the impact of operating COFDM at a power level that will give it the same coverage capability as 8VSB. The study conducted in Phase One was limited to determining the interference effects of COFDM operating at the same assigned power as 8VSB. This study revealed, contrary to allegations from some sources, that there was no meaningful impact on today's NTSC by the use of COFDM. In short, no DTV Table of Allotment issue is raised by the use of COFDM at the FCC's originally assigned DTV power levels. However, the FCC has authorized DTV stations to maximize their power levels as long as they do not exceed a defined level of new interference. For example, WBFF-DT in Baltimore is assigned 50kW. Under the Principle of Maximization, WBFF-DT can increase its power level to well over 500kW. Thus the coverage provided by COFDM can certainly be made equal to that of 8VSB. In addition to the similar coverage area, a broadcaster using COFDM would also have the added advantages of ease-of-reception and portability options demonstrated in Phase One testing (not to mention the possibility of mobile service that we know is not available with 8VSB). The option of any single broadcaster to choose these configurations is a business decision that should not be eliminated in an attempt to preserve exclusive reliance on 8VSB as the sole transmission method. A Phase Two effort to more precisely understand the opportunities that COFDM offers is an essential step to buttress broadcastingís defense against the encroachment of competitive services.

7. Promised 8VSB Improvements Have Yet To Materialize. The slow progress in 8VSB receiver improvements and the string of broken promises from the chip and receiver manufacturers should give us pause and concern. The 8VSB enhancement report, that was part of Phase One, did little but to repeat the same hackneyed statements that were put forward almost two years ago. Sinclairís efforts to introduce COFDM as an alternative to, but not a replacement of, 8VSB were blunted by these same grand promises of successful laboratory simulations and soon-to-be created ìmiracle chipsî that never materialized. The fact that any 8VSB performance progress has been made at all can be attributed to the fact that COFDM was being considered by our industry. We believe that only as long as we continue to investigate COFDM and consider it as a legitimate possibility then the 8VSB camp will continue meaningful development efforts. We are concerned, as the entire industry should be concerned, that to remove this competitive element from the scene will do nothing but eliminate the single most powerful motivation to improve 8VSB performance: that is, competition. In addition, there are no assurances that given the continuing lack of real demonstrated 8VSB improvements in ease-of-reception, portability and mobility that we will not be revisiting this subject three years from now. A continuing COFDM research effort and possible implementation will give our industry and our businesses a ìsafety netî if the promises coming from the 8VSB camp are again broken.

8. Redoubled Efforts Send Strongest Message to Washington. These tests have proven conclusively that the inflexible ATSC standard, as currently configured, does not support the broadcasters' requirements nor does it come close to replicating the level of service available with today's analog service. In fact, these results give us no hope of any dramatic increase in consumer adoption of DTV. To stop our industry-initiated efforts, to accept the status quo, and to rely on interests outside of our industry (i.e. the consumer electronics industry) to make good on promises they have yet to keep only sends the wrong signal to the Washington policymakers. We have already been under assault by those on Capitol Hill and at the FCC, and by adopting a ìmaybe it will get betterî attitude signals that we are not doing everything in our power to successfully rollout the DTV service. Instead, a consolidated industry commitment of time, effort, money and manpower sends an unassailable message that we will spare no expense and overlook no option in order to deliver the best possible DTV service to the American consumer and to return the analog channels as quickly as possible. Anything less will risk the loss of our spectrum when Congress realizes the rollout has failed and we did not try our best to save it. Our competitors will be the first to highlight our laissez-faire attitude.

9. It's The Sponsorship, Not The Phase Two Testing That Is Up For Debate. Finally, this matter is so critical to our business plans and our industry survival, that Sinclair firmly believes that individual station groups and broadcasters will take up the effort and continue to press for a transmission standard that meets our requirements. As this will likely happen, the question for both Boards is should this quest happen within the already existing operating structure of this program? Further, to the extent that there are those who wish no longer to participate, those that do should be given the opportunity to provide the additional funding to find the final truth as they relate to broadcasters requirements. We should point out that these are the same requirements that even the ATSC organization recognizes as legitimate and are the same requirements that the ATSC admits cannot be met with today's DTV standard using 8VSB. The ATSC's own VSB Performance Ad Hoc Group has urged the committee to ìinvestigate DTV transmission system alternativesî and that "[it] is not known whether it is theoretically possible, and therefore it is not clear how or when 8-VSB receivers could meet certain broadcaster requirements without changes to the standard."*

10. Unified Industry Effort Is The Most Desirable Outcome. A continued unified industry effort to resolve recognized problems may invite outside scrutiny, but it is the only action that will insulate us from serious attack while we toil to get our digital house in order. Therefore, in the interest of a unified industry and the future health of our companies we urge you, the members of the NAB and MSTV Boards of Directors, to support a continuation of the effort started, but not yet completed, in Phase One. We urge you to authorize a meaningful Phase Two effort to determine the true capabilities of COFDM and to further 8VSB enhancement efforts in light of our industry's stated requirements.

Lastly, while the majority of the participants in the steering committee may be well-heeled, there are many more interested broadcasters who are not. The economics of their DTV business must be considered as materially more tenuous than larger groups. We have an obligation to them regardless of whether they contributed to this process and must be given the maximum opportunity to compete and not be straddled with a standard that because of its lack of functionality may cause their ultimate downfall.

Thank you.



*Performance Assessment of the ATSC Transmission System, Equipment and Future Directions: Report of the VSB Performance Ad Hoc Group to the ATSC Task Force on RF System Performance (Version 4.3) Executive Summary.