Sinclair's David Smith Refutes CEA's Gary Shapiro on COFDM vs. 8-VSB DTV Modulation

Gary Shapiro sent a letter to broadcasters this week repeating the same old themes that have already been proved false. Like every other time, he has not offered one shred of data to support any of his claims (whereas, the Sinclair website is filled with technical data supporting our assertions). In the interest of open and honest discourse, Sinclair has addressed each of Shaprio's points. For your convenience, I am providing our response:
--Mark Hyman

November 19, 1999

Dear Broadcaster:

On November 15, 1999, Mr. Gary Shapiro, President of the Consumer Electronics Association ("CEA"), sent you a letter concerning your support for Sinclair's Petition for Expedited Rulemaking ("Petition"), which urges that the Commission grant DTV broadcasters the flexibility to transmit their digital signals using either COFDM or 8-VSB digital modulation technology. Mr. Shapiro fills his letter with intentional misstatements and blatant scare tactics, and this rhetoric is further evidence of CEA's desperation to avoid a reasoned examination of the issues raised by Sinclair and others. Your continued support is crucial to the success of the Petition, and we urge you not to be misled by manufacturers' self-interested attempt to derail this broadcaster-based effort to maintain free over-the-air broadcasting as a viable, independent means of distributing television programming. Below, we briefly refute CEA's various misrepresentations about COFDM:

- CEA says that COFDM "[i]s not currently standardized to work [over] a 6 MHz channel." While there is not yet a 6 MHz COFDM "standard," COFDM signals can clearly be transmitted over 6 MHz channels -- Sinclair's own tests were conducted over a 6 MHz bandwidth. In fact, COFDM could support 6 MHz data rates as high as approximately 24 Mbps (compared to the permanent, inflexible 19.4 mbps for 8-VSB), and would allow broadcasters to vary their data rates (4 to 24 Mbps) to achieve a wide range of operational modes. Accordingly, Sinclair's Petition asks that the Commission establish a COFDM Task Force to integrate COFDM into a U.S. DTV standard

- CEA claims that COFDM "could radically reduce signal reach in rural areas." Sinclair disagrees with this assertion. As explained in Sinclair's Petition, the signal decodability gap between today between 8-VSB and COFDM under real-world conditions is just 2 dB, which results in no material difference in the reception coverage of 8-VSB and COFDM signals. Indeed, Sinclair tested 8-VSB and COFDM reception at the fringe of the broadcast coverage area, and their performance was approximately equivalent.

- CEA claims that COFDM "[m]ay increase broadcaster transmission energy costs as much as ten fold." In fact, Sinclair believes that COFDM operations would not lead to any significant increase in broadcasters' average energy costs or other operational expenses. As described above, Sinclair found no practical, real-world difference in reception coverage between COFDM and 8-VSB, and Sinclair believes that no substantial power increase would be necessary to maintain equivalent DTV coverage. Moreover, Sinclair and its supporters are only requesting that broadcasters have the flexibility to use COFDM, and any costs incurred in broadcasting a COFDM DTV signal would therefore be borne voluntarily.

- CEA claims that COFDM "[h]as been rejected repeatedly in U.S. testing." In fact, COFDM has never been adequately considered in the U.S. ACATS summarily rejected COFDM in 1994 because it was "not ready" for testing at that time, and neither ACATS nor the Commission has ever made any effort to compare the reception of COFDM and 8-VSB through simple indoor antennas in a complex, dynamic multipath environment, despite the fact that such viewing conditions were and are the most common for over-the-air broadcast service. Since 1994, COFDM technology has advanced quickly and has far surpassed the capabilities of 8-VSB.

- CEA says that COFDM "[p]rovides inferior protection from impulse noise interference." In fact, while impulse noise was shown to be a problem for one early implementation of the COFDM-based DVB-T standard, this problem was resolved, and there is now absolutely no technical basis for concluding that a COFDM-based alternative DTV standard in the U.S. would be more susceptible than an 8-VSB standard to interference from impulse noises.

- CEA claims that COFDM "[p]rovides inadequate protection against adjacent and co-channel interference." With this assertion, CEA ignores the specifics of Sinclair's proposal, which requests that the Commission establish a COFDM Task Force to determine the interference ratios for COFDM transmissions into existing NTSC and 8-VSB DTV signals. Under Sinclair's proposal, a broadcaster would not be permitted to initiate COFDM operations until it demonstrated that it would not cause interference to existing NTSC and 8-VSB DTV broadcasters.

Thus, CEA either lacks a basic understanding of the capabilities of COFDM -- technology which Sinclair has described repeatedly in its filings -- or purposefully distorts the truth to further the narrow, short-term interests of the manufacturing community. In fact, the current, enormous advantages of COFDM for the provision of reliable, ubiquitous DTV service are fully demonstrated, and we trust you will continue to support our request for a flexible modulation standard. COFDM today permits far superior reception in urban areas and also allows for mobile and portable DTV applications, and these are just two of the factors that have led the majority of countries around the world to adopt COFDM as their sole modulation technology. Given this reality, shouldn't broadcasters in the U.S. at least have the option to use COFDM? While CEA says no, we encourage you to respond to Mr. Shapiro with a letter that makes clear your continuing support for the Sinclair Petition.
Sincerely,
David D. Smith,
President/CEO