On July 19th 1999 the Consumer Electronics Manufacturers Association, known as CEMA, filed comments with the FCC proposing a new broadcast service called Mobile Multimedia Broadcast Service or MMBS. The CEMA proposal suggests that the current UHF broadcast channels from 60 to 69 be used for this service after the return of our analog spectrum in 2006.
CEMA proposes that this new service will provide "a plethora of services" that would include audio and "ensembles of five or more program and data channels"(assume video), "news and information services" and that it would provide "robust and interference proof reception in a mobile environment".
The modulation system recommended by CEMA that will enable this new service is COFDM. Quoting from the CEMA submitted docket number 99-168, "Past studies have demonstrated the advantages of coded orthogonal frequency division multiplex ("COFDM") modulation to overcome difficult mobile multipath reception environments successfully." One might substitute "dynamic" for "mobile" and you would have the propagation situation Sinclair has encountered in the urban areas in and around Baltimore. We have also seen the robust nature of COFDM and so have more than 100 representatives who came to witness our testing.
The CEMA FCC filing goes on to point out in the next paragraph that CEMA commissioned a study in 1997 that studied the capabilities of COFDM. They append this study to the filing to support their conclusions about COFDM. Thus the outcome of the Baltimore tests should be no surprise to CEMA.
What is particularly interesting about the timing of this filing is that CEMA also launched, almost simultaneously, yet another attack on Sinclair in a release asking the industry to ignore the tests in Baltimore because they are simply a "demonstration". What was demonstrated was the total failure of the products that CEMA's members have launched into the public marketplace. In light of this filing it seems more than disingenuous of CEMA to take such a position. CEMA goes on in their published attack to imply that Sinclair should be ignored because Sinclair has been opposed to HDTV and has its own agenda. It is now clear that the hidden agenda is CEMA's.
What does all this mean?
It seems that CEMA and its partners are the ones with an agenda and it is a dangerous one for broadcasters. If CEMA can keep the traditional TV broadcast community's attention diverted by continuing to focus it on the single idea of HDTV using 8VSB they will have a clear route to the creation of a new service that would stimulate their revenue and profits at the expense of ours. Perhaps they now see that HDTV is not going to sell big screen, high profit margin, sets to the public at the rate they need to bail themselves out financially, but they see instead that a cheap receiver for music, data and SDTV for today's sets and tomorrow's cars would be a much better business. A whole new population of owners and stations would also be created. Manufacturers of everything from receivers to transmitters and everything in between would be well rewarded, while our advertising revenue would be under attack. Never mind that today's broadcasters would be able to do everything that the MMBS service could do if only COFDM were allowed as a modulation system. (Remember, COFDM comes in many data rates, all of them decoded by the same receiving hardware.) How attractive would this proposed new service be if ALL of the channels could be enlisted into providing such services by today's broadcast community? Not just Ch60 to Ch69! Perhaps, after the public's rejection of the HDTV model and the proof that there is no easy solution for 8VSB reception, our channels would someday become available at a much cheaper price? This is not an attractive outcome.
It now seems clear that CEMA's irrational defense of an antiquated modulation system, and a business model that has no viable income mechanism, is now intended by some to protect a new competitive business model intended to benefit themselves. A business model that is the rightful future business for today's broadcaster. A business model that we need to support our mandated billion dollar investment and a business model that would accelerate the acceptance of digital technology and the return of the analog spectrum and a business model that could be the natural safety net for our industry if or when HDTV fails. There should be no argument that a portion of the returned spectrum could be dedicated to a low data rate mobile service. It now seems patently deceptive however, to propose one service that would use a modulation system capable of high data rates and proven robust reception, by CEMA's own admission, and then continue to strongly support an outdated modulation system for traditional broadcasting. A system that has been shown to fail to reach an audience currently served by analog TV today. The outcome of CEMA's strategy, if not the bold faced intent, seems clear if CEMA is allowed to propagate this outrageous proposal and we continue to support 8VSB for our industry.
Imagine the future world that CEMA has been quietly working to create.
Today's broadcaster would be broadcasting, in the future, HDTV to fixed roof top antennas using 8VSB. There would be no meaningful wireless data services because the majority of receivers would be connected to cable. A cable system that may or may not carry the over the air local stations. However, lucrative data services would come from the cable company's servers and would be two way and robust. Wireless applications of the broadcast signal would be fragile at best, given the weaknesses of 8VSB. On the other hand CEMA's MMBS service, using COFDM at high data rates, would be received by mobile antennas BUT also it would be received indoors by simple antennas and portable computing devices. It would also be delivering multi-channel video and entertainment for advertising revenue. In competition with the local broadcaster! In short, the MMBS service would be all that the current broadcast industry wants to be but it would have the advantage of COFDM technology, while today's broadcaster would be limited to the CEMA promoted single channel of HDTV transmitted using the yet to be perfected 8VSB.
The revelation that CEMA has known for two years that COFDM is a robust modulation system and that they have planned this new service should serve to devalue them and their partners in the discussion of 8VSB. The tests in Baltimore that CEMA now wants everyone to ignore have, in fact, demonstrated the bankruptcy of their members products. In that sense it is a demonstration. The voices that continue to talk about replication of "area" coverage and ignore ease of reception need to re-evaluate their position in light of the hypocritical statements from CEMA and their partners. How can any broadcaster continue to accept any argument from a now declared competitor for our spectrum and our businesses? How and why should we accept any of their representations about future improvements? What is their incentive to do it now?
CEMA's agenda is now clear and it is NOT anything that will benefit broadcasting. Their empty promises of a solution for the 8VSB reception problem now must be looked at as part of a new alternative agenda to hobble the TV broadcaster and create a new business for themselves and their partners. As broadcasters it is way past the time that we take control of our own destiny and shake off the false premise and empty promises of a hypocritical industry organization. As far as ATSC is concerned I would simply say, *you better wake up and do it soon. It appears you have been duped.*
We as broadcasters need to demand from our industry organizations, NAB, MSTV and ALTV, that they awake from their blissful sleep and defend not only our spectrum but our business models. The continued reliance on the proclamations of CEMA and its members about a better day for 8VSB certainly sound hollow now. There is no time to waste. Sinclair has taken a lot of criticism about its efforts to uncover the truth about 8VSB. We were, quite frankly puzzled as to why the strong defense of such a poor performer. Now things seem much clearer.
