Industry Divided on Future DTV Signal Strength Rules

A Commission inquiry into DTV signal standards and testing is part of a Satellite Home Viewer Extension & Reauthorization (SHVERA)-mandated update. SHVERA requires the Commission to tell Congress what changes, if any, should be made to rules governing household eligibility to receive distant network signals from satellite carriers in light of the DTV transition. Industry officials responded to an FCC Notice of Inquiry (NOI)this week, weighing in on the pluses and minuses of the Longley-Rice model in a DTV environment.

Issues raised by the Commission inquiry are “vital to the DTV transition” because DTV reception problems are more dramatic than their analog counterparts, said EchoStar in its comments to the FCC. In reporting results of an engineering study it commissioned of commercially available DTV receivers, EchoStar urged the Commission to revise upwards its DTV signal strength standard. EchoStar said today’s DTV receivers may not be able to display a DTV picture even when the strength of the digital signal meets Commission standards, due to man-made noise and signal sensitivities not adequately planned for in existing standards.

Overall, EchoStar said, the Commission should urge Congress to adopt a predictive model, but one adjusted for DTV signal loss due to building penetration, land cover variations and other problems. EchoStar also suggested the Commission revise testing rules to account for multipath interference and DTV signals’ time variability. Indoor testing for apartment dwellers and others who can’t install an outdoor antenna should be required, EchoStar said.

The Consumer Electronics Assn. (CEA) backs a predictive methodology for determining whether a household is unserved, and doesn’t see a better model than Longley- Rice, the CEA said. But the group shied away from Longley-Rice’s intricacies and issues that may be raised by digital signals, advocating that “whatever the result of this inquiry, it is imperative that the FCC have a single, consistent definition of the service area for each analog and digital TV station.”

Govt. involvement in DTV signal reception “should be limited and specific so as to let the marketplace deliver the best solutions,” the CEA said. FCC rules shouldn’t have to consider antenna type and placement, and the Commission should “be wary of starting down a path of determining how much effort a consumer should put into broadcast DTV reception,” said the CEA. For the FCC to go beyond determining the presence of a signal of certain strength “invites the quagmire of assessing reasonableness, cost effectiveness, and ease of installation,” said the CEA: “There is only so much that the FCC can factor into its determination of served households.”

DirecTV also refrained from making specific comments on DTV protocols, but zeroed in on on-site testing’s inconvenience, asking that the Commission and Congress not increase their roles. DirecTV said on-site testing of TV signals at a customer’s home is “far from the norm” among its customers -- and should stay that way. Said DirecTV: “The Commission has requested comments about predictive modeling as only one among many topics -- most of which concern on-site testing. The implication, perhaps is that on-site testing should be the norm for digital signals. But testing is frustrating to subscribers and costly to satellite operators and consumers. It deserves an even smaller role in the digital world than it has today, not a bigger one.” Instead of giving prominence to on-site testing, the “Commission and Congress should, instead, devote their energies toward developing a digital predictive model that is as accurate as possible,” DirecTV said.

Congress has had a strong preference for local over distant signals in a variety of ways, including through implementation of the “if local, do distant” principle, the NAB said in comments. That simple and “sensible” policy is at the heart of SHVERA, NAB said. Local-to- local services is the desirable way to deliver network affiliates to satellite subscribers, and because distant network station signals are at best a necessary evil, the SHVERA pushes the DBS industry toward the former and away from the latter, NAB said.

The NAB recommended that the FCC continue to assume use of a properly oriented directional rooftop antenna with substantial gain. Antennas of that kind, which fully satisfy the Commission’s DTV planning factors, are readily available at low cost, the NAB said. “It would be difficult to overstate the unfairness of assuming that viewers will use only indoor antennas. Satellite antennas do not work when they are placed indoors, or pointed the wrong way, and it would be arbitrary and capricious to force over-the-air antennas to overcome these severe obstacles to successful reception,” NAB said. Also, the Commission’s existing procedures for measuring signal strength at individual locations will work well, with minor modifications, for measuring digital signal strength.

NAB said the Longley-Rice model, which determines interference of unlicensed devices in the TV broadcast band, does “exceptionally well” at predicting whether particular locations will receive a signal above the DTV minimums. However, there are very serious practical problems with using the results of a digital Longley-Rice model as a basis for signing up subscribers, the NAB said. Different dates that a station can be evaluated and the channels on which particular stations will broadcast in digital are in flux. Nonetheless, the FCC should endorse Longley-Rice for a long-term purpose, NAB said.