Continuing Consumer Confusion on DTV Transition

As we get closer to the 2/17/09 transition date, consumers continue to be confused over what they need to do.

If you have satellite TV, cable TV, or FiOS-like fiber-based service do you need to do anything about your analog TV?

The NTIA DTV2009.gov site is pretty clear on this issue:

"Analog television sets receiving free TV using an antenna will not work after February 17, 2009. Television viewers with these sets that are not connected to a pay TV service will need to take action before February 17, 2009, to ensure their TV sets continue to work. Consumers have a variety of options.

Options to explore include:

1. Keeping your existing analog TV and purchasing a TV converter box. A converter box plugs into your TV and will keep it working after Feb. 17, 2009. It is expected to cost between $50 and $70 and be available in early 2008, or
2. Connect to cable, satellite or other pay service, or
3. Purchase a television with a digital tuner."

1. 
   

By contrast, the FCC website is murkier on the issue with this long discussion

Will cable customers with analog TVs have to buy or rent a set-top box from their cable company? If so, how much will it cost?

First, it's important to know that the February 17, 2009 deadline for the digital television transition only applies to full-power broadcast stations. Cable companies are not required by the government to transition their systems to digital, and can continue to deliver channels to their customers in analog. Cable companies are actually required by FCC rules to continue offering local broadcast stations to their customers in analog as long as they offer any analog service. This requirement will continue for at least three years after February 17, 2009. The Commission will decide in 2011 whether the requirement should be continued beyond February 17, 2012. This means that customers who receive analog cable service (without a cable set-top box) will be able to continue to do so.

However, for business reasons (among other things, digital is much more efficient than analog), cable companies may be interested in transitioning their systems from analog delivery to digital delivery. If a cable company makes the business decision to go all-digital (meaning it will stop offering any channels to its customers in analog), it must ensure that its analog customers can continue to watch their local broadcast stations. This may require customers with analog televisions to get a set-top box. If the cable company provides the customer with a set-top box, any costs related to it will be determined by the cable company. Therefore, it is recommended that analog cable customers contact their cable company to ask if a set-top box will be needed, when it will be needed, and if there will be a cost.

It is also important to note that a cable set-top box is different from a digital-to-analog converter box. A digital-to-analog converter box is necessary only for analog televisions that receive their programming over-the-air using a rooftop antenna or "rabbit ears" connected to the set. A digital-to-analog converter box is not necessary for a TV connected to a paid television service such as a cable or satellite TV provider. Information on any set-top boxes needed for a paid service such as cable or satellite should be obtained from the service provider.

Try explaining that to your grandmother!

If you buy a DTV and want be join the 12% of US households who actually use the "free" over-the-air reception that NAB and MSTV are so sentimental about, do you need a new antenna? The FCC dtv.gov website says

"Will I need a special antenna to receive DTV over-the-air?

In general, dependable reception of over-the-air digital TV programming will require the same type of signal reception equipment that currently works to provide good quality reception of analog TV programming. If you need a roof-top antenna to receive analog TV broadcasts, the same antenna generally will work to receive digital TV broadcasts. You should not have to purchase new antennas that are marketed as “digital ready” or “HD ready."

How many people with technical backgrounds believe that this statement is a general truth? Dr. Oded Bendov, a veteran of the mainstream TV broadcasting industry was quoted by the NY Times as saying “For the people with rabbit-ear antennas, I would say at least 50 percent won’t get the channels they were getting. I would say a lot of people are going to be very unhappy.” The same article goes on to discuss a Centris report saying,

"Centris also estimated that of the 117 million TVs not connected to cable or satellite, up to 80 percent have set-top rabbit-ear antennas that may not be able to pull in an adequate digital signal. Many of those sets will require a better antenna or a cable or satellite connection to do so."

However, if you want really useful information, ignore the 2 feuding federal agencies that can't coordinate their websites, the huge trade associations, and go to Denny's TV Antenna Sales "Based in Ithaca, Michigan since 1988". For example, who else tells the public in plain English that in some cities, e.g. St. Louis, all the DTV stations will be on UHF so you can use a smaller UHF only antenna to get "free" over-the air reception?

So my compliment to Denny's (the TV antenna store - not the fast food place) for their excellent leadership in consumer education that presumably was done on a shoestring budget. I hope the 2 feuding agencies and the trade associations learn from this website and improve their consumer education.

FCC Website Update:
Search Engine Improves &
EDOCS Gets Worse

Readers may recall that I have criticized the ever chaotic FCC website in the past. Now some good news and some bad news. I have not seem announcements of any changes, the items below are personal observations.

Being positive, I will start with the good news: the search engine has improved. A while ago another blogger pointed out that the search engine could hardly find any documents with the name Kevin Martin. That seemed a little strange. But now try to search on the Chairman's name and you get 728 results! No, they didn't just rig it to find more stuff about Chmn. Martin. The new engine really is better. It can find the 2004 press release announcing my appointment as an IEEE Fellow - something that was impossible under the previous search engine.

The new search engine also clarifies its scope of search:

"Search Scope: The FCC Search Engine searches throughout the FCC's web site, including the Electronic Document Management System (EDOCS), but does not collect information from the FCC's other databases and Electronic Comment Filing System (ECFS). Information is collected from web pages and many types of documents including Word, Word Perfect, Acrobat, Excel, and ASCII Text, and is constantly updated."

While the FCC search engine ignores ECFS, it appears now that a Yahoo search - but not a Google search - will often find ECFS documents. Of course, FCC allows people to submit comments to ECFS that are not machine readable or copyable, either because they were scanned from printed copies or because they are "locked". This is a pet annoyance and an inconvenience for all involved in FCC proceedings both inside and outside the FCC.

So congratulations on the search engine improvement!

Now let's look at EDOCS itself. This is the system used to store and retrieve official FCC-generated documents in FCC rulemakings and many other - but not all - proceedings.

Here is part of the results from a search of the old EDOCS when looking for the NPRM in Docket 04-186 - "TV White Space"


I previously commented that the 15 different links are confusing. All the other federal regulatory agencies use only .pdf format. An FCC staffer sold me FCC started using .txt formats in releases when the visually disabled community complained that computer reading/speech synthesis software had problems with .pdf documents. I do not have direct knowledge, but I wonder whether that is still true for documents that are directly converted to .pdf by software. But why the .doc formats?

If you search for the Docket 04-186 NPRM using the "improved" EDOCS, you get the following


I show two different documents out of the 15 that result from a search on 04-186 because it is unclear which is actually the NPRM, even if you ignore the 15 different links for each document. It turns out that the top one is the NPRM and the bottom one is a press release. How are you supposed to know? At least the old EDOCS had an indication in the upper left corner that said "NPRM".

FCC Tries Again on D Block:
If at First You Don't Succeed, ...

At today's Commission meeting, FCC tried again on D block. The press release outlines a Second Further Notice of Proposed Rulemaking (Notice) that "seeks public comment on how the Commission should proceed with the reauction and licensing of the 700 MHz D Block spectrum while maximizing the public safety and commercial benefits of a nationwide, interoperable broadband network. The text is here (101 pages).

The 2ndFNPRM will seek comment on

• the rules governing public safety priority access to the network during emergencies
• the performance requirements and license term;
• whether to license the D Block and public safety broadband spectrum on a nationwide or regional basis;
• the various fees associated with the shared network;
• whether or not it would be appropriate for the Public Safety Broadband Licensee or any of its agents, advisors, or service providers to serve as a mobile virtual network operator to manage access and use of the 700 MHz D Block of spectrum by first responders;
• the process for the D Block licensee and the Public Safety Broadband Licensee to negotiate a Network Sharing Agreement;
• the potential for requirements that the Public Safety Broadband Licensee be a non-profit organization and that no for-profit entities, apart from certain outside advisors or counsel, be involved; and
• auction-related issues, such as whether to restrict auction participation and how to determine a reserve price.

One could say that these should have been considered before. But there was a great rush to get the D band rules out with only a few weeks between the closing of comments and the multihundred page decision. Another way to look at the problem is to say simply that the FCC's new Public Safety & Homeland Security Bureau was just too successful here. That is it marshalled the Commission's policy decision to be so much in favor of the public safety interests that no private party in their right mind would bid on the D block under the original rules. The more I read the decision, I was amazed that their was even one bidder! Did anyone with an MBA read the draft rules before they were adopted and advise the 8th Floor on the likelihood than an investor would find them attractive? In a partnership, it takes "two to tango".


The public/private partnership has to have advantages for both sides. The new notices shows that is being reexamined.

RCR's article on the new notice also mentioned that

"(s)hortly after the agency’s 5-0 vote on the D Block, Rep. Jane Harman (D-Calif.) introduced legislation to authorize $4 million to begin funding the Public Safety Spectrum Trust Corp. — the 700 MHz public-safety broadband licensee — that would partner with a winning commercial D-Block bidder under the shared wireless broadband network model."

This is a positive move that could eliminate the questionable Cyren Call funding of PSST - even though the FCC IG found no problem with it.

Interesting Spectrum News
from
"Down Under":

Asking Questions
Not Asked in US

From my friends in London's PolicyTracker I got news of some interesting spectrum developments in Australia. As we approach the 40th anniversary of Robert Kennedy's assassination, perhaps we should ask about the lack of parallel actions in the US spectrum policy community and "say why not?"

The first document is a report and request for comments/"consultation" from the Aussie regulator, Australia Communications and Media Authority (ACMA), entitled "Five-year Spectrum Outlook 2009-2014". In the past FCC has sometimes commented on such documents to the counterpart originating agency in a collegial way - don't count on it here since FCC doesn't seem to have any specific spectrum policy of its own recently, not withstanding the references in recent FCC budgets to the mysterious "Spectrum Management Task Force" and its "new approaches to spectrum management."

The ACMA document gives a good view of where the agency sees the growing demand for spectrum and what its proposed priorities are for the next few years. It then asks for comment on them.

One general comment is that it reminds me of the ill fated attempt of the FCC's former Private Radio Bureau in the 1980s to quantify future private land mobile requirements. (The biggest outcome of this effort, oddly, turned out to be today's DTV as the broadcasters squirmed and squirmed to avoiding being victim of a spectrum grab.)

The basic problem with the PRB approach was guessing future demand for spectrum when indeed no one has a need for spectrum - people have a need for communications capacity. Communications capacity then needs spectrum, but the amount needed is a function of both available technology and demand elasticity. Just as we can't accurately forecast the GDP x years from now, we can not forecast communications demand accurately. New trends will result in communications uses we can't anticipate. Other uses, like paging, made fade away under pressure from crosselastic alternatives. New spectrum technologies arise that increase the intensity of spectrum use which rarely approaches the theoretical limits in today's applications. Finally, some technologies, such as cellular, allow higher spectrum efficiency through higher capital investment/fixed costs. The the amount of spectrum needed depends on demand elasticity issues. I am impressed with the ACMA document, but hope that commenters explore this issue. I would be glad to be of assistance if you want to discuss it.

The second document shown above is a study commissioned by ACMA on government use of spectrum. I have reported previously that the European Commission is exploring a similar issue and that neither FCC nor NTIA are too interested in asking such a question in the US context. ACMA commissioned SpectrumWise Radiocommunications Consulting in 2006 to examine the measures required to better achieve an appropriate balance between government and broader community use of the radiofrequency spectrum.

The review was intended to do the following:

• To identify the major government spectrum holdings below 31 GHz
• To describe both actual and potential uses of major Government spectrum holdings;
• To identify major spectrum holdings for which existing or potential demand indicates that the overall public benefitcould be maximised by 1) Making all or part of the holding available for non-government use, 2) Identifying increased sharing opportunities; and 3) Devolving management of major Government spectrum holdings to other Government agencies;
• To develop a strategic approach to the re-allocation of Government spectrum holdings to non-government uses;
• To review the medium and long term effectiveness of existing regulatory arrangements;
• To identify regulatory mechanisms and approaches that will assist ACMA to maximise the overall public benefit from major Government spectrum holdings;
• To examine the opportunity cost of major Government spectrum holdings in order to identify opportunities for improved charging arrangements and other incentive mechanisms

The Review identified 30 individual recommendations for further consideration, some of which are not in the sole remit of ACMA. Three of the major areas identified in the Review relate to:

• increased transparency in the use of spectrum by government bodies;
• the need for increased sharing of government spectrum; and
• increased use of market approaches to improve the management of government spectrum.

These are good concepts in any society. The UK already charges government users for spectrum access and contemplates increases the charges to marketplace value in the future. (Governments pay marketplace prices for land and fuel, why not spectrum too?)

In the present bifurcated system of spectrum policy in the US (FCC & NTIA) such an review is unlikely, especially considering the strong influence the large agencies using spectrum have at NTIA's Office of Spectrum Management where they effectively make 95% of the decisions and where the NTIA staff de facto functions as the IRAC Secretariat.

While local, state, and federal government agencies probably need more spectrum access, why should they be exempt from effective oversight on how well they use existing spectrum. Shouldn't one consider whether some of future capacity increases might come from increasing efficiency of existing spectrum? The US form of government is based on checks and balances and effective oversight. Government spectrum use should not be exempt. Both Europe and Australia are exploring new oversight, "why not"?

Pioneering 19th Century Computer Display
Opens in Silicon Valley

The Computer History Museum opens an exhibit on May 10 of a replica of Charles Babbage's third computer design, Difference Engine No. 2. None of his designs were ever completed during his lifetime. The first working model of this device was completed by London's Science Museum in 2002. The model on display at the exhibit is a copy made by the Science Museum for former Microsoft CTO Nathan Myhrvold who has generously loaned it for a year.

The museum's website has a fascinating discussion of the history of this device and the exhibit complete with a video of the machine in action. While it may not be worth a special trip to Silicon Valley, I certainly plan to visit it the next time I am in the neighborhood and thought it would be of interest to readers.

(OK, this has nothing to do with spectrum. But I thought many readers would be interested.)


Computer History Museum
1401 N Shoreline Blvd.
Mountain View, CA 94043

Tel: (650) 810-1010

Wireless Microphones and
Docket 04-186: Two Different Viewpoints

On May 1st, the Sports Technology Alliance, a trade group consisting of the major professional sports leagues and ESPN, submitted an ex parte filing to FCC on why the FCC should reject the TV whitespace proposals of Docket 04-186 because of the threat of harm to the production of live sports events or the possible resulting requirement that using beacons to protect legal wireless microphone use "would result in significant additional expense to acquire new equipment merely to enable existing equipment to continue to function." Presumably the "existing equipment" they mention is the analog FM FDMA equipment that is being replaced now in almost every other radio service by more efficient equipment.

To bolster their technical points, this group has hired Harbour Group, a Washington DC PR firm to explain the advantages of the status quo. Harbour's website explains their approach to advocacy:

“We have helped clients sharpen their messaging and delivery to provide support to their allies and put pressure on opponents, shaping the policy environment... Managing the public policy issues that can affect an organization’s success starts with identifying and prioritizing challenges. We conduct thoughtful research, target key constituencies, build successful alliances and mobilize supporters. Our collective backgrounds provide a powerful combination of expertise and experience that allow us to help shape policy development and deliver results.”

Oddly, Harbour has never mentioned why these multibillion dollar clients need continued cost free access to spectrum on demand anywhere in the US even if it denies the use of the spectrum to others and why they cling to using dated FM FDMA technology when even your neighborhood taxi is transitioning to more efficient technology.

SpectrumTalk welcomes Harbour Group to the fray and looks forward to the "pressure" they promise. However, the wireless microphone community might do better hiring technical advisers to see what their technical options really are rather than clinging to technical and regulatory approaches of the past.

Marcus Spectrum Solutions LLC has filed with FCC today a response to the Sports Technology Alliance. Readers are encouraged to compare the two viewpoints and comment on them. While I nominally "moderate" comments on this blog to prevent spam, all comments received will be posted below except those that are clearly spam or contain words not fit for broadcasting. I suppose Harbour Group would not suggest that the other side be as open.