[opendtv] Re: Community Broadcaster's Association wants converter boxes to handle analog, too!

  • From: "Bob Miller" <robmxa@xxxxxxxxx>
  • To: opendtv@xxxxxxxxxxxxx
  • Date: Sun, 18 Nov 2007 00:47:01 -0500

On Nov 17, 2007 5:26 PM, John Willkie <johnwillkie@xxxxxxxxxxxxx> wrote:
>
> Bob miller said:
>
> "Met with the FCC LPTV person in 1999 with the request that LPTV
> stations be allowed to use DVB-T and was told first that digital rules
> for LPTV would be issued by Christmas of that year and that there was
> no reason that he could see not to allow other modulations like DVB-T
> on LPTV stations. Since by definition LPTV stations cannot interfere
> with FPTV stations that seemed reasonable at the time. Within a few
> months, as I remember it, the Sinclair controversy erupted and all
> chance of LPTV stations being allowed to use COFDM vanished."
>
> 1999 was perhaps too early, and in the heat of the battle, but you didn't
> need any interpretation from Hossein (an engineer, not an FCC attorney) to
> read Part 74, subpart G (LPTV and TV translator rules).
>
> They provided then, only slightly modified 6 years later, that as long as
> envelope limits were met, one could employ any "modulation technique
> permitted by the commission" in LPTV/Tv Translator service.
>
> Once the commission approved the first use in any service of OFDM
> modulation, you could use it in part 74 without EVEN NOTIFYING THE
> COMMISSION.  You chose to ask permission. Years ago, I told you that was
> foolish, because in 1999 was the heat of the battle, and the FCC KNEW that
> this loophole existed. (or, would exist, I'm not sure when BAS and other
> services were permitted to use OFDM.)
>
> Within it's rules and practice and procedure, the FCC could do nothing to
> stop your usage of OFDM once it was approved in any service.  I suspect that
> getting financing would be an issue, but not one that pertains to the FCC,
> but the courage of your investors (a class never known for courage.)
>
> Now, you work with Richard Bogner, and I believe that his hybrid 8-VSB/FM
> operation on channel 6 in NYC (with the FM on 87.9) seems to comport with
> FCC rules (not necessarily interference issues) at the present time.
> However, I am not prepared to say that is the case after the sunset of
> analog.  (I'll be fuzzy about whether this pertains to the sunset of analog
> for FSTV or LPTV.)  I do believe that the interference issue is likely to
> come to the forefront first.  The interference issue doesn't seem to apply
> to 87.7, but not all radios tune in that frequency.
>
> The only conclusion I can draw from your meetings with FCC commissioners and
> staff is that you only hear what you want to hear.  There was no rational
> reason to keep NTSC alive after PAL was adopted, except for the installed
> base of receivers and the off-shore aspects of PAL.
>
> John Willkie
>
>
As you know I am not an engineer and was not only not an engineer in
1999 but a complete novice at all things broadcast. I had just
navigated down the spectrum from LMDS to MMDS to LPTV and then FPTV
and Richard was my mentor. I knew absolutely nothing at the time.
Politically and FCC wise I was even worse. Fortunately I was dumb
enough to ask a lot of questions.

How dumb? We were thinking that we had somehow stumbled on this big
secret called COFDM and could not for the life of us understand why
the US broadcast industry didn't seem to know anything about it. This
after trying and failing at 8-VSB. We thought we could just possibly
scarf up some deals with broadcasters and LPTV stations to have a
business before broadcasters caught on.

Could not believe it when broadcasters did find out and rejected it
and I found myself, instead of hiding COFDM, testifying for it in
public. And then there was this auction in 2000 that was put off. I
thought broadcasters would want the auction and would be the main
bidders for channels 51 to 69 but there was NO interest. I was
completely dumbfounded.

And then in a kind of stuporous fog I saw Auction 44 come and go where
channels 54, 55 and 59 went for 1/100th of what the same and similar
channels would have gone for in 2000 and will go for in January 2008.
I was literally kneeling on the floor begging people to listen to me
that this was the deal of the centuries. An Oklahoma land rush where
no one was showing up. A gold rush where gold was just laying on the
ground and no one noticed for years.

Now today I hear that Google may have $13 billion committed to the
auction. That's up from $4.6 billion maybe a few weeks ago. Not enough
Google. You better have some in reserve we don't know about. $13
billion may not be enough. This is starting to look a lot like the UK
and German auctions where egos and CEO's thought they had to have the
spectrum or lose their jobs.

One thing is different. The egos are bigger now and the market caps of
some players are orders of magnitude larger and there could be a lot
more players. And one more thing. This time jobs will really be on the
line for the slackers who don't get their spectrum. 3G was BS in 2000
but the varied uses of this prime spectrum is real and now. I am going
to raise my estimate of the take for this auction to $60 Billion. I
just don't have the **** to say what I really think the number
is.going to be.

Bob Miller
 
 
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