Walking around CES this year, I asked the question of many '3rd tier'
product companies about "when will you start selling ATSC digital
sets?". Eventually they all answered correctly (march deadline). I then
asked "what is the add-on cost to do this?" The typical response was
that it would add $40 to the cost wholesale (i.e. not to the consumer).
Just wanted to add another data point in this exercise...
Mark
the Mark that never argued that DVB was the solution, but rather, ease
of reception was...
(just so happened that DVB-T could be used to demonstrate our
expectations, COFDM being used to set the bar of expected performance...)
PS - It was NEVER about COFDM. When one takes the time to read the 1999
"Petition for Expedited Rulemaking" filed with the FCC, the summary
makes clear our unchanging position...
Summary
Sinclair Broadcast Group, Inc. ("Sinclair") hereby urges the Commission
to modify its digital
television ("DTV") rules and give DTV broadcasters the flexibility to
transmit their digital signals using
COFDM digital modulation technology. Following Sinclair's 1999 field
trials, it is now clear that such
action is crucial to the future viability of DTV in the United States.
If broadcasters can operate under a
COFDM-based alternative ATSC DTV standard, they will be able to offer
ease of reception and
reliable over-the-air DTV service to the American public, will have far
greater flexibility in the video
marketplace, and will benefit from a greater capacity for technological
improvement. If the Commission
instead maintains exclusive reliance on inflexible 8-VSB digital
modulation technology, broadcasters will
be unable to replicate their current NTSC service, and will struggle to
adapt to new marketplace
conditions in the next century. At the same time, Sinclair recognizes
that many in the broadcast industry
have already made a significant commitment to 8-VSB operations, and
Sinclair does not advocate the
abandonment of 8-VSB; rather, if the Commission grants the rule changes
requested by Sinclair,
broadcasters will be able to operate under either a COFDM-based or
8-VSB-based ATSC DTV
standard.
Given the recent development of this technology, broadcasters using
COFDM would be able to
overcome complex multipath conditions and provide ease of reception and
reliable over-the-air DTV
service, including HDTV, to viewers using simple antennas within their
stations' core business areas
(their Grade A contours). Moreover, COFDM currently permits 6 MHz data
rates of up to 24 Mbps,
almost twenty-five percent greater than the forever-frozen 8-VSB rate of
19.34 Mbps, and further
development of COFDM over the next decade will allow easy and reliable
reception of COFDM at 24
Mbps and higher. In addition, COFDM would give broadcasters the
flexibility to vary their data rates,
permitting a variety of HDTV, Standard Definition TV, and mobile and
portable DTV programming
streams across their daily and weekly schedules. For these reasons, a
Commission decision to allow
COFDM operations would stimulate consumer acceptance of DTV,
accelerating its development and
speeding the recapture of NTSC spectrum. Such action would also be
consistent with the
Commission's flexible approach toward other elements of the ATSC DTV
standard, including scanning
formats, and would permit the marketplace to play an appropriate role in
the development of DTV
broadcast technology.
Ample signal strength does not guarantee that consumers will be able to
receive that signal, and,
as described in detail in Sinclair's attached comparative study of COFDM
and 8-VSB, the 8-VSB
standard currently does not permit ease of reception or reliable DTV
service through simple antennas in
broadcasters' core business areas. Given the unreliability of this
reception, 8-VSB broadcasters will be
unable to replicate their NTSC service, and, during the digital
transition, consumers will likely be forced
to receive DTV service through large rooftop antennas. Even consumers
able to afford such an outdoor
antennas will suffer limited viewing functionality in markets with
non-collocated DTV stations. In
addition, given 8-VSB's fixed data rate, this standard will not allow
the provision of mobile and portable
video services.
As a result of all these factors, if the Commission continues its
exclusive reliance on the 8-VSB
standard, DTV will likely be perceived negatively by the public, thereby
jeopardizing the digital
transition. Even if the DTV transition is eventually completed, this
policy would endanger the viability of
free over-the-air television service, since an overwhelming majority of
television households in the U.S.
would be forced to subscribe to cable or satellite service.
In recent months, 8-VSB proponents have put forward a number of
technical, operational, and
economic reasons not to authorize COFDM operations in the U.S.
(Sinclair's Petition does not
address the COFDM/8-VSB report released by FCC's Office of Engineering
and Technology on
October 1, 1999. Sinclair will respond separately to the OET report
within one week of the filing of
this Petition.) First, despite the doubts of entrenched 8-VSB interests,
COFDM signals can be used to
provide HDTV over 6 MHz channels, as shown by the 18.67 Mbps data rate
achieved in Sinclair's
Baltimore testing. In addition, while some argue that 8-VSB provides
greater coverage than COFDM
at equivalent power levels, this theoretical coverage gap appears to
disappear under real-world
conditions, as described in Sinclair's study. Finally, claims that
technological improvements will allow 8-
VSB to overcome dynamic multipath conditions are mere speculation, and
in the absence of specific
and identifiable consumer products that achieve these results, such
promises cannot serve as the basis
for the Commission's continued exclusive reliance on 8-VSB. In any case,
given the fact that COFDM
can currently support a variety of data rates up to a maximum of 24
Mbps, the potential for
improvement of that technology is far greater than for 8-VSB, and
Sinclair fully expects that COFDM
will remain superior to 8-VSB across the full range of reception
environments.
While defenders of the status quo claim otherwise, broadcasters,
manufacturers, and consumers
would not incur significant costs if the Commission decided to permit
use of COFDM in the U.S. Any
additional power and equipment costs for COFDM broadcasters would be
borne voluntarily, and
would likely be inconsequential. Grant of the instant petition would not
impose significant costs on DTV
receiver manufacturers, since it appears that the necessary equipment
and expertise are already
available to incorporate COFDM technology into DTV receivers targeted
for sale in the U.S. Finally,
the prior sale of 8-VSB receivers to a tiny fraction of consumers should
not prevent the Commission
from permitting broadcasters to use the COFDM standard.
Accordingly, for the reasons described above, Sinclair respectfully
urges the Commission to
modify through rulemaking the existing rule for digital modulation to
permit broadcasters to transmit their
digital signals using COFDM technology. In its order, the Commission
should institute a general
principle of flexibility with respect to DTV modulation technology,
establishing that broadcasters will be
able to operate under either a COFDM-based or 8-VSB-based ATSC DTV
standard. The
Commission should facilitate COFDM operations by U.S. broadcasters by
appointing an industry task
force that would be directed to do the following, within 120 days of its
appointment:
(I) Conduct a study and issue recommendations to the Commission
regarding the
integration of COFDM digital modulation technology into the ATSC DTV
standard;
and
(ii) Conduct a rigorous scientific analysis to determine the
interference ratios for COFDM
transmissions into existing NTSC and 8-VSB DTV signals.
Once this task force has performed these duties, the Commission should
review its
recommendations and adopt an alternative COFDM-based ATSC DTV standard.
The Commission
should establish simple procedures whereby broadcasters could
demonstrate, using the interference
ratios provided by the COFDM Task Force, that they will not cause
interference to any operating
NTSC or 8-VSB DTV broadcasters. Once a broadcaster has made this
interference showing, it would
be permitted to initiate COFDM operations. Sinclair urges that the
Commission act expeditiously
throughout this proceeding.
While this petition urges the Commission to permit COFDM operations,
Sinclair does not have
an inherent interest in the adoption of any particular digital
modulation standard. Sinclair does believe,
however, that the Commission, having mandated an accelerated shift to
digital operations, must now
take the steps necessary to make this transition successful and
beneficial to all Americans. Since the
development of COFDM has now raised the benchmark for DTV reception, the
Commission should
authorize use of this technology, allow the marketplace to play its
appropriate role, and enable
broadcasters to deliver the long-awaited era of advanced television to
the U.S. public.
Mark Schubin wrote:
> You confuse me with someone making an argument in favor of DVB-T. You
> are pointing to a $50-retail box of which, according to your figures
> (higher ones are also published), half would be IP costs.
>
> I point to readily available inexpensive analog TV sets, some of which
> currently retail for less than your IP costs.
>
> As the old joke goes, will they make it up on the volume?
>
> TTFN,
> Mark
>
>
> Manfredi, Albert E wrote:
>> Mark Schubin wrote:
>>
>>> Once again, the issue is the IP fees.
>>
>> Mark, I thought we had established that those are about $23.
>>
>> If $16 are for the MPEG-2 decoder, as has been suggested in the past,
>> then the majority of the IP fees apply equally to DVB-T boxen.
>>
>> Bert
>>
>>
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--
><> ><> ><> ><> ><> ><> ><>
Regards,
Mark A. Aitken
Director, Advanced Technology
<>< <>< <>< <>< <>< <>< <><
===================================
Sinclair Broadcast Group
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Hunt Valley, MD 21030
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