It looks like the FCC won't be adding COFDM to U.S. DTV standards....
> FOR IMMEDIATE RELEASE: News Media contact:
> February 4, 2000 David Fiske (202) 418-0513
> FCC DENIES SINCLAIR PETITION FOR RULEMAKING ON COFDM STANDARD
> WASHINGTON, D.C. - The FCC today released a letter denying a Petition for Expedited Rulemaking, filed by Sinclair Broadcast Group, Inc., requesting that the Commission modify its rules to allow broadcasters to transmit Digital Television (DTV) signals using COFDM modulation in addition to the current 8-VSB modulation standard.
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> The Commission said that numerous studies conducted to date support the conclusion that NTSC replication is attainable under the 8-VSB standard. It said that the concerns raised in the Sinclair petition had done no more than to demonstrate a shortcoming of early DTV receiver implementation. It said that manufacturers are aware of problems cited by Sinclair and are aggressively taking steps to resolve multipath problems exhibited in some first-generation TV receivers.
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> The Commission noted that the FCC Office of Engineering and Technology (OET) recently analyzed the relative merits of the two standards, and concluded that the benefits of changing the DTV transmission standard to COFDM would not outweigh the costs of making such a revision. It reiterated its view that allowing more than one standard could result in compatibility problems that could cause consumers and licensees to postpone purchasing DTV equipment and lead to significant delay in the implementation and provision of DTV services to the public. It said that development of a COFDM standard would result in a multi-year effort, rather than the "unrealistic" 120 days suggested in the Sinclair petition.
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> At the same time it dismissed the petition, the Commission recognized the importance of the issues raised in Sinclair's petition. The Commission, stated, however that the issue of the adequacy of the DTV standard is more appropriately addressed in the context of its review of the entire DTV transition. The Commission clarified that, within 30 days, it will commence its biennial review of the DTV transition and, as a part of that proceeding, will encourage parties to comment on concerns regarding the 8-VSB standard.
> - FCC -
> Action by the Commission February 4, 2000, (FCC 00-35)
> Office of Engineering and Technology Contact: Bob Calaff (202) 418-2470
> *********************************
> Federal Communications Commission
> Washington, D.C. 20554
> Released: February 4, 2000
> BY CERTIFIED MAIL, RETURN RECEIPT REQUESTED
> Mr. Martin R. Leader
> Fisher, Wayland, Cooper, Leader
> & Zaragoza, L.L.P.
> 2001 Pennsylvania Avenue, N.W.
> Suite 400
> Washington, DC 20006
>
> Dear Mr. Leader:
>
> This letter responds to the Petition for Expedited Rulemaking, dated October 8, 1999, filed by Sinclair Broadcast Group, Inc. This petition requests that the Commission modify its rules to allow broadcasters to transmit Digital Television (DTV) signals using COFDM modulation in addition to the current 8-VSB modulation standard. For the reasons described below, the Commission rejects this Petition.
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> In its Petition, Sinclair argues that broadcasters will be unable to achieve the goal of NTSC replication with their DTV operations under the current ATSC 8-VSB DTV standard. According to Sinclair, this is because 8-VSB cannot be received reliably today with a simple antenna in a station's core business area due to complex multipath effects. Sinclair states that a COFDM-based alternative DTV standard will offer viewers ease of reception using simple antennas, and enable broadcasters to provide a variety of fixed, mobile and portable video services and greater capacity for technological improvement. Sinclair further argues that this approach would allow the marketplace to determine the appropriate DTV modulation technology and accelerate the development of DTV. Sinclair in particular requests that the Commission appoint an industry task force that, in 120 days, would be directed to: 1) conduct a study and issue recommendations to the FCC regarding the integration of COF!
DM technology into the ATSC standard; and 2) conduct rigorous scientific analysis to determine the interference ratios for COFDM into existing NTSC and 8-VSB DTV signals.
>
> On October 14, 1999, the Consumer Electronics Manufacturers Association (CEMA) filed an opposition to Sinclair's petition and a motion for its immediate dismissal. CEMA argues that the petition fails to assert any valid basis for re-opening the DTV standards proceeding at
> this late date, and presents only arguments that are repetitive of those previously considered. It states that re-opening the DTV standards proceeding would create uncertainty and benefit only those seeking to delay the transition to digital broadcasting. It argues that the industry recommended 8-VSB modulation standard was selected in an open and scientifically rigorous process that included the relative multipath capabilities of both COFDM and 8-VSB.
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> On October 29, 1999, Sinclair submitted a reply to CEMA's opposition filing. Sinclair argues that contrary to CEMA's assertions, it has provided a compelling and convincing basis for initiating a new rulemaking proceeding on DTV standards. It states that it has raised crucial and previously unrecognized issues relating to ease of DTV reception with simple antennas under dynamic multipath conditions. In addition, several broadcasters have filed letters with the Commission supporting Sinclair's petition and subsequent filing.
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> For the reasons set forth below, we do not find that Sinclair's petition warrants consideration by the Commission. We continue to believe that NTSC service replication is achievable by DTV operations using the 8-VSB standard. We note that field test data taken to date supports this conclusion. Sinclair has presented no persuasive evidence to indicate that NTSC service replication cannot be achieved with the 8-VSB standard.
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> In the Commission's Office of Engineering & Technology's (OET's) recent DTV Report on COFDM and 8-VSB Performance, OET concluded that both 8-VSB and COFDM have certain advantages and disadvantages. OET did not find that the performance potential of either system was clearly superior in all respects. OET further concluded that the relative benefits of changing the DTV transmission standard to COFDM are unclear and would not outweigh the costs of making such a revision. OET also indicated that it believed that 8-VSB has advantages with regard to data rate, spectrum efficiency and transmitter power requirements. We do not find that Sinclair has presented any valid technical information to refute OET's assessment of these 8-VSB advantages or to refute the recommendation in its report that the ATSC 8-VSB standard be retained.
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> In making its decision to adopt the ATSC standard, the Commission stated that a single system standard would ensure that all affected parties, i.e., broadcasters, equipment manufacturers, and the public, have sufficient confidence and certainty to promote the introduction of DTV service. The Commission stated that allowing more than one standard could result in compatibility problems and increase the risk that consumer DTV equipment purchased in one city would not work well in another city; or that a digital television set purchased one year might not work several years later. The Commission found that such results would harm consumers and would make it more difficult to preserve a universally available television service. The Commission also found that having more than one standard could cause consumers and licensees to postpone purchasing DTV equipment, because they would not wish to take the risk of investing in what may soon be an obsolete technology, or because the!
y believe better technologies would soon be available. The Commission stated that this could slow investment and, thereby, slow the transition to DTV.
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> Sinclair has presented no persuasive evidence in its petition and related filings to convince us that the interests of broadcasters, equipment manufacturers and consumers would not be harmed under its alternative standards approach or that conditions have changed to make such an alternative standards approach appropriate at this time. We are concerned that allowing the use of an alternative DTV modulation method as Sinclair proposes would lead to the adverse situations identified by the Commission in the Fourth Report and Order. Further, contrary to Sinclair's claims, we believe that granting its request would lead to significant delay in the implementation and provision of DTV services to the public. For example, under the Sinclair proposal, the task force would have to develop a complete COFDM standard and achieve industry consensus on that standard. There are, however, a number of different COFDM approaches, such as DVB in Europe and ISDB in Japan. In addition, even !
if only the European DVB systems were considered, there are a number of implementation options, such as modulation, code rate, and guard interval, that would have to be decided. In addition, laboratory and field testing would likely be needed to develop appropriate interference criteria. We therefore believe that Sinclair's suggestion that this matter could be addressed and resolved by an industry task force within 120 days is unrealistic and that it is much more likely that this approach would result in a multi-year effort, as argued by CEMA in its filing.
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> Finally, although Sinclair presents evidence that certain first generation 8-VSB receivers may not operate satisfactorily in strong multipath conditions using simple indoor antennas, we believe that Sinclair has done no more than to demonstrate a shortcoming of early DTV receiver implementation, rather than a basic flaw in the ATSC standard or an indication that service replication is unachievable. We note that OET's recent DTV Report found that reasonable solutions to the indoor reception and multipath interference issues raised by Sinclair are being developed and are expected to be available in the near future. Information from a number of DTV receiver chip-set manufacturers, such as, Motorola, NextWave Communications, Inc., Thomson Consumer Electronics, and others, indicates that manufacturers are aware of these problems and are aggressively taking steps to resolve the multipath handling limitations exhibited in some first-generation DTV receivers.
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> While we dismiss this petition, we recognize the importance of the issues raised therein. We believe, however, that the issue of the adequacy of the standard is more appropriately addressed in the context of our review of the entire DTV transition. In adopting the DTV standard in 1997, we stated that "regular reviews of the progress of DTV are highly desirable" and that we would conduct a biennial review of the digital transition to ensure that the introduction of DTV and the recovery of spectrum at the end of the transition "fully serves the public interest." Among other things, we said we would address "any new issues raised by technological developments, necessary alterations in our rules, or other change necessitated by unforeseen circumstances [including issues related to DTV receiver designs and set labeling]."
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> In that proceeding, we will be able to consider together all of the issues related to the digital transition, including the progress being made to improve indoor DTV reception under the existing DTV transmission standard and manufacturers' efforts to implement DTV receiver design improvements. Therefore, within 30 days, we will commence our biennial review of the digital transition and, as a part of that proceeding, will encourage parties to comment on the DTV standard.
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> Finally, although we are dismissing its petition, we wish to commend Sinclair for its leadership efforts in identifying certain DTV receiver performance concerns and for providing information and data that will be useful to consumer electronics manufacturers in building receivers that meet the expectations of broadcasters and consumers.
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> Accordingly, pursuant to Section 1.401(e) of the Commission's Rules, the Petition for Expedited Rulemaking submitted by Sinclair Broadcast Group, Inc., dated October 8, 1999, is hereby denied.
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> This letter was adopted by the Commission on February 3, 2000. BY DIRECTION OF THE COMMISSION
> Magalie Roman Salas
> Secretary |
