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FCC Commissioner: Let's Do More Testing Before We Abandon Analog

March 4, 2008

U.S. Federal Communications Commission member Michael Copps has written FCC Chair Kevin Martin, suggesting that more testing be completed before U.S. broadcasters pull the plug on analog television stations and complete their switch to all-digital broadcasting on February 17 of next year.

In his letter, Commissioner Copps suggested this procedure be done by means of test markets, where real world conditions would serve as a realistic template for any additional changes needed for the new standards.

The letter from Commissioner Copps to Chair Martin is below.

March 3, 2008

Chairman Kevin J. Martin

Federal Communications Commission

445 12th St. SW

Washington, DC 20554

Dear Mr. Chairman:

I am writing to suggest some ways we could gain critical real-world experience in advance of the digital-television transition now less than one year away. Real-world experience is an extremely important step -- although only one of many we must take -- in order to minimize consumer disruption Feb. 17, 2009.

My strong first preference, as we have discussed, is to actually switch a small number of markets to all-digital service before the national transition date. Broadway shows open on the road to work out the kinks before opening night. The DTV transition deserves no less. Other countries are transitioning over time, with phased schedules. The United Kingdom, again as we have discussed, is transitioning on a regional basis between 2007 and 2012, learning at every step along the way and making necessary adjustments. Our single transition date does not afford us the luxury of a built-in learning curve. We have one chance to get this right -- one opening night.

I recognize the technical and practical challenges with planning and conducting full-scale test markets this close to the transition date. Turning off even some analog signals early in a particular market would require us to secure the participation of the affected stakeholders, to front-load consumer-education efforts and to ensure the ready availability of converter boxes. Nevertheless, I continue to believe that these challenges can be overcome and that given the potential benefits for the broader transition, we need to try.

Whether or not we are able to conduct full-scale testing, however, there are a number of more limited DTV field tests that we can and should conduct in advance of the transition date. These tests would not raise the logistical concerns of a full-scale trial because the analog signals in these markets would remain on throughout the community. Individual households would volunteer to switch to digital reception early and participate in the testing process. I believe that a series of field tests could provide critical insights into many of the issues that consumers will face in February 2009 and permit us to make inevitable mid-course adjustments.

Among other issues, field tests could explore the following:

• DTV reception: There has been some controversy recently about whether consumers could lose access to certain channels they currently receive when the digital switch-over occurs. Although one study purported to demonstrate that reception of digital signals falls off sharply after 35 miles, the broadcast industry countered that the findings were not based on real-world signal-strength measurements and made incorrect assumptions about the types of antennas consumers will use. The best way to resolve this issue is with real-world tests in markets with various topographies, at various distances and with various home antenna options.

• Antennas: In a related issue, there is a lack of certainty regarding the number of consumers who will need new antennas in order to transition to digital service. Reports from the United Kingdom indicated that approximately 10% of households have needed new antennas. Given our different DTV-transmission standard and topography, we cannot assume a similar experience here.

• Cable/satellite coordination: We can and should assess whether cable and satellite systems will be adequately prepared to receive and pass through broadcasters’ digital signals in February 2009.

• DTV-equipment installation: The United Kingdom has a program to provide eligible households -- including the elderly and certain people with disabilities -- with practical assistance in converting to digital. This could include help installing new equipment and learning how to use it.The United States, by contrast, has no formal in-home assistance plan. We can and should explore issues such as: (1) difficulties consumers have installing DTV converter boxes and connecting peripheral equipment (e.g., VCRs); (2) particular difficulties faced by certain communities, such as the elderly, people with disabilities, and non-English speaking consumers; and (3) difficulties consumers have in using the new equipment, including analog pass-through functionality.

• DTV-equipment functionality: We can and should assess whether functionalities such as closed captioning and V-chip work with converter boxes and other DTV equipment.

• Consumer reactions: After the field testing is complete in a particular household, we can and should assess the consumer’s views of the difficulties, costs and benefits of the DTV transition.

I urge you to convene a working group as soon as possible to begin exploring potential test markets and timing. This working group should be a public-private partnership led by the FCC and should include representatives from government, industry, consumer groups and others. Once test markets are identified, the working group should work with local broadcasters, state and local officials and local community groups to organize and conduct the tests. The ultimate results could, I believe, significantly enhance the effectiveness of our efforts to prepare consumers for what is going to be a major challenge.

I look forward to working with you and our colleagues to implement workable proposals like these. Although we have less than one year to go, there is much that can still be done to make the DTV transition as smooth as possible for the American people.

Warm regards,

Michael J. Copps

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