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New DTV Proposed Rules from FCC & NTIA; More

April 27, 2008

Where I'd like to be right about now -- the picture on the left, that is, Bora-Bora.

On Thursday the NTIA published a proposed rule that would relax the eligibility requirements for converter box coupons. To wit, nursing home residents would be eligible for coupons (one each), and certain people using P.O. box addresses would become eligible if they offer some other proof that they are a "household."

Comments on the proposed rule changes are due June 9.

Right now nursing homes and other assisted living institutions are not considered to be "households" and therefore their residents are not eligible for coupons. At the same time, the government (NTIA included) has targeted seniors as one of the primary demographic groups "at risk" of missing the DTV transition boat. While telling seniors they need to get a converter box for their antenna-driven analog TVs, the nursing home crowd is then told they can't have a coupon.

Needless to say, pressure has been brought to bear.

The folks at the NTIA don't yet know how to get coupons to nursing home residents, that is, how to verify that an applicant is a bona fide resident of a legitimate facility. They're asking for suggestions.

They also are debating whether they should allow the managers of the facilities to obtain coupons and boxes for their residents in need -- do everyone in one go, a mass buy. Probably a good idea, considering that many will have diminished mental capacity or not be able to hop in their cars and drive down to the local electronics store.

There is also the potential for abuse and fraud. Lots of scammers out there, unfortunately, waiting for new opportunities. Complicated issue -- one that Kneuer's NTIA chose not to be bothered with. Hopefully Baker will resolve it before Cheney's chum arrives. Er, sorry . . .

Post office boxes. NTIA now allows the use of P.O. boxes for coupon applications in limited situations for people living in Indian reservations, in areas where the Postal Service will not deliver to physical addresses, etc.

For other people, NTIA has been rejecting applications for coupons using P.O. boxes for their address. Many of those people have appealed, and NTIA has apparently been persuaded that some people have valid reasons for using a P.O. box address on their application (where the coupons will be sent), and so NTIA is proposing to expand the exceptions to the general rule.

Under the proposal, all you would have to do is prove you live someplace eligible by submitting: a valid driver's license containing the applicant's physical address; a utility bill (water, gas, electric, oil, cable, or landline telephone (i.e., not wireless or pager) bearing the applicant's name and physical address and issued within the sixty (60) days immediately preceding the date the coupon application is submitted, etc. You get the point.

Enough of that.

No sooner than the FCC had published their DTV consumer education initiative requirements than they were beset by industry lobbyists asking for clarifications and a delay in the effective date. Things the FCC had not thought about, they were.

These are not things consumers are going to notice.

The FCC rules (first go-around) required manufacturers of television receivers and "related devices" to include DTV transition educational materials with those products, starting for products that were shipped before March 31. So first of all, "related devices" was not specifically defined and includes products that aren't really connected to the transition, so that was narrowed. Then, the ambiguity about when a product is "shipped" was cleared up. And then there was the "who" -- the original rules applied to anyone who "manufactured, imported, or shipped" a TV receiver. Did all of those people have to add an education flyer? Apparently not.

Oh, and May 30 is the new effective date, to give everyone time to print up those educational materials and start stuffing them in TV boxes.

The second part is a "further" notice of proposed rulemaking.

The current rule requires that telecommunications carriers that receive funds under the Low Income Federal universal service program notify each of their low-income customers of the digital transition and include such a notice in their required Lifeline and Link-Up publicity efforts. Congressman Upton subsequently suggested that the FCC require them to send all of their customers the DTV transition information, not just the poor ones.

The FCC is asking for comments on this proposal.

In addition, they want to know if they should require cable and satellite systems to air DTV education public service announcements, as are already required for TV stations. (The FCC noted in the proposal that the cable industry is already engaged in a "$200 million digital TV transition consumer education campaign." Read marketing blitz.

Moving on.

There was an Associated Press article making the rounds this past week on converter boxes. The title was "The incredible shrinking TV screen," with the sub-title "Converter boxes will keep older sets tuned in -- but aren't problem-free." That latter bit may have been added by MSNBC, where I saw it, but wherever it came from, it's wrong.

The "shrinking TV screen" reference applies to the "postage stamp" picture I've been writing about. The article blames it on the converter box, but the culprits are the TV stations that have not implemented ATSC's Active Format Description data standard. My Insignia box properly decodes AFD data and presents programming correctly, without the black border, but only for stations that do AFD. I assume most other respectable boxes will also decode AFD data. I'm also assuming the article's author never heard of AFD.

Anyway, he also reviewed two converter boxes - Insignia and Digital Stream DTX 9900 (now sold at Radio Shack). This is a little of what he said:

"The two models we tried are quite similar, and opening them up reveals that their major components are in fact identical.

"We preferred the RadioShack's Digital Stream model for its user interface, which contains a program guide that allows you to look ahead at a channel's programming for up to 24 hours. It's bare-bones compared to the program guides that come with cable or satellite subscriptions, but hey, it's free. The Insignia also has a program guide, but it only tells you what the current and following shows are.

"Another minor difference is that the Insignia remembers the zoom setting for each channel, while the Digital Stream applies the same setting to all widescreen channels. Either way, you'll be using the zoom button a lot if you want to watch TV the right way."

No shit.

I found a consumer review of the Digital Stream DTX 9900 in an FCC regulatory docket, of all places. Nothing detailed -- he said he's had it a couple of weeks and it's worked well. The same consumer from Cary, NC, seemed smitten with the electronic comment process; he also submitted this short comment:

"Please consider updating your promotional material with this suggestion. 'If you will have one TV converter for a VCR and another for a TV in the same room, buy different brands of converters with incompatible remote controls. Otherwise when you change your TV channel you may inadvertently change your VCR channel.'"


There were a couple of other interesting consumer complaints:

From Fairless Hills, PA:

"The DTV education initiative FAILS to mention that not ALL of the local stations a viewer currently receives via NTSC broadcasters will be received using the converter boxes being sold/used to tune the DTV broadcasts. I have recently made the conversion in my household and am disappointed with the results I have obtained.

"WHYY (channel 12) a public broadcasting station is un-obtainable, while other major network carriers are marginal and/or to weak to maintain a continuous video/sound delivery reliably, therefore providing a non-intelligent delivery of their broadcast.

"Unlike the analog transmissions, digital reception has been a less than impressive experience at my location. There needs to be a positive way to ensure the USA public that this conversion does not leave the general population who are DEPENDENT upon the over the air broadcast for their television delivery needs baron on the cut over date. Who will be there to lead the way when an established and necessary communication tool vanishes and will force many to find a costly alternative to replace this once FREE service?"

There is no doubt that this is a common situation, due to three factors:

1) many stations are not transmitting at full signal strength on their interim digital channel,

2) digital broadcasts are either perfect or not there at all (or at marginal signal strength, there will be intermittant drop-outs and pixelization -- the signal is never constant; the strength goes up and down). For reliable digital reception, the antenna may need to be upgraded to one with higher gain. With analog, the picture degrades "gracefully," that is, gets snowy with wavy lines etc, with weak signals. And,

3) the digital receivers in converter boxes are not all created equal; some work better than others. Older receiver designs should be avoided, but the average consumer isn't going to know anything about that -- neither will the people selling the boxes.

The TV industry education campaign tends to ignore these problems, and therefore does not present solutions (too negative).

From Denver, CO:

"Most conversion information has been directed to antennae TV owners. Cable customers have been lulled by a message of "do nothing". Cable subscribers are just starting to understand we will have little benefit with standard cable services. We will have to pay more to the cable companies to get digital programining. Many who are buying new TV sets will not experience the technical value of the change without paying the cable companies more to upgrade service and systems. This expected higher income for the cable company taints anticipation of the viewer benefit."

Absolutely correct!

Speaking of complaints about high-def on cable systems, there was another one of those articles on MSNBC this past week. The title - "Cable TV under fire for degrading HD quality -- Owners of pricey home-entertainment systems complain quality isn't there."

Well, we all knew cable systems (and satellite providers as well) cut resolution on high-definition programming when they feel most consumers won't notice. Saves them bandwidth. And with no side-by-side comparisons available, most people won't know -- they've probably never seen true high-definition.

Almost anything is called HD these days, and digital standard-definition is frequently called "enhanced-definition" -- which is not a term defined by the ATSC. Marketing thing. (The picture on analog TVs is called "conventional definition.")

So, broadcasters are dragging their feet on implementing consumer-friendly AFD. That's a voluntary standard (so far). What would they do with a mandatory standard?

The FCC had set a May 30 deadline for broadcasters to implement the part of PSIP data standard that provides up-to-date program information to TV receivers, enabling them to display an accurate electronic program guide (for over-the-air viewers). PSIP = Program and System Information Protocol.

Broadcasters have been ignoring the requirement, apparently, and now that the deadline is imminent, they are lobbying the FCC to postpone it (instead of making their case way back when the requirement was a proposed rule).

Business as usual. Incompetent planning. Lots of that going around during this period of change.

Finally, another little bit about the network neutrality issue. At Tuesday's Senate internet hearing, FCC Chairman Kevin Martin explained how Comcast was blocking some internet traffic (apparently the same technique used by the Chinese government):

"The Commission has heard from several engineers and technical experts who have raised questions regarding the network management techniques used by Comcast for peer-to-peer traffic.

"The Commission is still investigating these complaints and we have not yet determined whether the actions violated our principles protecting consumer access to the Internet. However, Comcast appears to have utilized Internet equipment from Sandvine or something similar that is widely known to be a relatively inexpensive, blunt means to reduce peer-to-peer traffic by blocking certain traffic completely. In contrast, more modern equipment can be finely tuned to slow traffic to certain speeds based on various levels of congestion.

"Specifically, this equipment (1) blocks certain attempts by subscribers to upload information using particular legal peer-to-peer applications by pretending to be the subscriber's computer and falsifying a "reset" packet to end the communication, and (2) degrades the corresponding attempts to download information using the same peer-to-peer applications."


Until next week . . .