ATSC 3.0 Tuner Mandates Would Be ‘Counterproductive,’ Argue CTA, NAB

CTA, NAB, America’s Public TV Stations and the AWARN Alliance used their joint comments before the Tuesday deadline in the FCC ATSC 3.0 rulemaking docket 16-142 to argue against tuner mandates for the next-generation broadcast standard, as expected (see 1702240069). Adopting such mandates for ATSC 3.0 “would be counterproductive and unnecessary,” said the groups. Reply comments in the ATSC 3.0 NPRM are due June 8.

Broadcasters and the CE industry “are confident the market will address the need for Next Gen-compatible devices as Next Gen deployment spreads and consumers realize the benefits of the new standard,” the groups said. They cautioned “it is simply too early to predict how quickly this will happen,” though they said commercial development of ATSC 3.0 receivers would get a kick-start from South Korea's launch this month of ATSC 3.0 broadcast services.

Tuner mandates would be “heavy-handed government regulation" that would be “wholly unnecessary and will only frustrate consumers, particularly those in markets where Next Gen is not yet available,” said groups said. Forcing CE makers “to include tuners consumers do not yet demand will undermine the inter-industry cooperation that has been the hallmark of the development of the new transmission standard,” they said. “The Commission should adopt its tentative conclusion that a tuner mandate is unnecessary for the voluntary, market-driven deployment of Next Gen TV.”

For the same reasons, the FCC “should not pursue any requirement” that manufacturers include HDMI ports in TVs that would accept ATSC 3.0 tuner dongles for receiver upgrades, said the commenters. The FCC “lacks authority to impose this unprecedented requirement,” they said. “Any such requirement would be counterproductive and harmful to consumers, locking manufacturers into a needless cost associated with a specific technology regardless of marketplace developments. A better approach is to trust the consumer electronics industry to respond to the market.” By all current indications, requiring HDMI ports on future TVs appears likely to be a moot point because licensing administrator HDMI LA estimates 100 percent of new flat-panel TVs shipped today already have those ports, which began appearing on TVs more than a decade ago (see 1702270059).

The FCC should adopt only rule changes that are “necessary to permit broadcasters to move forward with deployment” in its proceeding on ATSC 3.0, said CTA, NAB and the other groups. “Rather than imposing mandates, the Commission should allow the consumer electronics industry to respond to market conditions and introduce Next Gen-compatible equipment as consumers demand it,” said the entities that introduced the original ATSC 3.0 petition. “The Commission should allow the market, not regulatory dictates, to determine whether or not Next Gen is successful.”

Broadcasters shouldn't "obtain MVPD carriage of ATSC 3.0 signals (in which viewers may have little interest) by threatening existing television service (in which viewers have a great deal of interest),” commented the American Television Alliance. ATVA warned the broadcast transition shouldn’t be a burden to others, an issue the American Cable Association focused on. Since smaller cable companies face more capacity constraints and are less able to absorb unexpected costs, the broadcast transition “presents particular challenges and requires particularized solutions,” ACA said.

Comments posted from private citizens dominated much of ATSC 3.0 docket 16-142 through Tuesday afternoon, before more trade groups and companies were expected to weigh in later on deadline day. Regardless of whether the FCC requires ATSC 3.0 tuners in new TV sets, which the commission has said it’s disinclined to do, “it seems there should be minimum tuner standards” mandated as part of the migration to next-gen broadcasting, commented Ronald Brey, of Rockford, Illinois. Minimum ATSC 3.0 tuner standards would “prevent overload by non-TV services and linearity requirements to reduce intermodulation distortion,” said the frequent commenter in past FCC radio and TV proceedings. “The tighter geographic packing of TV stations should require a specified minimum of adjacent channel rejection.”

The ability of ATSC 3.0 broadcasters to “vary bit rates, and thus signal-to-noise floors, would seem to suggest minimum sensitivity and noise figure standards for the tuners,” Brey said. Specifications for TV tuners “are scarce, if available at all, so even technically savvy TV set buyers are in the dark as to which tuner is better for their situation,” said Brey. “Hence, minimum tuner standards would be of great service to the public. If tuner standards are adopted, mandatory inclusion of ATSC 3.0 tuners in new TV sets might be an obvious additional step to take advantage of manufacturing economy of scale.” If the FCC opts not to impose minimum standards, a good fallback would be requiring that “every TV set with an ATSC 3.0 tuner have available a mandated list of specifications for the tuner,” he said. That would be “a good marketplace solution,” he said.