Engineers Back LG’s Request That FCC Adopt Both ATSC 3.0 Physical-Layer Documents

LG Electronics was right to urge the FCC to incorporate into its rules both the A/322 and A/321 physical-layer documents within the ATSC 3.0 suite of standards (see 1705100003), Hatfield & Dawson Consulting Engineers told the commission in comments posted Wednesday in the next-generation broadcast standard rulemaking proceeding (docket 16-142). The engineers' "primary concern" in the ATSC 3.0 rulemaking "is with minimizing the potential for intersystem interference among users of the broadcast spectrum," they said. “While in general we support a minimum of regulation, fundamental technical standards must be a part of the regulation package,” said the engineers. “A/321, by itself, is insufficient to define the waveform and interference requirements” of ATSC 3.0, they said. “A possible solution would be to incorporate A/322 as a part of the Commission’s rules, applicable to television broadcast content, allowing flexibility for use of non-television content so long as the basic emission waveform criteria are met.” LG has called the A/322 document on physical-layer protocol "critical for ensuring that an ATSC 3.0 signal is reliably transmitted and received." A/321 on system discovery and signaling was the only ATSC 3.0 physical-layer document that ATSC had ratified when CTA, NAB and others filed their petition for rulemaking last April asking the FCC to allow broadcasters to begin using the new broadcast standard (see 1604130065). ATSC ratified A/322 in September and approved a 2017 amendment to the document just this Tuesday. Reply comments in the ATSC 3.0 rulemaking are due Thursday.