DTS Commenters Worried About Broadcasters Expanding Service Areas

Microsoft, public interest groups and some broadcasters disagree with NAB, America’s Public Television Stations, larger broadcasters such as Meredith and Tegna, and both the BitPath (formerly SpectrumCo) and PearlTV ATSC 3.0 consortiums on whether proposed changes to the rules on TV distributed transmission systems would lead to stations with vastly expanded reach. “The intent of the proposed rule change is not to have broadcasters reach viewers beyond their authorized service area,” said Pearl TV in comments filed by Friday’s deadline in docket 20-74, urging the FCC to “stay focused.” The FCC shouldn’t be “spawning monstrous megastations that are largely divorced from any real connection to the ‘communities’ that they are licensed to serve,” said TV broadcaster PMCM.

Many of the commenters focused on proposals in the NPRM that would allow broadcasters using distributed transmission systems to have some signal “spillover” outside their contour. The NPRM proposes allowing broadcaster DTS signals to spill over “to the extent necessary to achieve a practical design.” Gray Television, One Media and other broadcasters said that flexibility is needed to make DTS systems practical. DTS will enable broadcasters to reach customers that would otherwise have difficulty receiving a station’s signal, several broadcasters said. “Providing television stations with greater flexibility to deploy DTS and SFN is one of many steps that the Commission can take to encourage the transition to the next generation ATSC 3.0 standard," said Gray.

APTS and NAB, who originally petitioned the FCC for the DTS proceeding, said in a joint filing the proposal would strictly limit DTS signals from extending beyond the interference contour of the primary facility. That should avoid concerns that broadcasters are seeking to “’dramatically’ expand service beyond their communities of license,” NAB and APTS said. Concerns about broadcasters seeking to expand service areas were raised in a 2008 DTS proceeding, and NAB and APTS sought to avoid raising them again with their petition, they said. “Old Conventions” about what constitutes local broadcasting “may be due for reconsideration,” said BitPath. “In an era of mobile services, the concept of “localism”, imagined in an era when ‘television’ broadly defined was exclusively a fixed in-home service, is worth reconsidering.”

PMCM, Microsoft and others said the proposed standard is too subjective, and would become a workaround for broadcasters to expand their service area or cause interference to other licensees. “This is likely to disrupt, if not destroy, other secondary and unlicensed uses of the band, including particularly low power TV and access to sufficient TV White Space spectrum to narrow the rural digital divide,” said Public Knowledge and the New America Foundation’s Open Technology Institute in a joint filing. “It appears on the surface to be a thinly veiled attempt to increase the service area of a facility under the guise of a speedier rollout of ATSC 3.0,” said broadcast engineering firm T.Z. Sawyer. Tegna, Cox, and Meredith said the FCC should promptly approve DTS.

Microsoft and the public interest groups linked the DTS proceeding to the recent FCC declaratory ruling exempting ATSC 3.0 datacasting from broadcast ownership rules. “We do worry that the issues at hand are not solely about providing broadcast television to more remote viewers, but about creating a more seamless national coverage footprint for prospective Broadcast Internet Providers,” said Microsoft. The proposal “seems oriented to pave the way for them to aggregate and lease out their spectrum to third parties likely to use it for 5G or other broadband internet access services,” said PK and OTI.

Concerns about whether spillover signals would have the same primary status as full power broadcasters were also debated. The FCC should protect LPTV and translators from interference by such signals, sad Ark Multicasting and Watch TV. NAB and APTS said LPTV stations and unlicensed spectrum users are secondary to full power TV signals. “LPTV and TV translator stations should remain secondary to a full power DTS signal,” said Gray Television. “NTA cannot think of any justification for one station interfering with another outside of its service contour,” said the National Translator Association, which opposes the DTS proposal.

Several commenters said the FCC should streamline licensing for DTS stations and for stations transitioning to ATSC 3.0. Stations using ATSC 3.0 may seek to share single frequency networks, said Public Media Group. “The FCC’s current licensing scheme for ATSC 3.0 could be slightly modified in a minor way to help streamline the transition process,” Public Media Group said. “The current application form allows one applicant to license multiple transmitters but provides minimal flexibility for alternative structures,” said One Media.