The National Association of Broadcasters is urging the FCC to speed up its approval of distributed transmission services to authorized service areas.
In its reply comments on DTV distributed transmission system technologies Docket 05-312 before the commission, NAB noted that comments in the proceeding "enthusiastically endorse the many benefits DTS can bring to the viewing public and the digital television stations serving them."
NAB agreed with comments from broadcasters that, it said, "are in near unanimity that the FCC should not adopt the Table of Distances approach." NAB said DTS service should be authorized based on DMA, provided that stations continue to provide service to local communities and that they do not create interference to existing stations beyond that allowed under rules for single transmitters.
NAB cites comments from the Coalition for DTS, Paxson Communications, RBI and TV Plus emphasizing "the DMA approach is consistent with the traditional focus on localism, because service requirements for the community of license will not be altered and, today, these stations already serve the DMA via cable carriage."
NAB agreed that the FCC must modify its method of calculating interference to properly assess interference from DTS transmitters, saying, "NAB supports MSTV's general proposals in this regard as a reasonable starting point and will work with MSTV and the FCC as these modifications and extensions to OET-69 are defined."
NAB concurred with broadcasters who disagreed with the NPRM's conclusion that the DMA proposal would reduce opportunities for new stations, pointing out that DTS expansion will occur on a station's already-occupied channel and "thus, in almost all circumstances, new full-power television entrants would not be permitted on these channels because of interference." NAB suggested that to allay these fears, service outside a station's authorized service area, but within the DMA could be granted on a "secondary" basis, so that new station entrants, if and where possible, would not be precluded by the existing station's DTS service.
Commenters "virtually all agree" with the FCC's proposal for licensing DTS transmitters as part of a linked group covered by a single license under Part 73 rules and compliant with Part 73 rules regarding power, antenna height and emission mask, NAB noted.
NAB supported use of DTS for LPTV, TV translators and TV boosters. It agreed with MSTV that the same rules that apply to low-power stations (including classification as a secondary service) should apply to these stations' use of DTS. NAB agreed with MSTV that the FCC should not permit separate Class A stations to operate as a single frequency network, which would convert the separate stations into a "super" Class A station.
The 10-page filing provides a summary of broadcasters' comments in this proceeding. In addition to the topics covered here, the reply comments list the many benefits DTS can offer both broadcasters and the public.
Reply comments filed by the MSTV covered other topics, including New America Foundation's request that the FCC prohibit the use of DTS in order to reserve spectrum for unlicensed devices.
"The New American Foundation objections are groundless and should be disregarded," MSTV told the commission. "This position is puzzling, given that the primary purpose of DTS is to enhance the reliability of a broadcaster's existing service on its existing frequencies."
MSTV also noted that such concerns fly in the face of NAF claims that there are significant "white spaces" throughout the broadcast band. The comments point out that DTS would operate primarily on channel within a broadcaster's service area and question how such operations could be claimed to impact on the operation of unlicensed devices, unless the NAF spectrum studies were "erroneous and there is not significant 'white space' in most major markets."
MSTV concluded that "if on-channel or single-frequency DTS transmissions would 'substantially diminish' the amount of spectrum available to unlicensed devices, NAF has significantly erred in its definition and estimation of available white space."
Refer to MSTV's reply comments for more details on MSTV's opposition to NAF's comments and a review of concerns raised in its original comments. These and all other comments filed in the proceeding are available through the FCC Search for Filed Comments Web page. Enter "05-312" in the "Proceeding" box to retrieve the comments. MSTV's original comments were covered in the February 15 RF Report.
