Letter to FCC in Support of ATCS 3.0 petition


FCC’s William Lake addresses questions at the ATBA LPTV Day event at NAB.

Federal Communications Commission
William Lake
Media Bureau Chief

We are writing this letter in response to the filing by NAB, CTA, APTS and the AWARN Alliance of a petition to the FCC to approve a new, optional ATSC 3.0-enabled broadcast transmission technology. The ATBA is an organization comprised of Thousands of low-power television (“LPTV”) broadcasters, owners and operators of broadcast translator and booster stations and services and allied industry organizations and companies.  For efficiency, unless otherwise stated or implied by the context, references to “LPTV” in this note include low power television broadcast translator and booster stations and services.

The effects of the Incentive Auction and subsequent repacking on low power and translator facilities will be widespread and negative. How widespread is anyone’s guess right now; in any event, the upcoming auction and impacts will only reduce the number of channels available for LPTV and translator displacement, broadcast modifications, and new broadcast facilities.
The ATBA is always looking for mitigating events or technologies and we believe that, ATSC 3.0 will be a help to LPTV stations to remain a viable part of the American broadcasting landscape.

We therefore support the petition and are very encouraged to see the public safety industries and the consumer electronics industries join broadcasters in taking all of our joint industries into the 21st century and helping LPTV survive the auction, along with a dramatic improvement in our distribution capabilities. We believe that this petition is an important first step in finally helping LPTV, as well as all of broadcasting, full power as well, which need each other to survive. We believe this will bring better coverage and services to LPTV, and our hope is that the FCC will move with great speed to unleash that innovation.

This is a very positive direction for the industry. We have been inside the process since the beginning and we support any new action, which may provide a positive impact for LPTV.
To date, the FCC has refused to take any credible steps to quantify (and is grossly underestimating) the destruction of the LPTV broadcast service, to achieve a wholly unrelated policy goal.

In addition to LPTV, most translator networks are “daisy-chained”.  Like Christmas tree lights, if one goes out, so do the ones further down the chain.  The translators closest to the source broadcast signal are often the most important. Since many small cable operators serving small communities rely on translators to receive the signals of major networks and public broadcasting, loss of one translator could result in a near total loss of broadcast service in a large area.

ATBA has always supported the fact that all broadcasters need flexibility to adjust service areas over time to implement new technology.

Respectfully submitted,
Louis Libin, Executive Director

Advanced Television Broadcasting Alliance

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Dear Fellow LPTV Broadcaster and Industry Leaders,

The auction has ended and most of us are still here.  While it was not only our hope but the hope of many others that the auction would not take place . . . it did, but it did not have the devastating effect that it might have had. 

The world after the auction looks different and amazingly so has a very bright future!

What does that future look like?  Not only the amazing possibilities of ATSC 3.0 but the landscape of a nation of people who are increasingly cutting their cable cords and looking for free, over the air, broadcasting content.

That’s why it’s more important than ever that you join the Advanced Television Broadcast Alliance.  Our board of directors have a combined 500+ years of experience which beginning with your membership we are going to start making more available to our members on an increasing basis.

Soon as an ATBA member, you will be eligible to start tapping into not only this brain trust through unique services available only to our members but regular news updates regarding our collective broadcast future.  We are exploring new ways to tap into information from Washington as well as important updates that will benefit you right there where you live.

The need for the ATBA has increased with the new opportunities that are becoming available for those of us who still know that the future of LPTV, Class A and Translators is bright!  Are you selling your station to local sponsors?  Are you maximizing your spectrum to the advantage that you truly can?  Are you struggling with FCC rules and regulations that you either don’t understand or can’t get explained?

The ATBA is developing a database of information to help you find the answers you need! 

In addition we are still working with the true decision makers in Washington.  Your ATBA has earned the respect and the ear of the true movers and shakers that continue to shape our collective broadcasting future.

So what can you do to get involved and begin to take advantage of these, and many other, benefits?  Join the ATBA today!  Your membership benefits will include:

  1. Members only access to hundreds of years of LPTV experience through our new “Brain Trust”
  2. Early entry to our annual NAB LPTV evening event with access to our special event guest(s)
  3. Exclusive digital content regarding real world information you need to know
  4. Eligibility for recognition for your hard work through our ATBA LPTV Awards
  5. Access to equipment manufacturers with discounts available especially for ATBA members!

To be honest you can’t afford not to be a member of the ATBA! 

We’re making it affordable because it’s a win – win!  When you join, you’re going to receive more than just the benefits listed above but also you’ll be aligning with hundreds of others who, like yourself, have a vested interest in the continued forward movement of free, over-the-air broadcasting.  It’s a win for your ATBA because we will increase our strength through numbers as we grow together.

So what’s the next step?  If you’re ready follow this link https://www.broadcastingalliance.org/join-us/ to sign up.  If you have more questions please don’t hesitate to call a member of the ATBA board of directors by calling this number (877) 214-4277.   You’ll get a rapid response!

Thanks for taking the time to read this note and for your ongoing passion for the future of communication in this great country.


The Board of Directors – The Advanced Television Broadcast Alliance