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
