DBS, Broadcasters Continue to Spar Over STELA
The FCC’s proposed update to the Individual Location Longley-Rice model is “potentially useful” but includes “insufficient improvements to the model,” said Dish Network. It was responding to the FCC’s proposed adoption of a new ILLR model hoped to increase predictive accuracy. The FCC uses the ILLR model to predict broadcast signal strengths and helps determine who is eligible to receive affiliated distant signals, which are meant to fill in where consumers are “unserved” by broadcast signals. The proposed rulemaking was part of the FCC implementation of the Satellite TV Extension and Localism Act (CD Nov 24 p4), which broadcasters and DBS providers have clashed over before. The current model has led to significant overprediction, said Dish.
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The proposal, suggested by an outside engineering firm, seeks to add an Irregular Terrain with Obstructions Model (ITWOM) as a way to lower overprediction. The tests submitted by the engineering firm, Givens & Bell, show the current model has led to a situation where “as many 51 percent of households that are actually unserved are falsely predicted to be served under the model,” said Dish. While the ITWOM model lessens the overprediction, it wouldn’t eliminate it, it said. The FCC should confirm the test results from Givens & Bell and should adopt the ITWOM model, said Dish.
The FCC should use the methodology used by AntennaWeb.org, a website created by the NAB and CEA, to make the predictions, said DirecTV. That methodology is based on the ILLR and it gives consumers advice on whether they can receive broadcast signals, the DBS company said. Having created the site, broadcasters endorse this methodology even though it’s often different than the digital ILLR used by the FCC now, said DirecTV. AntennaWeb uses better geological and topographical data and makes adjustments to “location, interference, line loss, and the like to increase the model’s accuracy and reliability,” said DirecTV. DirecTV only mentions the Givens & Bell proposal in a footnote, saying it believes the AntennaWeb model provides a more straightforward method of improving accuracy.
The proposed ILLR changes aren’t warranted, said NAB and the Association for Maximum Service TV in joint comments. The FCC has recognize that the ILLR model provides accurate and reliable signal strength, they said. “Given its proven track record, any need to expend Commission and industry resources to make and implement marginal refinements is highly dubious,” they said.
There isn’t a statutory requirement that the FCC undertake this rulemaking, the associations said. Although the FCC is required to continually refine the ILLR model using additional data, the proposed modifications don’t “purport to do this.” they said. Instead, they propose changes that “go far beyond refinements and alter the very science used by the ILLR model,” the groups said. The modifications haven’t been peer reviewed by the scientific and engineering communities and there’s no evidence that the submitted testing results are accurate and can be replicated, they said. The NPRM doesn’t include any evidence that the modifications would increase accuracy because the “data provided shows virtually all the prediction errors in the proposed model to be positive, which will do nothing to more accurately predict eligibility to receive distant signals,” the groups said.