Advanced TV Broadcasting Alliance Among Few Seeking ATSC 3.0 Tuner Mandate

But that “entirely hands-off approach falls far short of the goal” of the 1963 All-Channel Receiver Act (ACRA) requiring that all devices be capable of receiving all frequencies allocated by the FCC to TV broadcasting, said the alliance, without mentioning the commission’s NPRM proposes a specific ACRA waiver for ATSC 3.0 reception. “Without a nudge from the FCC, the combination of the ‘chicken and egg’ problem and competitive resistance from wireless companies that are expanding into broadcasting could delay or altogether prevent many Americans from enjoying the benefits of Next Gen TV technology.”

It’s “not enough” to require ATSC 3.0 only on “large screens in the home in an era when each year witnesses an accelerating shift of viewing to more convenient and flexible devices that allow viewers to access television wherever they are,” said the alliance. Smartphones clearly fall “within the ambit” of the ACRA, it said. "Each includes an RF front end receiver, hardware and software to decode and process audiovisual programming, and high resolution screens and audio outputs that in many cases are more technically capable than flat-screen television sets.”

As low-power stations “seek to maximize any potential advantage to serve both fixed and mobile viewers, they require access to as many users as possible,” said the alliance. LPTV stations are a “conduit” for local programming access, it said. “They are uniquely situated to provide local emergency warnings to local viewers -- a service that is markedly enhanced by Next Gen TV capabilities.” Requiring tuners in all ATSC 3.0 reception devices “enhances the service” that LPTV stations provide, it said: “As many of these stations operate on a not-for-profit basis or at the margins of profitability, it is critical to their ongoing viability that their ATSC 3.0 broadcasts be receivable (especially given that many may face substantially smaller coverage areas post-repacking).”

The cost of adding ATSC 3.0 reception to large and small screens “will be small,” said the alliance. Large- screen TVs already have “the necessary RF front end,” it said. Current “traditional” TV sets and mobile devices “already include the great majority of electronics that are required to receive and display ATSC 3.0 transmissions,” it said: “Even mobile ‘phones’ today operate in former ‘low band’ television frequencies. Their RF front ends, if not already capable, can easily be modified, at least to receive UHF television channels.”

But LG Electronics is among those that agrees the FCC was right to tentatively conclude in its NPRM that a tuner mandate isn’t necessary now, the company said in its comments Tuesday. Declining to impose a tuner mandate “is in keeping with the voluntary nature of ATSC 3.0,” LG said.

LG thinks there already are “strong market incentives” for CE makers to develop receivers capable of receiving ATSC 3.0 signals, including TVs with HDMI ports to which an adapter or “other external receiver could be attached,” the company said. TVs with 4K resolution “are gaining popularity and will likely drive consumer demand for ATSC 3.0-enabled sets capable of taking advantage of the higher resolution and higher dynamic range broadcast signals enabled by ATSC 3.0,” it said. LG in South Korea already is introducing TVs capable of receiving ATSC 3.0 transmissions being launched this year in preparation for the February 2018 Winter Olympics, it said: “South Korea's early deployment of ATSC 3.0 also suggests that substantial amounts of research and development necessary to build ATSC 3.0-capable consumer devices will already be done by the time ATSC 3.0 is deployed in the United States.”

The FCC should incorporate into its rules both the A/322 and A/321 documents within the ATSC 3.0 suite of standards, as those are the only components “necessary to ensure a stable and predictable RF operating environment,” LG said. The A/322 document on “physical layer protocol” is “critical for ensuring that an ATSC 3.0 signal is reliably transmitted and received” because the physical layer is the “foundational element” of the next-gen broadcast system. The A/321 document on “system discovery and signaling” was included in the ATSC 3.0 suite “as an attempt to future-proof Next Gen TV so that sometime in the distant future, the emitted signal might be upgraded, and existing receiving equipment could still latch onto the newer signal,” LG said.

A/322 is “vitally important” to ATSC 3.0's physical layer, because it “carries the vast bulk of the data payload that enables all the video, audio and data features” of the next-gen system, LG said. While A/321 enables a receiver to find a transmitted ATSC 3.0 signal and “latch onto it” as a “bootstrap,” it’s A/322 “that defines the interference characteristics of the ATSC 3.0 signal and ensures that it does not interfere with ATSC 1.0 signals or other 3.0 signals,” LG said. “Both A/322 and A/321 are necessary for ensuring that an emitted 3.0 signal is reliably delivered to all reception devices, fixed and mobile alike.”

The AWARN Alliance “does not seek a tuner mandate” for reception of Advanced Warning and Response Network (AWARN) emergency alerts or any other ATSC 3.0 services, it told the commission. The AWARN network will be “the most advanced alerting system in the world,” and was developed through “the voluntary, inter-industry cooperation of broadcasters, consumer electronics manufacturers, other technology companies, service providers, and public safety organizations,” it said. Any “regulatory mandate” for ATSC 3.0 tuners or AWARN reception “could stifle the innovation that is driving continued development and eventual deployment of AWARN,” it said: “The Alliance’s reliance on market forces is grounded in the proposition that, as Americans become aware that AWARN alerts can provide lifesaving information instantaneously to their homes, worksites, schools, and to mobile devices literally at their fingertips, consumers will demand the service and manufacturers and service providers will respond for competitive purposes."

“Why saddle manufacturers and consumers with extra costs when broadcasters are under no obligation to affirmatively build out a 3.0 broadcast capability?” asked Consumers Union, Public Knowledge and New America’s Open Technology Institute in joint comments also opposing a tuner mandate. The groups also don’t think an HDMI port mandate is necessary, they said. “A consumer would be hard-pressed to purchase a new television today and in the future that did not have an HDMI port,” they said. “We feel the FCC need not consider an ATSC 3.0 tuner mandate or HDMI port mandate so long as consumers have access to an ATSC 1.0 signal.” When and if the commission considers a hard cutoff of ATSC 1.0, it should do so through “a future separate rulemaking” and “need not concern itself with a mandate at this time,” they said.