Comments on ET Docket No. 05-24 DTV Tuner Requirements Submitted by: Chris Llana [email protected] 809 Emory Dr. Chapel Hill, NC 27517 I submit these comments as a consumer interested in the successful and timely completion of the transition to the ATSC television standard. Since the CEA-CERC petition and the FCC’s rulemaking seem to be rooted in consumers’ alleged strong preference for television sets without digital tuners, my comments will address the options presented to consumers, and why the typical consumer makes his or her choices. If consumers’ preferences can be altered in favor of ATSC sets, the transition to digital/ATSC television can be expedited. As a starting point, I disagree with CEA-CERC’s twisted logic that delaying the onset of a requirement for digital tuners in the most popular 25” to 36” TV sizes to March 2006 will somehow advance the transition to the ATSC standard. That date is a year from now, and without a requirement, many millions of new NTSC sets will be taken home by consumers in that period. Each of those new NTSC sets will compound the quandary faced by the FCC and our friends up on the Hill: how do you appease the millions of American consumers who own perhaps almost-new NTSC sets that will be rendered nonfunctional when analog broadcasts are shut off? Subsidize STBs? A poor alternative. Right now the problem would seem to be that the typical consumer doesn’t understand the profound difference between NTSC and ATSC television sets. The so-called “HD-Ready” digital “monitors” are virtually all NTSC sets, as much as the plain old 480i versions, because they come with NTSC tuners and no ATSC tuners. An ATSC television is defined by the incorporation of an ATSC receiver. If it doesn’t have one, then it’s not an ATSC set. If it has only an NTSC tuner inside, it’s an NTSC set. My radical suggestion is to tell the consumer the difference between NTSC and ATSC televisions, and explain the ramifications for buying one or the other. And do it quickly. Then let him choose. He’ll choose ATSC. The FCC also states that one purpose of the phased-in digital tuner requirement is “to avoid disruption of the TV receiver market.” If this means avoiding a disruption of the continued sales of NTSC television sets, then the FCC is bound to fail in its regulatory efforts, as this purpose is at odds with the goal of completing a timely transition to the ATSC standard. One goal or the other must prevail. So why aren’t consumers willing to pay a little extra for an integrated ATSC tuner? The short answer is that they are uninformed and misinformed. There is now good information out there but you first have to know to look for it, then how and where to look for it. Lots of people “know” about HDTV, but only a few know the all-critical context. None of my friends knew anything about the transition to the ATSC television standard until I told them; they had no idea that each TV station is broadcasting two separate signals. Most people think there is only one signal that works with all TV sets, or as I have learned, many have no real idea how the picture gets to the TV set. Newspaper articles on digital television are few and far between, generally don’t mention a transition per se, and as a rule are dominated by misinformation. The Sunday newspaper TV program supplement lists only the NTSC channels; the digital channels just don’t exist. At Congressman Upton’s February 17 Telecommunications subcommittee meeting (The Role of Technology in Achieving a Hard Deadline for the DTV Transition), Rep. Terry spoke out against the labeling of televisions (educating the public) and claimed the only way to receive over- the-air HD programming was with a special $300 antenna, when in fact the old inexpensive “analog” antenna receives digital signals equally well. One would hope that someone in his position would not be spreading DTV myths that serve only to discourage consumers from adopting ATSC hardware, but if he doesn’t know the facts about digital television, it is not surprising that an ordinary consumer in the hinterlands doesn’t have a clue. (I thought it was also unfortunate that at the same meeting, Joe Barton, probably the person most able to move the transition along, disclosed that he had recently purchased an NTSC television for his personal use. Leadership by example?) Much of the problem stems from how digital/HDTV has been - 2 - marketed. Rather than come right out and say that ATSC digital/HD widescreen television represents a completely new and incompatible TV STANDARD that is REPLACING the old analog/NTSC standard, digital high-definition television is being marketed as a premium tier product (with integral NTSC tuners), with the unspoken presumption that traditional analog television sets are just a lower tier in the mix. The ordinary consumer has accepted that; the few informed consumers who have sought out guidance typically read that they can safely buy an NTSC set and not be concerned that it will become obsolete, that the analog shutoff will be years away and when it finally does happen, they can get an adapter. But at what sacrifice? Losing ATSC’s benefits for years to come? Fortunately, the information now in publications like Consumer Reports is a lot better than it was a year or two ago. I had thought we were finally making good progress until this proposed rulemaking was released, detailing the CEA-CERC petition. “They state that no matter how committed a retailer is to the DTV transition, the 50 percent rule provides an imperative to over-order the potentially scarce non-DTV tuner products and to under-order the more expensive products whose prices may be driven down later as a manufacturer seeks to achieve a 50/50 balance. “CEA-CERC state that this process and imperative have been present in the 36 inch screen size and above market during the current 50 percent environment, in which the costs of the DTV tuner accounts for a much smaller percentage of product cost.” I was amused by the suggestion that “no matter how committed a retailer is to the DTV transition,” there would still be a problem. Considering that a successful DTV transition requires the sale of ATSC televisions, it seems strange that a “committed” retailer would support the transition by deciding not to carry any ATSC CRT rear-projection sets. CRT rear-projection sets have been the most affordable and most popular sets bigger than 36”, as well as being arguably capable of presenting the best picture quality when properly adjusted. So why not offer at least a few of these models with integrated - 3 - digital tuners? Certainly some consumers want to receive OTA high-definition broadcasts. A “committed” retailer would be giving the consumer the good reasons why he should be buying those ATSC sets. When the new Hitachi CRT rear-projection sets with integrated digital tuners came out last year, I wanted to look at them but could not find a nearby Hitachi dealer that carried those models. I did find an internet forum string on the availability of those sets. People active in these forums tend to be the best informed about the DTV transition, and therefore tend to favor sets with integrated ATSC tuners. Two posts in that string are revealing: “Well I finally got a call back from someone at CC. Per Danny, the Senior TV buyer for Circuit City, they are NOT going to carry this model because it's a CRT RPTV with integrated tuner. But will carry LCD RPTV's with integrated tuner.” “I got the same reply as the store manager told me a tv with an integrated tuner is pointless because OTA in my area you can only pick up 3 hd channels but getting cable or satellite, you will get around 12-15.” In late February while preparing these comments I went to Circuit City and Best Buy to see if they were selling any high-def widescreen direct- view CRT TVs with integrated digital tuners (size range covered by this NPRM). Circuit City had two 34” high-end Sonys: one for $2000 and the other for $2200. These are very nice sets—hardly “entry-level.” They had no cheaper ATSC sets. When I asked the salesman if they had any more models with integrated tuners, he said no and immediately told me that they did not recommend models with integrated digital tuners. When I pressed for an explanation, he said you could only pick up a few local channels, suggesting instead that you could get local channels via DirecTV along with many other channels (they had a big DirecTV display and sold a range of DirecTV hardware). I told him not until later this year after DirecTV had launched a new pair of satellites would they be able to carry local channels in high definition, and only then in 12 major markets. The more I talked about the ways you could receive HD - 4 - programming, the less it seemed he knew. He seemed to equate high- definition with “digital,” as in “digital” cable, and “all-digital” DirecTV. I asked if they carried any digital-to-analog converter boxes; he didn’t know what I was talking about. I found two ATSC receiver STB models there: one for $250 and the other for $400. Then I drove to Best Buy.