There’s much more to adding DTV reception capability to an analog...

a deadline earlier than March 1, 2007, for requiring DTV tuning capability in 13-24” sets “is not achievable without unacceptable risk of quality problems and needlessly high prices for consumers,” TTE said, echoing virtually all other set makers and the CEA. The Commission has proposed moving up the current deadline on 13-24” sets to Dec. 31, 2006, from July 1, 2007. But TTE said there’s “no evidence” Dec. 2006 -- or an even earlier 2006 date that broadcasters have proposed -- “would be achievable for any manufacturer, much less for the general population of manufacturers.” DTV integration “requires a major re-engineering effort -- and in the case of smaller- sized sets, an entirely new chassis -- to accept the digital tuner, demodulator and other essential circuitry and related components,” TTE said. Also needed are cabinet modifications, all new reliability and safety testing, “and, of course, regulatory approvals,” as required for all RF emitters, TTE said. The FCC and Congress long have recognized the importance to set makers of the 18-month manufacturing cycle “in every instance where a new television technology has been mandated,” TTE said. “Truncating” that cycle “would introduce unacceptable levels of complication and risk” to product quality and availability and cause “needlessly steep price increases for consumers,” TTE said. “It also would be arbitrary and capricious as a matter of law.” TTE said it believes Congress “almost certainly will enact legislation this fall” setting a hard analog cutoff date in 2009. A March 2007 deadline for 13-24” sets would afford 22-34 months lead time before the analog cutoff -- “more than sufficient time for consumers to obtain integrated DTV receivers to accommodate the switch to digital broadcasting,” TTE said. The FCC is “erroneous” in speculating there will be only “modest” costs associated with building DTV tuners into 13-24” sets on an accelerated deadline, TTE said: “Integrating DTV tuning and reception capability will result in substantial increases in the costs of smaller-sized sets, as much as doubling the price of many 13” TVs and other products.”