CTA Intensifies Call for FCC to Include A/322 Document in Final ATSC 3.0 Rules

Previously, CTA said only that it wants the rules to “encourage” adoption of the A/322 document. In keeping with the voluntary, market-driven nature of the 3.0 transition, “CTA does not seek a requirement to implement A/322,” it said in reply comments in June (see 1706090026). Thursday’s letter appeared to be a reversal of that position.

Without a “defined modulation standard” for broadcasters’ 3.0 transmissions, such as that contained in the A/322 document, “there is a very real possibility of chaos in the marketplace and consumer rejection of ATSC 3.0,” wrote Julie Kearney, vice president-regulatory affairs, and Brian Markwalter, senior vice president-research and technology. The letter, posted Thursday in docket 16-142, was addressed to all five commissioners. Kearney and Markwalter didn’t comment Thursday on what prompted CTA’s A/322 position change and why so late in the 3.0 proceeding.

Unlike in the wireless domain, “where a small handful of nationwide carrier-providers are able to dictate to phone manufacturers what technology to incorporate into devices, no single broadcaster or broadcast group has the requisite market power to dictate to television manufacturers what technology to incorporate into television sets,” said CTA. It was an obvious swipe at Sinclair, which, with its One Media subsidiary, is lobbying the FCC aggressively against including A/322 in the final rules on grounds it would be redundant with existing rules on station coverage and interference and would stifle innovation (see 1706080054). NAB last month conditionally softened opposition to including A/322 in the final rules to give "confidence" to TV makers that think the A/322 document has value (see 1709110062).

One Media’s "consistent position is that broadcasters should be treated like all other regulated entities," Jerald Fritz, executive vice president-strategic and legal affairs, emailed us Thursday. "Others must simply abide by interference criteria. Broadcasters are subject to having actual standards incorporated into rules. We believe that the interference criteria currently applicable to broadcasters are and will remain more than adequate to meet the goal of non-interference. Despite this preference, to the extent any piece of the ATSC 3.0 standard is incorporated in the rules, the less the better." One Media thinks A/321 "is all that should be necessary," said Fritz. "Incorporating other parts of the standard simply is not necessary in a free market. We do not want to have to keep coming back to seek government approval each time the standard changes."

CTA thinks that in drafting and finalizing A/322, “the framers of ATSC 3.0 specified a robust and extremely flexible new modulation system” that’s “optimized to deliver all the benefits” of the next-generation system to fixed and mobile receivers, said the trade group. Design of A/322 “took into account broadcasters’ needs for flexibility and future-proofing,” it said. “More than 10,000 different emission parameters are possible with the waveform and coding choices available within A/322.”

CTA acknowledged it previously urged the FCC to “recognize that A/322 is an important aspect of ATSC 3.0 that will further facilitate the transition to Next Generation broadcasting.” CTA now also “recommends that the Commission should encourage this advanced modulation method for television services to be displayed on mobile, portable, and fixed devices.” Such recognition “will give device manufacturers more certainty and instill consumer confidence in new ATSC 3.0-enabled television receivers, thus further supporting the voluntary transition,” CTA said. “To ensure the successful launch and rapid adoption of Next Gen TV, CTA urges the Commission to incorporate into its rules the two critical components of ATSC 3.0" -- A/322 and A/321, CTA said. Failure to do so risks “disenfranchising viewers,” it said.