Published by: Larry Bloomfield & Jim Mendrala
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February 9, 2001 

Tech Note – 072 

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Subject: Reader InputA chance to voice your opinion!

A sad story
From: Ed Norris

I bought a HDTV two years ago.  It cost me $9,000 and did not include a DTV receiver.  I waited and waited for the new generation of DTV HDTV receivers to come out and bought the Panasonic TU-HDS20 this past Saturday in hopes of seeing the Super Bowl in HDTV.  The Panasonic, with the new oval dish, set me back another $1300.  The top of the line Radio Shack outdoor TV antenna and mount set me back another $200.

I spent all day Saturday and most of Sunday morning installing the new equipment.  At 12 noon on Sunday I was finally able to turn the TV on with the new HDTV receiver.  To my dismay, I could not receive ANY local HDTV signals!  I live in Simi Valley, CA, which is a suburb of Los Angeles.  I got out my GPS mapping program and checked and I am 81 miles away from the transmitter towers that are located on Mt. Wilson.  You would think that I would be able to receive the stations.

I am able to receive the one HBO HDTV from DTV, as well as the pay-per-view channel that they have.  However, I have now spent over $10,500 to be able to receive only two offerings of HDTV in a market that should be saturated with HDTV!!

Since it looks like it will be a cold day in Hell before the local cable carries HDTV my only option appears to be satellite. My hard question is this:  When the FCC approved for DTV and Dish Network to carry the local TV stations (for which there is an additional charge to the user), why did they not have the foresight to require them to also add the HDTV broadcasts???  The original purported purpose of satellite was to be able to supply customers that were in marginal reception areas with programming that they could not get anywhere else.  Why not include HDTV transmissions in this??

It seems that the FCC has missed the boat here (again!).  Can you tell me who I should write to so that I can express my opinion and concerns

Thank you very much, Ed Norris

(Ed Note: You’ll get just as far with this posting as you will writing to the FCC, if you have the same luck we’ve had.)

Subject: Delivery Systems
By Roy Trumbull – (Recently retired) Assistant Chief Engineer – KRON-TV

Broadcasters have limited enthusiasm regarding additional expenditures for delivering a signal. In major urban areas the cable companies are the method of choice for getting the signal into downtown areas and terrain blocked suburbs.  In rural parts of the country, where a station has to struggle to put together an audience, it’s much more common to see complex networks of translators to pick up the odd 1200 homes here and the 4000 homes there. Not all small communities have cable, so to count a community in a station’s audience base, the station has to do some work.

None of the DTV systems will work without repeaters. The idea of a central site serving a radius of 60 to 80 miles didn’t work in 1949 and not much has happened since to change that. Get over it. The benefit of 8VSB is that you get  adequate distant coverage with the caveat that terrain blockage may degrade the signal to zip. COFDM certainly has its advantages in the close-in zone where reflections are strong and multipath is severe. To say we are going to replicate the alleged audience area of the NTSC signal means that we are going to need to have our rural cousins instruct us in how to effectively use repeaters.

This is the business model I propose. In each market, a consortium, with an initial membership, of 3 to 5 stations is formed. It designs the repeater scheme, secures the sites, and constructs the system with an eye toward adding additional members later. The central site employs lower power than under the FCC plan as it no longer has to reach the full radius. Thus COFDM would work within the existing allocation scheme. Higher power wouldn’t be  required. Each repeater would operates at a power level appropriate to its task. Some will be low power gap fillers of less than 100 watts whereas others will be 1 to 5KW.

Each station will deploy 4 standard definition channels. One will be the “free” channel, which will carry the station’s normal programming. The remainder of the channels use programming from the highest rated “cable” channels. Set-top boxes will be required. The monthly fee is to be set so as to be very competitive with cable and direct broadcast satellite. There might be no fee. So what if only a dozen additional channels can be offered, the public has figured out that 500 channels of nothing is still nothing.

What happens when there is more HD programming? If the viewer selects the program via the transmitted master program guide, he will be able to receive the program regardless of its source. That permits some of the transmission slots of non-network affiliated stations to be held in reserve so that bandwidth can be freed up for HD programs on the affiliated stations. Thus MTV is here and two hours later it’s there but the switching scheme is invisible to the public.

The object is to make the broadcaster a serious competitor in the delivery business so that he can negotiate from a position of strength rather than weakness. The problem is that to carry this out requires VP/GMs to be more entrepreneurial. My impression is that the current generation gets high marks for “milking the cow” but low marks for starting new ventures. Fortunately it takes only a few individuals to launch a successful business model before everyone else jumps on board.

A business model that has strong advocates and backing is datacasting.  I tend to dismiss the datacasting option because it brings back memories of all of the schemes to make big bucks with an FM SCA. Many ideas were tried but few did much more than cover a portion of the site rent or the power bill. SCA leasing never produced a revenue stream comparable to selling program advertising.
Roy Trumbull

Subject: A letter to the departing FCC Chairman William Kennard
From: Bob Miller, New York City

Yesterday, Mr Kennard, your last day as Chairman of the FCC, you presided over an outright and egregious fraud on the American people.

In your speeches, the ones I've attended and those I've read, you champion free enterprise, the entrepreneurial spirit, helping small business get a toehold in the world of communications and bringing the benefits of our revolutionary times to minorities in the cities and rural areas.

However yesterday, as you prepared to leave your office, weeks after you announced your resignation, one of the last acts of your tenure was to deny all of the above. Based on undisclosed information that you received from sources within the FCC and a poorly-considered decision based on apparently false data from the recently completed NAB/MSTV (National Association of Broadcasters / Maximum Service Television, Inc.) television modulation test, the FCC issued a "Further Order" reaffirming the hotly-contested 8-VSB (8-Vestigial Sideband) specification as the only modulation standard for the US Digital TV broadcast transition.

This was totally unnecessary and will cost American consumers billions of dollars in unnecessary expense while at the same time denying them wonderful new High Definition TV and other terrestrially broadcast services for an indefinite time. The rest of the world has chosen a more recently developed and proven Digital Television modulation system that promises a cornucopia of advanced Television services. Forty or more countries have now chosen the COFDM (Coded Orthogonal Frequency Division Multiplexing) modulation system which has been deployed to far greater success  in the United Kingdom. While we have seen sales to dealers of under 70,000 Digital Television receivers in the last two years, England has seen over 1,100,000 units going to users who have signed up for their state of the art Digital Television service. Compare the penetration figures into TV households, assuming that every one of those 70.000 receivers is eventually sold (an extremely optimistic estimate), bearing in mind that the UK has less than a third of the TV households of the United States. Both services were launched in the same month two years ago, November 1998. If the US Digital transition was as successful you would expect 3.3 million users by now instead of something less than 70,000.

Our Digital Television system selection process has apparently been handed over to special interest manufacturer groups and backroom dealings of the Television Industry. The FCC has apparently abdicated their responsibility to ensure that the best technology is used in our land.

If this is allowed to stand it will be one of the blackest marks ever held against a Federal Regulatory Agency. I was a witness at the June 25th House Subcommittee on Telecommunications Hearings on Digital Television. I was, and remain, a proponent for the COFDM digital modulation standard. The standard that the FCC reaffirmed today as the American Digital Television standard is 8-VSB. At the hearings the two standards were debated and it became clear to me from FCC testimony at the hearings that the FCC does not have the internal technical ability to study and understand the various technologies. Instead the FCC relies on information fed to them by industry sources  who almost certainly have their own special interest at heart. Industry bodies like the ATSC, whose founding member Zenith Corporation, although in receivership, and owned by troubled Korean manufacturer LG Electronics, has complete ownership and copyright on the 8-VSB specification.

This was radically apparent in the last few days as a major test of COFDM and 8-VSB was finalized and reported on by the NAB and MSTV. This test was to be an impartial test of the two modulation schemes and I believe the FCC relied on the results to issue the Order that was issued yesterday that will saddle the US with a very inferior Digital Television system.

The results were not just incorrect, incompetent, misleading, or biased. I strongly believe they were fraudulent.  The persons in charge who were supposed to be impartial were not. When certain irregularities and anomalies in the contending system test receiver were pointed out at the final NAB/MSTV decision meeting, this hard evidence was discarded, and ruled out on a technicality. This was supposed to be an impartial scientific test of two different Digital television modulation schemes in which highly qualified professionals did their best to find the correct information so that the FCC could make an informed decision. Instead it was very one-sided test in which the COFDM data produced was totally incorrect. This happened despite the test personnel having known that there was a problem with the single COFDM receiver that they had picked for the test. One to two weeks into the four month long test it was known by the testers that there was a problem with the COFDM receiver that was making all data totally inaccurate. It would have been easy to fix the problem and how to do so, is common knowledge among technicians not nearly as qualified as those performing the test.

Nothing was done. In an atmosphere of total secrecy for four months the test went on to the tune of several millions of dollars and nothing was done.

This problem was somehow leaked from the testing program into public debate, but no one in the industry was worried since the testers were thought to be impartial and the identified problem had, as I said before, an easy fix.

On January 11th, the NAB/MSTV groups met and the bogus results were released, to a loud objection from parties who had identified the afflicted receiver standard. On January 15th they voted based on these contested results to recommend staying with the 8-VSB Digital TV standard. Yesterday you and the other four commissioners voted to stay
with 8-VSB.

The FCC subsequently made its order based on fraudulent data.

Some might say it is really only an argument between two interest groups  with different agendas and the fall out either way for the American consumer is very small, almost imperceptible, right? No, wrong!

There are major differences in the two standards. The COFDM standard (based on OFDM invented at Bell Labs in the USA in the 30s) was released nearly a decade later than the VSB system. Ultimately the most disturbing fact is that in six or seven independently authenticated tests across the world for the last 3 years, this is the first time that 8-VSB has apparently performed better than COFDM, entirely due to a deliberately anomalous receiver. The differences in performance have major consequences in terms of cost to the consumer, in terms of services rendered and in terms of who can get the services.

First, who can get the services? Broadcast television right now is received over the air to an antenna on top of your TV or on the roof to about 15% of TV viewers. This is a declining number. Each year it is lower, next year it will be 14 or 13%. One of the major reasons for the decline is reception problems. Over the air TV doesn't work very well and never has. Isn't that why you probably have cable or satellite at home?

The primary requirement of the new Digital Television system was that it at least replicate the coverage of the old analog NTSC system still in use. In other words those who relied on over the air TV could still get their TV over the air.

Curiously, there was no requirement that it be better than the old system even though you would think it should be, considering it is fifty years later and we should have learned something.

Well it could have been if you had gotten the right information and had chosen COFDM. Why didn't you look critically at the data from the MSTV test? Why didn't you call up a few people on both sides of the continuing debate to come in and comment on the test? Why was everybody in such a hurry to make this decision? In fact you didn't have to choose COFDM. You could have allowed it as a second (optional) standard.

Back to who can receive TV. The MSTV test that shamelessly subverted to political ends any sense of scientific impartiality and brings to the tongue the word fraudulent, was nonetheless accurate about 8-VSB. Maybe because the report so totally destroyed COFDM with its false data, the testers felt that they could be truthful about 8-VSB our current very weakly performing National standard. Finally, we got the truth about 8-VSB - at least since no one on the 8-VSB side is crying foul – and since it jibes with what I know about 8-VSB. I believe it is the truth. 

So here is the truth about 8-VSB according to the MSTV test just completed.

8-VSB doesn't replicate our current analog system which was its minimum stated requirement. If you can receive decent analog TV now over the air with an antenna you have a 92% chance of getting the new and unimproved (maybe disimproved is better) Digital TV. At best, that means 8% will lose all free to air TV that depend on it now. Well those are the poor unfortunate beings who will be unceremoniously  disenfranchised from the use of their spectrum by the wonders of Digital TV.

Not surprisingly these are the poor unfortunates who can't afford cable or satellite, unlike the A and B income TV executives, officials and engineers who made the decision. They are the  rural poor who also live past the farthest cable drop. They are the inner city resident who till now were disenfranchised by the reality of poor analog TV reception but now will owe that favor to the FCC.

By the way who will be enfranchised at the expense of these poor? Why the rich suburbanite couch potato who can afford the $10,000.00 to $50,000.00 home entertainment centers that HDTV is designed for. 

Who else can't get an 8-VSB Digital TV signal according to the report? Well 40% of all sites tried couldn't receive a DTV signal even with a 30 ft tower with one of those monstrous old Yagi antennas carefully aimed at the transmitter. These were sites out there in suburbia where 8-VSB is supposed to work.

What if you live in the urban canyons of a major city? Well even 30 ft towers won't help you there. Multipath interference caused by reflections of the signal from a forest of stationary and moving objects is going to raise that 40% to 70%  even for those who can obtain rooftop rights and install ghastly antennas 30 ft antennas all over the city. That's right 70% of those happy campers in the city won't get to use their free HDTV spectrum either.

Now what if you don't get real excited about the decorative look of the Yagi antenna on your roof and even less excited about getting up there to install it. Well you can try an indoor antenna. The MSTV test showed that only 26% could receive an 8-VSB signal indoors with various indoor antennas from $5.00 to $100.00.

Total? It's hard to total this mish-mash of numbers but when you try to average 74% failure with 40% failure with 70% failure you get a pretty big number, let's say 55%. Can we agree on that? Pick  a number somewhere between 40% failure and 74% failure and close your eyes - because that is what you did when you picked 8-VSB. The FCC had its eyes closed real tight when it picked 8-VSB the first time.

Chairman Kennard, you and your fellow commissioners just saddled the US with a grossly failed Digital TV system.  Why did you do it? You didn't have to. You had already resigned. What was the big hurry? 

Now that we have examined receivability or the lack of it (my number is over 50% so it should be lack of it), let's check cost.

With COFDM there is the strong possibility that the consumer would have to pay nothing for the Digital TV receiver. There are many business models that I know of that would accomplish that quite easily. COFDM is a worldwide standard and its economies of scale allow for the silicon cost to go down. Being sold to a current forty plus country group allows for economies of scale that already have kicked in. Current COFDM receivers cost wholesale as little as $100.00 and for more than a year have been given away in the United Kingdom with a $15/month subscription. This cost continues to go down. We believe that in the US COFDM receivers can and will be given away free without a subscription service.

Where COFDM Digital TV receivers can be given away , 8-VSB receivers after the same amount of time on the market, still cost between  $500.00 and $1500.00. The $500.00 model works much worse than the state of the art 8-VSB receivers which produced the poor reception numbers in the MSTV test quoted above..

Chairman Kennard, you and your fellow commissioners also decided today to start considering forcing 8-VSB receivers to be built into all TVs. A decision hailed by the CEA, who were very quick to hail the results from the NAB/MSTV tests as flawless. Who just happen to have as their priority increased sales of new consumer electronics appliances. You suggest starting with the big Digital TVs because it won't be as big a percentage of the price on the big ones. What do you say to the 55% (my number, plug yours in here) who can't receive a signal? Tough luck I suppose.

You would not be saying by any chance: "On top of disenfranchising you from your free over the air TV reception on the spectrum that you the citizen own we are going to further rip you off by making you pay for a Digital TV receiver that you will never use.

You are thinking that the economies of scale will get the 8-VSB receiver down to say $200.00 or $100.00 maybe lower? You put your lower number here, I can't go any lower. I think in trying to fix 8-VSB (A task force has been working on this for more than a year at the ATSC and has not released an official document yet) the number will probably go higher. Yes, higher than $500.00 and definitely higher than $200.00 for the tuner integrated into all TV's

That is a lot when you get around to adding it to a $50.00 portable TV. Going from $50.00 to $200.00 is a 400% increase. Oh I forgot 8-VSB doesn't work with portable TVs. Well that is an unexpected benefit. We don't have to buy mobile TVs anymore and we can throw all the ones we have away. But we will get to that in the third part, services. We are still looking at cost.

Let's compare COFDM with $200.00 receivers available now, that cost $100.00 to 8-VSB receivers that cost $500.00 to $1500.00 now. These receivers still need a lot of fixing that could take years - if it is even possible - and will raise the cost . But let's be kind and say by forcing this suspect technology into every future TV set we may get it down to $100.00 or $200.00.

Can we live with that? Well we could ask the 55% of the population who will pay for that Digital TV receiver but not be able to benefit from it. Do they think it is worth a $15 to $30 billion dollars to put non usable receivers in your TVs so that the rich suburban couch potatoes can watch the Super Bowl in HDTV? Here is the math, 75 million households X 2 TVs each X $100.00 or $200.00 X 55% =  at $100.00 that comes to $14,999,999,945.00 or at $200.00 that comes to $29,999,999,890.00

Between $15 billion and $30 billion wasted on forcing people to buy receivers in Digital TVs that can't receive a signal. There  is no scenario in which I can see the need to force anyone to buy COFDM receivers. A current COFDM receiver as an insert into the 8-VSB crippled Digital TV set would cost $50.00 or less in US quantities. Maybe as little as $25.00 or $30.00 per unit. So maybe you should have considered letting COFDM exist as a co-standard. At least then the people in the cities and rural areas would have a chance. The MSTV test also admitted that there would be no detectable difference in deploying COFDM or 8-VSB as far as interference. So why didn't you do it? Give the 55% of us we can't receive an 8-VSB signal a reason you decided to disenfranchise us.

COFDM has the additional added value of being receivable in almost all conditions even mobile up to 55 mph at near the highest data rate and up to 250 mph at a reduced data rate.

Sticking with cost we come to the cost of 8-VSB as opposed to COFDM. Even staying with the archaic big stick, single tower, high power broadcast model used in the US, the COFDM signal is receivable on simple omni-directional monopole antennas in a good part of its range, simple bow tie or rabbit ears in even a greater part of its coverage area and it would need to use 30 ft towers like 8-VSB only in a much smaller more distant part of the coverage area. I estimate the antenna cost for COFDM would be nationally one third that for 8-VSB. So if we say the average 8-VSB antenna cost for antenna and installation is $150.00 than it would be $50.00 for COFDM. However since COFDM can be received by 95% of the population its cost goes up by 40%.

Big savings for the 8-VSB side on antenna cost because 55% of the potential Digital TV audience can't get a signal and presumably won't bother to buy an antenna. Unless of course the FCC and HUD get together and force all homes to be built with Digital TV antennas. I'll wager you didn't think of that one? If you had all homes built with antennas, only 40% would be wasted since we know the failure rate on 30 ft antenna towers is only 40% not 55%. Wait I forgot in the cities the number goes way back up to 70% even with big ugly antennas. I guess we should stick with the 55%.

Maybe COFDM is just too easy, too cheap - it would probably wreck the economy. Well I think the greatest cost of 8-VSB is the 55% of the population that is disenfranchised forever from the free to air Digital TV experience that is theirs by right. Especially since they would not be disenfranchised if we use a more modern COFDM-based system.

The third consideration is the actual Digital TV experience, what can be delivered with 8-VSB and COFDM. What macro savings or cost each will

When you were considering COFDM and 8-VSB what weight did you give to the mobile issue, now identified as a priority commercial requirement by one of the agencies that is delighted with your decision, the ATSC, including Zenith, inventors of the 8-VSB system? I mean this is a modulation standard for the next 50 years right? What happens when all those Germans start bringing their mobile Digital HDTV's that have 40" roll-up screens (invented in 2007) and expect them to work on the beach in Key Largo like they do in Rio, Greece, the Black sea and Monte Carlo. How about when the Tokyo crowd hits the beaches of Maui with the new pocket rocket COFDM receiver projector from Sony that throws an incredible saturated HDTV image 15 ft across on the side of a building from a two pound laser device (invented in 2005).

How about foreign students who bring their Toshiba Slates,  2 lb flat 11" screens with virtual keyboard-equipped computers that receive Digital TV and high speed Internet over COFDM (available now!!!) while they are in school, at home or on the bus in most countries of the world? What will we tell them? I guess I would tell them to go home because they will have a hard time getting over this lost functionality in such an apparently backward society.

I tell you they are going to be surprised at how backward we appear to be. You will tell them that you had good reasons for picking the broken 8-VSB modulation system. Could you tell me one of those good public service reasons?

Do you realize that the 8-VSB system was never correctly tested before it was chosen? That the first real US test of 8-VSB happened between August and December of 2000 in secret and that results were announced to a simultaneous challenge of "anomalies" in test methodology (again) on January 11th, the public has not seen the results and may never. That the first preliminary tests, back in the early 90s, when COFDM was brand new, and not quite ready were according to experts like William Schreiber, Professor of Electronic Engineering Emeritus at MIT, similarly suspect? I assume that the FCC was now as then given the results and used those results in making the decision to recertify 8-VSB.

It seems strange to me that the first inadequate test of 8-VSB produced results good enough for the FCC to pick it as the modulation standard. Now nearly a decade later  using the results of a better test of 8-VSB which shows it to be total failure and not capable of being used as a Digital TV modulation system for the US, you decide to recertify it. . 

And based on those fatal pronouncements in that crucial test, within a few days and with no public debate of any kind, the FCC sticks the US with this monstrosity, 8-VSB again. I would have loved to hear that discussion. Or was there a discussion at all? Did the FCC, CEA, NAB, MSTV and ATSC all have their watches synchronized to get this job done
by yesterday? First there was the sanitizing of the ATSC report that was highly critical of 8-VSB in leaked copies in December that was delayed in being made public and came out much less critical on January 11th at the same time as the bogus test results came out. Then there was the NAB/MSTV vote on January 15th and the FCC order yesterday.

We were talking about mobile, ubiquitous and user friendly Digital TV reception. This is the reality of COFDM. It is something that 8-VSB cannot do. Our current television system works on portable receivers. Why do we have to give it up? What is the compelling public service reason that we have to suffer this loss? Can you give a good reason why in your conscientious deliberations you decided that for the next 50 years we didn't need mobile or portable Digital TV? You know HDTV can already be viewed on computer screens. It looks great. Laptop computers could be HDTV receivers - they already are HDTV displays. They will be all over the world but here. Why?

COFDM allows for the use of on channel repeaters. That means that using the same frequency you can rebroadcast the original signal without regard to in interfering with the original signal. You can't do that with 8-VSB. It is a big deal and one of the main reasons that other countries choose COFDM. 8-VSB has to use other frequencies (other channels) to do the same thing. This is very wasteful. In the US we currently use over 5000 other channels to rebroadcast our 1600 analog stations to hard-to-reach rural and terrain-challenged viewers. Has someone at the FCC considered that there are not 5000 more channels to be found to support the rebroadcast of the 1600 Digital TV stations. This may mean that the FCC has decided to write off most of the rural areas of the US for the Digital TV revolution. 

COFDM would not only not need the 5000 extra stations but would free up all 5000 now being used by analog stations when the digital transition is over and the analog stations go off the air. The recovery of those 5000 stations alone should have been enough to choose COFDM if all else was equal. All else is not equal.

The use of on channel repeaters works in the neighborhood also. We mentioned above that at the far edge of coverage COFDM, not as much but like 8-VSB, will need 30 ft antennas to receive an adequate signal. Instead of everyone in the neighborhood having these ugly antennas strapped to their chimneys with on channel repeaters and COFDM a single antenna could cover a large neighborhood, rebroadcasting with an Inexpensive repeater without interfering with the main transmitted signal. Everyone in the neighborhood could then receive with simple rabbit ear antennas indoors.

Unlike 8-VSB, COFDM allows for the use of modern network designs like SFN's (Single Frequency Networks). Very few engineers I have talked to in the modulation debates have any scientific or business argument against the use of SFN's. An SFN is a cellular-like Digital TV infrastructure that is composed of overlapping cells of the same station's signal. The ability of a COFDM receiver to tolerate, even to thrive off of, the same station's signal received at differing times and from different directions allows for many small broadcast antenna instead of one big antenna tower. This reduces power cost and promotes even better reception. An SFN allows for simple small 6" whip antennas that are hidden in the Digital TV or Digital mobile TV much like a cell phone.

SFN's allow a given station to accurately sculpt the borders of its coverage. This allows for the re-use of a local station's frequency in an adjacent market. This allows for more Digital TV stations in any given market. For example Channel #4 in New York is too close to Philadelphia to allow a Channel #4 there because of the big 1000 ft antennas and high power model currently used. With an SFN concept, Philadelphia can have its own Channel #4. This feature would allow for many new local stations in highly populated areas.

Did you run the idea of SFN's by the environmentalists? No more fried birds dropping out of the sky with SFNs. Maybe we can cut the leukemia rate. You must have had a hard time convincing the Green Party that the big ugly 1000 ft sticks were still necessary. Why again do we need 8-VSB so bad?

I have tried to make the point that COFDM is not a little different than 8-VSB, COFDM is radically different than 8-VSB.

COFDM is a revolutionary TV technology. Used in the US with the free over the air broadcast industry it will increase the present value of this spectrum 100 fold. Staying with the failed 8-VSB system will kill over the air broadcasting the moment you switch off analog.

COFDM will very likely be used in the US with spectrum that comes up for auction. However with that spectrum the benefits of this technology will have to be part of costly subscription services that will benefit individual users in an inefficient use of such prime beachfront broadcast real estate. The use of COFDM with the Digital TV free over the air service will benefit all Americans.

We met two times in New York City. Once at the New York Bar Association and the second time at the Museum for TV on 54th St. and once at the NAB convention in Las Vegas. Each time I was very impressed with your interest and apparently passionate commitment to your public service obligation.

This is why I find myself so disappointed by the statement you issued yesterday. Everything about it speaks of political pressure from a closed lobby of elements of the CEA, ATSC and other special interest groups, who all rushed to congratulate you with prepared statements which arrived simultaneously with your decision. A payback and at such incredible cost to the American people not just in money but in the loss of a major piece of spectrum and what it could do for so many people.

8-VSB disenfranchises the inner cities and rural areas whose inhabitants would stand to gain so much from COFDM. The suburbs where the ability to pay for cable and satellite service is the greatest are further enriched by a niche service called HDTV. Not that I am against HDTV. But COFDM can deliver HDTV as well or better than 8-VSB and to millions more people. Even the fat-cat Home Cinema enthusiast in the suburbs would benefit from COFDM. HDTV can be received mobile with COFDM and I wouldn't mind taking a 20" flat screen Digital TV that would effortlessly pick up exquisite HDTV right in the stands at the Superbowl.

Disabling broadcasting with 8-VSB should not have been your legacy. Enabling it with COFDM should have been. The test you relied on was fraudulent, the timing of the order much too convenient. 

8-VSB is a turkey, and a sick one. It will not stand.

Bob Miller, New York City

Subj: Real Estate/MDU Biz Wants Two-Way Ban
From: Sky Report

The Satellite Broadcasting and Communications Association is fighting real estate interests that want to ban over-the-air reception device rules for two-way satellite/broadband systems set up by apartment, condo and other multi-dwelling unit tenants.

The Real Access Alliance, which represents MDU property owners and other housing interests, filed with the Federal Communications Commission a motion to stay portions of the over-the-air reception devices rules (known in industry jargon as "OTARD"). The Real Access Alliance wants the agency to stay OTARD rules relating to "the receipt and transmission of fixed wireless signals via satellite or other radio signals."

The SBCA, in comments filed with the FCC this week, asked the agency to deny the alliance's motion.

"The FCC included within the purview of the rules all customer-end antennas and supporting structures of the same physical type, regardless of the nature of the services provided through the antenna," the SBCA said in its opposition comments.

Over-the-air antenna exemptions, which allow for the installation of satellite dishes and other antennas in certain areas - such as a patio or balcony - that can be accessed by MDU tenants, have long been fought by real estate interests.

Subj: NCTA Complains About DTV Labeling

What's in a label? Confusion, if it involves a description of a digital television set, according to one trade group.

The National Cable Association told the Federal Communications Commission this week that it should reconsider its labels for digital TV sets, saying descriptions the agency formalized last year will create unneeded confusion at the consumer level. The NCTA complaints center around the FCC's work on compatibility between cable systems and consumer electronics.

"Putting aside the fact that the labels adopted by the commission had never been subject to comment, the commission relied upon the term 'cable ready,' which carries a legacy of consumer confusion from the analog world," the NCTA said.

In September, the commission specified three categories for digital TV sets. They are: Digital Cable Ready 1, for devices receiving analog basic, digital basic and digital premium cable programming; Digital Cable Ready 2, which includes features found on Digital Cable Ready 1 sets along with the 1394 digital interface connector; and digital Cable Ready 3, sets that get digital cable along with advanced TV and interactive services.

The NCTA said the FCC should adopt more descriptive labels that would "ensure that consumers, when considering the purchase of a DTV set, can make informed decisions." The organization also reiterated its support for labels it developed with the Consumer Electronics Association in 1999.

When it signed off on the digital TV labels last year, the FCC complained that it would have preferred a "comprehensive market-driven solution" to the matter, but felt it had to adopt a regulatory approach "because the relevant industries were unable to develop a consensus."
Subject: Unit Conversions
By: Jim Mendrala

(Ed Note: A little off topic and besides, Mendrala doesn’t have much to do these days.)

In doing our jobs as Engineers we sometime have to juggle different systems of units. To convert from one type of unit to another can either be a chore or an opportunity for a disaster such as the demise of the Mars Climate Orbiter in September of 1999. That spacecraft burned up in the Martian atmosphere because of the failure of system engineers to convert critical parameters between different systems of units.

In a recent e-mail to Kevin Self forwarded by Chris Vanderbuilt of Flower Mound, Texas and appearing in the IEEE Spectrum magazine (Vol. 38, No. 2, pg 104) proves, not all conversions need to be a drudge. The following is a list of unlikely yet humorous conversion factors between different units. Chris thought this collection of equivalencies, most of which are a play on words or puns, was humorous yet have a technical bent that engineers would find interesting.

Here are a few examples:

Vaudeville comedians who’ve become engineers may find this definition handy: The time between slipping on a peel and smacking the pavement is defined as 1 bananosecond.

Broadcast engineers, 1012 microphones equals 1 megaphone.

Mathematicians living north of the Artic Circle would, of course, know that the ratio of an igloo's circumference to its diameter is Eskimo Pi. 

The force exerted by 1 kilogram of falling figs would be 1 Fig Newton.

Chemical engineers, or fans of ethyl alcohol in general, should know that 365.25 days of drinking low-calorie beer (Because it is less filling) is the same as 1 lite year.

Fans of science fiction shows and surveyors who use the rod in linear measurements should certainly be familiar with this conversion: 16.5 feet in the Twilight Zone is equal to 1 Rod Serling.

Anyone working in the medical industry might find it handy to know that half of a large intestine is equivalent to 1 semicolon, and that the basic unit of laryngitis is 1 hoarsepower.

If you are involved with transportation then 106 bicycles are equivalent to 2 megacycles, and the time it takes to sail 220 yards at a rate of 1 nautical mile per hour is 1 Knot-furlong.

To round out the list, 1000 grams of wet socks makes 1 liter-hosen, 2 monograms can be used to form 1 diagram, 10 millipedes are equivalent to 1 centipede.
Parting Shots
By Larry Bloomfield

I was going to do a bit of bragging about our website, but because of the length of this electronic epistle, I’ll give you all a reprieve. Give it a look-see if you haven’t yet. If anyone really cares, I have a new street address in Morgan Hill, CA. Everything else is the same. If you'd really like to have it, e-mail me.

I also wanted to mention a few things about the wonderful world of Harris Automation, but we’ll let that slide too, for now. I don't want to depress anyone.

Larry Bloomfield and Jim Mendrala publish the Tech-Notes. We can be reached by either e-mail (above) or land lines (408) 778-3412, (661) 294-1049 or fax at (419) 710-1913 or (419) 793-8340. The opinions expressed herein are those of the individual authors and do not necessarily reflect the opinions or positions of their friends, employers or associates.  If you wish to remove yourself from this list, send E-mail to:  In the subject area put the wordRemove”.

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