NAB President and CEO David K. Rehr sent the following letter to Community Broadcasters Association's Peter Tannewald in response to a Communications Daily front page story on March 3, 2008, reporting that Community Broadcasters Association (CBA) officials were threatening to "disrupt efforts to educate viewers about the [digital television] transition if their concerns aren't dealt with."

March 11, 2008

Peter Tannenwald, Esq.
Counsel to Community Broadcasters Association
Irwin Campbell & Tannenwald
1730 Rhode Island Ave NW
Washington DC 20036

Dear Mr. Tannenwald:

I am writing in response to a Communications Daily front page story (March 3, 2008) reporting that Community Broadcasters Association (CBA) officials were threatening to "disrupt efforts to educate viewers about the [digital television] transition if their concerns aren't dealt with." Surely CBA would rather work cooperatively to address the current issues facing low power television (LPTV) viewers in the digital television transition than this report suggests.

I appreciate and share your concern that low power television viewers without digital televisions will need to know how to access analog LPTV stations after full-power television broadcasters (and many LPTVs) end analog broadcasts and switch to all-digital transmissions on February 17, 2009. As you know, the National Association of Broadcasters (NAB) has proactively stepped up to proffer a list of actions we are ready to take to assist in solving this problem. But broadcasters are not willing to stand mute while threats are made to disrupt the massive DTV consumer transition that is well over a decade in the making.

I find it unfortunate that, as NAB and others are attempting to help address and solve the problem facing LPTV viewers, CBA lashes out with threats rather than working on solutions. It is also disappointing that, as recently as four months ago, CBA in written testimony submitted to the House Telecommunications Subcommittee failed to raise this issue.

Let me also express concern about the misimpression created by CBA on its Web site KEEPUSON.COM and in a television spot seen on that site that CBA apparently is distributing for airing on LPTV stations. The spot and the Web site say that "the ATSC-only [digital converter] boxes will block you from seeing 80% of the TV stations that are broadcasting in the United States." In reality, practically all of the 1,762 full power television stations are currently broadcasting in digital, reaching virtually all U.S. television consumers. By including in its calculation low power stations and TV translators that serve a small percentage of overall TV viewers, CBA distorts the real picture.

That said, NAB remains ready, willing and able to offer assistance to ensure that all television audiences - both low and full power - have the information needed to maintain their regular television viewing. We have proposed, and repeat our offer, to undertake the following eight concrete actions to promote viewer access to LPTV stations after the digital transition:

• Help the FCC and other interested parties determine the scope of the impact on television viewers:
• Help identify geographic areas where viewers only receive television via translators and LPTVs;
• Help determine how many Americans live in "mixed" areas that will receive both digital channels and analog signals after the transition in February 2009;
• Have NAB's LPTV Task Force work closely with the Community Broadcasters Association (CBA) to develop further solutions to the analog bypass issue;
• Urge the FCC to immediately complete its proceeding to assign digital companion channels for LPTV and translators;
• Educate potentially affected viewers via the DTVAnswers.com Web site and other outreach methods;
• Create spots that will air on low power television stations to alert viewers that they may need to purchase either: (a) a converter box that includes an analog pass-through feature, or (b) an A/B switch route-around kit (that we hope to make available);
• Create for the FCC, National Telecommunications and Information Administration, Community Broadcasters Association and others, a kit for affected viewers that includes an A/B switch, extra cable and instructions so that those who have purchased digital-only converter boxes can access analog stations;
• Encourage accelerated NTIA certification and FCC review of converter boxes that include the analog pass-through feature; and
• Advise CBA on how to create a user-friendly Web site and hotline that will answer consumer questions about the analog bypass issue. NAB is prepared to provide technical assistance.

In addition, NAB is launching a new Web site this month, LPTVAnswers.com, with all the tools and information viewers will need to know about LPTV and the digital transition. We would urge CBA also to make viewers aware of all the options for maintaining access to analog LPTV stations during and after the DTV transition. This includes the following specific options, which will appear on NAB's LPTVAnswers.com:

1. Purchase a new set with both analog (NTSC) and digital (ATSC) tuners and connect it to a suitable antenna. This is the option for viewers who wish to watch analog and digital programming interchangeably.
2. Purchase a converter box with analog-antenna pass-through capability and connect it to a suitable antenna. The converter box radio frequency (RF) output is then connected to the antenna input of the TV. Consumers can simply turn the converter box power off and use the television tuner to select the low-power analog station channels they are used to watching. They can turn the box on to watch a digital channel and tune the DTV channels using the tuner in the converter box.
3. Purchase a converter box that can receive both analog (NTSC) and digital (ATSC) signals. Note that because these boxes are generally used for HD television sets, they run well over $100. These boxes are also not eligible for purchase with a converter box coupon from the federal government.
4. Consumers who purchase a converter box without the analog-antenna pass-through capability and wish to watch both digital and low-power analog programming must purchase an antenna splitter and/or an antenna A/B switch and make some additional connections. Viewers can then switch back and forth between analog reception directly with the television or digital through the converter box. An A/B switch and splitter and additional antenna cables are inexpensive and can be found at most consumer electronic retailers. There are three possible ways to make the connections:
• The antenna is connected to the input of the antenna splitter and one of the outputs of the splitter is connected to the antenna input on the converter box. The other output of the splitter is connected to one input of the A/B switch, with the other input of the A/B switch being connected to the RF antenna output of the converter box. The output of the A/B switch is connected to the antenna input on the TV set. The TV is set to "antenna" for its source. Low power analog stations can then be watched using the tuner in the TV set. To watch digital stations, the TV is set to channel 3 or 4 and the converter box is used to tune the digital channels.
• The antenna is connected to the input of the antenna splitter and the two outputs of the splitter are connected to the antenna inputs on the converter box and on the TV set. The converter box output is then connected to the TV using the "line" or "video and audio" connections. In this case, no A/B switch is required. To watch low-power analog stations, the TV is set to "antenna" for its source and uses the tuner in the TV set. The converter box is used to tune digital stations, using the "line" input on the TV.
• In fringe reception areas, the small loss of signal strength through the antenna splitter may be undesirable, in which case the splitter in arrangement B can be replaced with an A/B switch, which must also be changed over when switching from analog to digital reception.

In addition to the list of actions that NAB is ready to undertake, the low power television community must share in the commitment to educate its audience via the airwaves about what steps they will need to take to maintain reception. Most importantly, low power stations must take all necessary steps to transition to digital transmissions as soon as possible.

As you can see, NAB is committed to a successful digital television transition, and stands by ready to help.

Best wishes.

Sincerely,

David K. Rehr