NAB, along with several other broadcast groups, recently filed comments in a pair of Federal Communication Commission (FCC) proceedings that have been spun out of the recently passed satellite TV legislation, the Satellite Television Extension and Localism Act (STELA). STELA required the FCC to conduct one rulemaking to implement changes to its significantly viewed (SV) rules and another to assess the effect of STELA on its rules concerning the prediction and measurement of signal strength (antenna proceeding). Signal strength affects individual households’ eligibility to receive distant network signals by satellite.

In the SV Proceeding, NAB filed jointly with affiliate associations for ABC, CBS, Fox and NBC (affiliate associations). Affiliate associations argued STELA requires that a satellite carrier delivering a distant SV network station in a particular local market must (1) provide local-into-local service in the local market, (2) retransmit in SD format the local network station’s signal, whether a primary or multicast channel, as a condition precedent to importation of an SV duplicating distant network signal and (3) retransmit in HD format, if available, the local network station’s signal, whether a primary or multicast channel, as a condition precedent to importation of an SV duplicating distant network signal in HD format. Affiliate associations also urged that the FCC reject DISH’s request to initiate further rulemakings designed to provide MVPDs with unfair advantages in retransmission consent negotiations. Affiliate associations’ comments and reply comments can be viewed here and here.

In the antenna proceeding, NAB filed jointly with the affiliate associations for ABC, CBS, Fox and NBC and with the Association for Maximum Service Television. The joint filing urged the FCC to continue to rely on the Individual Location Longley Rice model, including its specification of an outdoor rooftop antenna to determine which households are eligible to receive distant network stations by satellite. There are so many variables that affect signal strength indoors that it would be impossible to arrive at any standardized set of parameters for predicting indoor signal strength.

Measurement of signal strength at individual household locations should, likewise, be done using an outdoor antenna. It would be impossible to characterize a "median" indoor environment, and performing measurements indoors would be inconsistent with the fundamental premises of the digital transition, which was based from the beginning on use of outdoor antennas.

The filing also urged that all multicast streams be treated equally for purposes of both prediction and measurement of signal strength; that the FCC should continue to use the analog ILLR model for LPTV, Class A, and translator stations that are still broadcasting in analog; and that the FCC should continue to rely on its current approaches to land use and land cover and to location and timer variability. The comments can be viewed here. An engineering statement can be read here.