Members of Congress*
Washington, DC 20515

Re: Digital-Analog TV converter box program

Dear Senator or Representative:

I am writing to bring to your attention a serious problem with the technical specifications, promulgated by the National Telecommunications and Information Administration (NTIA), for the Digital-to-Analog TV converter box coupon program. This problem will result in millions of Americans being deprived of the stereo audio sound that they currently enjoy using off-air reception of analog TV.

Under the coupon program regulations issued by NTIA (47 CFR Part 301, Docket Number: 0612242667-7051-01), the Agency failed to require, in its minimum standards for an eligible converter box, that stereo audio signals be present in the channel 3-4 RF connector at the back of the box. While the regulation allows such functionality as a permissible feature, it is uncertain that converter box manufacturers will make this feature standard. This will create a circumstance in which the audio portion of the broadcast signal will be degraded for consumers relying upon the federal coupon subsidy program.

The current standard of analog broadcasting is to provide color video along with stereo audio. The standard for stereo audio was introduced in 1984 (following the Broadcast Television Systems Committee – BTSC – recommendation) and subsequently made stereo off-air signals a matter of course in broadcast signals. Because the NTIA regulation fails to require BTSC stereo audio in the RF connector as a mandatory feature, millions of American consumers who will rely upon the coupon program will be deprived of stereo audio after February 2009 unless they take additional steps to purchase additional sophisticated equipment, or complete complicated assembly procedures to restore today’s standard audio features in the broadcast signal.

We can predict consumer behavior in following these additional procedures through experience with cable-TV set-top boxes. These boxes typically include an RF connector as well as separate left and right audio and video jacks, just as the NTIA’s DTV converter box does. Experience has demonstrated that the RF connector serves as the default connector to the television set. Very few consumers use the more complex separate jacks to connect TVs to set-top boxes. It is reasonable to assume that this same consumer behavior will apply to DTV converter boxes. For these reasons, most consumers who will rely upon the DTV converter boxes post- transition are going to rely solely upon the RF connector and its capabilities. For these consumer to maintain the stereo audio they currently receive, BTSC stereo audio must be present at the RF connector.

THAT Corporation filed comments with the NTIA on this matter. Enclosed is a copy of our filing for you to review. The NTIA acted to permit stereo to be carried at the RF jack, but fell short of requiring this necessary addition in their rulemaking. THAT Corporation has learned in conversations with potential converter-box makers that these manufacturers are universally planning not to include stereo in the RF connection. The result is that consumers will be forced to install additional wires, and in many cases, purchase additional equipment to maintain the same standard of performance they currently enjoy with their analog TVs.

As you know, Congress did not intend for consumers to experience a degradation of television broadcast quality post-digital conversion. Nor did Congress intend that consumers would have to endure complicated set-up procedures and additional costs – over and above the purchase of converter boxes – in order to maintain the same quality signal after the government-mandated conversion to digital television. Nevertheless, I fear this is what is in store for consumers as a result of the NTIA regulations for the coupon program.

I believe it is imperative that Congress immediately engage on this matter and act to ensure that consumers are aware of this potential problem with DTV convert boxes purchased under the coupon program. Congress needs to address this problem before consumers experience a degradation of the over-the-air broadcast signal in 2009. Specifically, Congress should hold hearings and receive testimony from experts who can highlight the limited capability of the DTV set-top box standards established under the NTIA regulations. This will serve to both educate the public on the potential shortfalls as well to provide Congress with an opportunity to learn of the specific plans on the part of potential manufacturers.

As you know, the deadline for the digital conversion is fast approaching and Congressional action is needed immediately. Thank you for your consideration of my views. I would be very pleased to provide you with more information on this important matter.

Sincerely yours,

Leslie B. Tyler
President, THAT Corporation

Enclosure: THAT Corporation Comments on NTIA DTV Coupon Program