Public Knowledge writes in support of efforts to end the digital television transition with a hard deadline for the return of the so-called “analog” spectrum. Signed by Gigi Sohn of Public Knowledge.
A PDF version of the letter is here.
Re: The Transition to Digital Television
Dear :
Public Knowledge writes in support of efforts to end the digital television transition with a hard deadline for the return of the so-called “analog” spectrum. Public Knowledge believes that the benefits to consumers of the returned spectrum will far outweigh the inconvenience and cost of the end of the digital transition, and that Congress should recognize that while there will be some bumps in the road toward the transition for consumers, none are insurmountable.
Completing the transition to digital television is vitally important for the economic and social well being of this country. While some have derided calls to speed the transition to digital television as a mere spectrum reclamation project, reclaiming that spectrum has undeniable and very palpable public interest benefits. These include the ability to vastly improve current licensed and unlicensed wireless telephone and wireless broadband services, including:
- permitting interoperability among local and national public safety and law enforcement personnel and enabling end users to send and receive video, pictures, data and phone calls. This will allow public safety officials to better communicate among themselves and with citizens in case of local and national emergencies;
- filling in cellphone “dead zones” where signals routinely get dropped; and
- providing wireless “last mile” Internet connections that can compete with copper-based DSL and coax-based cable modem services. These more powerful and lower cost connections would improve Internet access for health care agencies, schools and people in underserved areas such as rural and poor communities.
The higher quality and lower priced broadband services that the returned spectrum will facilitate will undoubtedly speed broadband adoption in the United States, which in turn will result in a citizenry that is better educated and better able to compete in today’s information economy. The U.S. currently ranks 16th in the world in broadband adoption, and the near-term return of the analog spectrum could provide the boost this country needs to improve that ranking significantly.
Public Knowledge believes that the main factor that will spell the difference between a relatively smooth and difficult digital TV transition is public education. It is quite clear that many consumers do not know that there is a possibility that their analog television sets will cease receiving broadcast television at sometime in the near future. Part of the reason for this is that the broadcast industry has done little, if anything, to promote the transition and the value of free, over-the-air digital broadcasting. Broadcasters must commit to real and substantial consumer education, including public service announcements and extended news coverage; if they do not commit to such an education program, Congress should consider mandating that broadcasters provide it. A hard date also gives the consumer electronics industry the information they need to effectively label television sets. The date most recently mentioned as the analog cut off date — January 1, 2009 — should give broadcasters, consumer electronics manufacturers, retailers and consumer advocates plenty of time to educate consumers, but they must do so starting now. Waiting until the waning moments of the transition to educate consumers will only cause panic and confusion.
Public Knowledge believes that the vast majority of consumers will do what is necessary to preserve their broadcast service once they understand that they must do something affirmative, and are educated about what exactly they must do. To the extent that Congress believes that it should provide some support for adoption of converter boxes for those who do not, or cannot afford to, receive digital TV signals, Public Knowledge would urge that such a subsidy be for a limited time (for example, six months prior and six months after the transition), be easy to administer, and that it involve some affirmative activity on the part of the consumer. This activity could include, for example, filling out a simple application or providing a small ($10-$15) upfront payment. However, simply placing boxes or vouchers in every mailbox invites fraud and is a waste of taxpayer dollars. In addition, broadcasters and others may have market incentives to provide free or low cost boxes to consumers — for example, broadcasters cannot charge premium rates for advertising unless they can demonstrate universal coverage.
We emphasize, however, that Public Knowledge’s core interest is in the swift return of the spectrum — so that the ultimate resolution of the converter box subsidy or any other related issue is of secondary importance. There is more than one way to facilitate a final transition to digital broadcast television, but any successful measure must include setting a hard date and a pro-active consumer education program. While we recognize that there are some economic and cultural differences, the transition to digital television in Berlin, Germany, is nonetheless an instructive example of how the transition can be completed with minimal consumer disruption. Consumers were informed early and often about the analog cut-off and were given several concrete options to transition. Those unable to purchase a converter box were given a subsidy. And in August 2003, analog stations in Berlin went dark with barely a complaint.
We believe that with pervasive consumer education and limitations on expenditures of taxpayer dollars, Congress can similarly make the transition to digital television a non-event. Public Knowledge will pledge to do its part to educate consumers about the coming digital TV transition, but no entity with a stake in the DTV transition has the reach and influence of television broadcasters. To the extent that the public has given broadcasters an interest-free “loan” of billions of dollars of public spectrum to transition to digital TV, the least broadcasters can do is provide the public with the information they need to make the transition a smooth one.
We look forward to working with you to bring a near-term, consumer-friendly end to the digital television transition.
Sincerely,
Gigi B. Sohn
President
