California Energy Efficiency Regulations

The California Energy Commission has issued a rule that would single out digital to analog DTV adapters (DTAs) for artificially low energy consumption restrictions. These regulations will make it difficult or impossible to sell DTAs in California.

The ruling unfairly places a disproportionate burden on DTA devices. The circuitry required in a DTA is much more complex than that in either a DVD or Compact Audio device -- two devices that the CEC has allowed to consume more power than a DTA. Even when reduced to highly-miniaturized integrated circuits, the density of the chips in a DTA is much higher than that in the other devices. This higher density means that the devices must consume more power than the other devices.

The ruling unfairly discriminates against over-the-air broadcast television. The satellite and cable television industries have deployed settop boxes that are of a similar functionality to the DTA. Direct-broadcast satellite in the U.S. has employed a digital transmission system that requires a level of circuitry comparable to the DTA. In addition, cable television operators have begun deploying digital video services, again using comparable technology. Yet, none of these other devices appear in the CEC Appliance Efficiency Regulations.

The ruling will impede the digital transition and will make it difficult for low-income households to continue to receive free, over-the-air TV. DTA devices, and specifically the Federal DTA subsidy program, are targeted to make the digital transition convenient and of low cost, especially to low-income households. The ruling may make it difficult, if not impossible, to manufacture low-cost DTA devices during the immediate digital transition period. The addition of selective power functions to any electronic device means added complexity, and hence added cost.

The ruling will impair the ability of broadcasters and manufacturers to implement an effective emergency public-safety alert system. The DTA provides a novel platform for the reception of emergency broadcast messaging. This is due to the inherent data-delivery capability of the ATSC digital television system. One such use, currently under elaboration, is the potential for the reciver to scan incoming data, and automatically react and alert the consumer, even when the device is not active. In order to provide such a service, the unit must have certain functions active while in the standby mode. Such functions will in all probability require the unit to draw more power than is allowed in the CEC Ruling.

For all of these reasons, we urge the California agency to withdraw the rule.

FCC Consumer Advisory Committee

The FCC CONSUMER ADVISORY COMMITTEE received a report and recommendations from its Advanced Technologies Working Group regarding capabilities of digital-to-analog set-top boxes, closed captioning related to digital television and multicast channels, and a proposed consumer/disability impact statement for inclusion in FCC proceedings. The ATWG is charged with understanding consumer interest obligations and arriving at a consensus on the benefits to the public of advanced technologies. Early in the meeting, it was clarified that the ATWG cannot file petitions – however, it can submit comments on FCC rulemakings.

Highlights of the ATWG Recommendations

Rec 1: The FCC has proposed a consumer/disability impact statement for inclusion in the FCC proceedings. The Commission will establish a consumer disability statement & emerging technologies checklist. The purpose of this is to investigate and disclose the potential impact on existing services by disruptive new technologies (e.g., wired line removal, etc.).

Rec. 2: DTA Converter Boxes. The ATWG wants to understand what the capabilities of these boxes will be. There is a sentiment that at least basic analog-legacy broadcaster services must be supported: pass through of captioning, and other video services. The question was raised, “should it be the burden on the manufacturer to prove compliance?” One committee member joked, “will instructions be included?”

According to another committee member, the NTIA will open an NPRM to ask for public comments on what the DTA is: its functionality, as well as remarks on coupon distribution. A proposal was made that individual members of the group should be actively involved in the NTIA rulemaking. It was pointed out that the NTIA has no language – “someone is working on it” – on what the box functionality should be. Anne (Orr?) at NAB gave the invitation for the public to “work with us.” Julie Carney, CEA, said that the goal is to maintain analog functionality. Joel Snyder, NTIA, said accessibility of the user interface is important – regarding disability issues. Joe Gordon, (???) said that “we already have two boxes on the the set – cable and [???] – can the public be expected to have a third?"

A suggestion was made to encourage the FCC to work with NTIA on the DTA definitions. Among other topics, the ATWG wants clarification from the FCC concerning analog vs digital captioning; e.g., will captioning show up on digital channels?

During the public comments section of the meeting, Andrew Cotler of the Association of Public TV Stations reiterated that there is considerable consumer confusion about digital television: most consumers don’t know what it is, or how and when it will affect them. There is a lesson to be learned, he said, in the digital transitions underway in the UK and Germany: a unified, consistent, widely distributed message to consumers, wherever they are, is critical.

(See my NAB BEC 2004 paper, “Global Deployment of Terrestrial DTV.” - agc)

Several times during the meeting, we heard that there is need for a multi-industry consensus on the DTV transition – but where is the action item to carry this out? Everyone says we need better coordination of information, but there is no one spearheading the issue. It reminds me of Jonathan Winters' character in the film, "The Russians are Coming, the Russians are Coming." Amidst growing chaos, the police officer repeatedly admonishes the townsfolk, "We've just got to get organized."

- agc