HDTV 3DTV
BLONDER BROADCASTING CORP.
Isaac S. Blonder
8  Adams Way
Shrewsbury, NJ 07702
(732) 450-9972

Submitted to the FCC, January 1988

Comments on MM docket No. 87-268 in the matter of Advanced Television Systems and Their Impact on the Existing Broadcast Service. Review of Technical and Operational Requirements: Part 73-E, Television Broadcast Stations. reevaluation of the UHF Television Channel and Distance Separation. Requirements of Part 73 of the Commission's Rules.

What is suggested is a reassignment of the UHF TV frequencies to accomplish these desirable objectives:

1. Allow more UHF broadcast licenses.

2. Assign 12 MHz on a contiguous basis in order to provide spectrum space for the ATV systems requiring more than 6 MHz of bandwidth.

3. Preserve compatibility of the NTSC signal, so that none of the home TV's are ever rendered obsolete.

4. Provide additional spectrum space for land mobile, paging, data etc.

5. All of the above benefits with minor expense to the UHF TV broadcaster.

Isaac S. Blonder desires to comment on Docket No. 87-268 particularly from his experience as an independent UHF broadcaster since 1964, and also from his activities in the fields of engineering, manufacturing, and cable systems management.

Listed below are the recommended actions to be implemented by the FCC. Statements on these actions will parallel the FCC table of contents in order to serve a dual purpose for presenting Mr. Blonder's views on the specific issues discussed therein as well as to support his presentation.

1. Assign 12 Mhz of continuous bandwidth to each UHF station as follows:

Set 1. 17,18; 21,22; 25,26; 29,30; 33,34; 38,39; 42,43; 46,47; 50,51; 54,55; 58,59; 62,63; 66,67,

Set 2.15,16; 19,20; 23,24; 27,28; 31,32; 35,36; 40,41; 44,45; 48,49; 52,53; 56,57; 60, 61; 64,65; 68,69.

Thus a total of 27 12 Mhz channels would be available, sans taboos, observing only the present on channel and adjacent channel spacing, with channel 37 left open, resulting in two sets for assignments by adjacent channels rules.

2. Authorize the station to use the additional channel of bandwidth in any fashion it may find advantageous, e.g. two independent standard NTSC programs; one NTSC advertiser-supported program, land mobile, data, teletext, paging etc. Within the adjacent 6 MHz; HDTV; 3D-TV; etc.

3. Authorize the station to use a single transmitter and antenna to deliver any of the services suggested in 2.

4. Revise the taboos to recognize that the comparatively minor reductions due to taboo artifacts are not only temporary, but that the advantage of transmitting 12 Mhz is a positive economic gain for the established UHF broadcaster even when some reduction in his coverage area.

5. Avoid any requirement for an increased aspect ratio. There have appeared intriguing proposals for compatible ATV within the 6 MHz current bandwidth that will enable the 12 Mhz broadcaster to deliver simultaneously two ATV signals with the usual 4:3 aspect ratio. Also for the first time ever, two independent channels will permit the viewing of high quality 3D-TV in a satisfactory fashion for both the monocular and binocular displays.

6. Consider turning back the clock somewhat and assign the 14-20 channels as follows: 15,16; 19,20. 14 would be assigned to land mobile. The current occupants on 15-19 could make their deals with the UHF stations who now have a far greater bandwidth available for lease than the present assignments for land mobile, and ultimately these channels would be freed to become full service broadcast facilities.

7. Low power TV would also benefit from the new 12 Mhz bandwidth.

8. Technology exists for the delivery of four channels within 12 MHz at a quality level similar to today's standards. None of the published multiplex systems are compatible with NTSC. Unimaginable but not impossible to see an extraordinary effort on the parts of both the broadcasters and manufacturers in order to achieve a doubling of the channels in the major metropolitan areas to 38.

Responses to the Table of Contents.

Paragraph 3. As a UHF broadcaster since 1964, Mr. Blonder is intimately acquainted with the red ink so often associated with the disadvantaged UHF spectrum. It is not too late to save the day for UHF, and award every UHF station 12 MHz, with all the implied technical and economical benefits. The general public will be rewarded with superior picture quality, more programs, more stations, and more coverage. Although cable will continue to be the preferred source of TV for the majority, the lower income, and rural citizens deserve consideration for their plight from the FCC. One estimate gives 40 million as the long term uncabled viewers who need TV service at a low price, only available by land-based broadcast TV facilities.

Paragraph 17. Mr. Blonder takes sharp issue with the subject of "compressed aspect ratio" relative to a cinema-like aspect ratio. His views are expressed in a printed editorial, Exhibit 2. Besides the historical and technical arguments presented in exhibit 2, two more issues are either ignored or patronized - cost and home viewing habits. None of the published psychological studies investigating the preference for 16:9 versus 4:3 horizontal to vertical dimensions (incidentally, 16:9 is a rather feeble increase in ratio) gave the increased cost of 16:9 as one of the factors in the viewers choice of format. One company in limited production, charges $3,000 for a HDTV receiver. What percentage of the US public wants to pay six times as much for 16:9? Of course the the futurist will predict competitive prices in the gloaming, but even if you believe him, why do you need 16:9 in the home? The home viewing area is extremely variable and mostly small. Typically the screen size goes according to the pocketbook. Indeed 20% are still black and white. The angle subtended by the eye, in most cases, is around 10 degrees, whether in the format of 16:9, or 4:3, and substantially below the human field of vision (1:4), and thus there is little psychological stimulus from the minor increase in aspect ratio. Why burden the pocketbook of Mr. Average Citizen with the added cost of 16:9 and the extra bandwidth which may be better used for additional programming? Even in motion picture theaters where Cinema was born, the vast majority are screened with the standard 4:3 35 mm film and often with masking the top and bottom of the screen to simulate a wide screen format.

Paragraph 40,5. The immediate advantage of augmenting the channel capacity of existing Television assignments from 6 MHz to a contiguous 12 Mhz, is the economic survival of the broadcaster during the research and shakeout period of the various proposed ATV schemes. The second important economic advantage of two contiguous channels is the ability to transmit two channels on a single transmitter and antenna investment. The UHF broadcaster needs the added income to survive the stormy seas of format battles. Third, and most important for quality, only a single antenna and transmission pattern will provide stable artifacts if more than 6 MHz is need for the ATV system. In the real world of ghosts, noise sources and atmospheric anomalies, non contiguous frequencies, particularly if emanating from physically displaced antennas, may even drop the ATV picture quality below the level of a normal NTSC transmission.

Paragraph 43 There is no pressure from the general public to replace NTSC. Viewers have been polled many times, both formally and informally, and they have usually expressed their satisfaction with the present NTSC quality level. Only if new rivals such as Super VHS tape recorders, and HDTV DBS, appear, will there be a public outcry for change in the broadcast standards. Indeed the present VCR standards are lower than broadcast and yet have enjoyed a phenomenal reception by the general public. Remember that the same public is still buying black and white TVs, so it is obvious that the programs and price are the principal concerns of our citizenry

Paragraph 50. As has already been stated in the introduction, compatibility with the current receivers is of paramount importance, therefore the present 6 MHz bandwidth and technical standards should be retained. If finally a scheme is devised that will allow a single 6 MHz bandwidth to deliver the old NTSC picture and simultaneously ATV, with an appropriate TV receiver display, then VHF will be able to compete on equal picture terms with UHF. UHF will of course have two channels but this advantage will still not overcome the frequency superiority of VHF. And if it develops that UHF has a superior picture and a higher earning power than VHF, c'est la querre!

No changes need be made in the cochannel and adjacent channel spacings. All other taboos would be dropped. The small reductions in service area are a minor tradeoff penalty to existing UHF stations who would now be blessed with two individual programs and superior technology. There should be no problem technically in either transmitting the two channels or receiving them, since the television receivers have proven their ability to operate satisfactorily with adjacent channels on a cable system.

Paragraph 51, 52, 53. Coverage of the service area by microwave has been proven to be so inferior to UHF that the commission would be well advised to drop this item from the agenda.

Paragraph 60. The UHF taboos may be reasonably grouped into two categories; 1. radiation from the tuner local oscillator, tending to interfere with neighboring TV receivers, 2. internal receiver problems arising from unequal strength received signals.

On March 22, 1978, Blonder Tongue Labs submitted an unsolicited proposal for the purpose of developing, building and demonstrating a TV receiver with improved performance in response to RFD 76-22 April 19, 1976, suggesting the elimination of all taboos except on channel. Our proposal was not approved, nevertheless we sent a prototype to Lawrence Middlekamp for evaluation by the FCC laboratory. On March 7, 1979, we received a phone call from Alex Felker that the booster would perform as claimed.

As for the internal receiver problems, we suggested that the manufacturer install a temporary single low cost trap in the tuner, manually tuned by the viewer to suppress the rare cases of interference as may arise due to one of the other taboos. CATV has undeniable proven that a spectrum as wide as UHF can be viewed if there exists an equal level of adjacent TV signals. In due course, the TV designer will be readily able to eliminate the tunable trap and substantially satisfy the requirements posed by RFD 76-22.

Section 1V. The proposal to allow 12 Mhz bandwidth for each UHF station with 6 MHz always programmed to the current NTSC standard, answers practically all of the concerns expressed by the FCC in section 1 V. ATV will arise by two methods, both cost effective and responsive to new technology, and the public purse. 1. New TV display technologies will markedly improve the reception of the 6 MHz standard NTSC signal. 2. the additional 6 MHz awarded to UHF broadcasting can be utilized in any way the marketplace swings; digital sound, extended resolution, increased width-height ratios, 3D-TV format, and a myriad of non-TV clients who can be accommodated without having to beg the FCC for yet more spectrum space.

Paragraph 110, 111, 112, 113. In place of the present interference level standards as expressed by the taboos, on a mileage basis, the commission might find X desirable the adopt the non -interference protection procedure as outlined below for low power TV.

First, set a standard loss of service area due to interference of between 10-205 and arbitrate the remaining potential disputes within the FCC administrative Law Judge procedures. As has been previously mentioned, the UHF station should be willing to adept a minor reduction in service area for the major income potential afforded by a 12 MHz bandwidth