Analog to Digital Conversion

To:  IMCC Members and Friends

As you know, the Federal government has decided that all analog spectrum will be returned to the FCC on 2/17/09.  Thereafter, all over-the-air programming must be transmitted in digital format.  This has several ramifications for PCOs.  One question is whether PCOs have the technical/hardware/equipment means to deal with this change so that all subscribers will still be able to receive signals after that date.  Bob Palle of Blonder Tongue prepared materials to help PCOs understand what is needed for different situations in which PCOs find themselves.  Those materials were sent to you.  We have heard little reaction from PCOs or MDUs.  Therefore, I assume you understand what technical/hardware/equipment you need in order to comply as of the transition date.

The FCC has now adopted another rule with which PCOs must comply.  The rule requires all MVPDs to help educate consumers about the transition.  PCOs are required to communicate with all their subscribers giving them information about the change and what it might mean for their different subscribers in different circumstances.  That is, what will happen on the date, what consumers should do to make sure they are ready for the transition and how PCOs will facilitate the change so that all subscribers have TV sets or equipment needed to still receive signal after the date.

Below is a description of what PCOs must do in this educational effort.  It requires all MVPDs to include stuffers in monthly bills or to print information on the bottom of bills.  This will impact PCOs in different ways.  I have asked the FCC numerous questions, such as the following:

  1. Does a PCO need to comply with this requirement if that PCO has all the equipment and technology needed so that its subscribers will notice no change as of the transition date?  Answer:  Yes
  2. Does a PCO need to do this if that PCO acquires all its programming from a DBS company?  Answer:  Both the DBS company and the PCO must comply, see below.
  3. Does a PCO need to comply if the DBS company handles all the billing of individual subscribers and the PCO does not send out anything to subscribers on a monthly basis?  Answer:  The DBS company has the responsibility to educate the consumer, the PCO does not have the responsibility unless it communicates with its subscribers on a monthly basis.
  4. Does a PCO need to comply by informing all subscribers if the PCO provides video service to the MDU community through a bulk billing contract?  Answer:  The PCO needs to inform the HOA/MDU/REIT owner of the need to inform their residents, but it is the HOA/MDU/REIT responsibility to provide the required education.
  5. Does an HOA/MDU/REIT have the educational responsibility if it has and operates its own MATV system?  Answer:  Yes. In that case it is the responsibility of the MATV system operator and there is no PCO responsibility.
  6. When does this responsibility begin?  Answer:  Not exactly clear, but probably in May of 2008 and continue until March of 2009.
  7. Who is the FCC target audience?  Answer: The whole bloody world.  They want every consumer informed even if they are not directly effected by the conversion.

I know there will be other questions that arise as we move forward.

Below find the actual language of the new FCC consumer education rule.  It tells you what the PCO must do to help educate subscribers, what they need to be told and how that education must be accomplished.

As of today, do not do anything.  Please just read the requirements and figure how best to comply given your particular situation.

I assume that most PCOs will find printing information at the end of a monthly bill will be less expensive than doing a bill stuffer.  In the next couple of weeks I will supply you with a draft of what to print on the bill.

Transitioning Television Broadcasts from Analog to Digital (Sept. 2004)

Broadcast Television's Analog to Digital Transition (Dec. 2005)