LPTVBA comments on ATSC3 Mandate

April 24, 2025

VIA ELECTRONIC FILING

Marlene H. Dortch, Secretary

Federal Communications Commission

45 L Street NW

Washington, DC 20554

RE: Authorizing Permissive Use of the "Next Generation" Broadcast Television Standard (MB Docket No. 16-142)

The LPTV Broadcasters Association (“LPTVBA”)1 fully supports the NAB’s proposal for full power stations to have a mandatory transition to ATSC 3.0. However, we do not support a mandatory transition for low power television stations, television translator stations, or Class A television stations (herein collective referred to as “LPTV Stations”).

Throughout our participation in the “Future of TV Initiative,” LPTVBA made it perfectly clear that we supported a transition of full power TV stations to ATSC 3.0, but LPTV stations did not want to be forced to switch to ATSC 3.0 due to expense and a very unclear final purpose/business plan. LPTVBA’s position is two-fold: (i) there should be no mandatory sunset of ATSC 1.0, and (ii) a television broadcaster should have the flexibility to broadcast in any broadcast standard, as the local broadcaster knows what is best to serve its community. The LPTVBA position was included in the first two drafts of the summary report of Group 2 of the “Future of TV Initiative,” but curiously omitted from the final version of the summary report.

NAB touts the technological innovations and possibilities of ATSC 3.0, but neglects to supply the bigger picture. The Commission should not be fooled: the fact that consumers have purchased 14 million 3.0-enabled televisions is actually laughable, considering that Nielsen estimates there are 125 million households with at least one television.2 At best, the number of 3.0-capable sets in use represent less than 10% of the market, and many other estimates place it at 5%. The Commission should ask why, despite the fact that this supposedly incredibly advanced broadcast technology is now available to 75% of the U.S. population, less than 10% of households have decided to purchase a television that receives it.

Meanwhile, ATSC 1.0 has seen technological advances that should not be ignored. With MPEG-4 compression being used in sub-channels, LPTV Stations are delivering as many as 17 sub-channels with clear reception. These stations have invested in equipment to deliver high quality pictures and content that connect to their community. Forcing a transition potentially would cause viewers to be caught in limbo and push precariously profitable LPTV Stations over the edge. This is a particularly acute issue for LPTV Stations, which do not have mandatory carriage and are therefore viewed almost exclusively over the air (OTA). Full power stations have less concern given that the majority of their viewers still receive their programming over a MVPD or vMVPD.

The vast majority of LPTV stations are community operations with limited finances. They bear no financial resemblance to full power stations. A mandatory sunset of ATSC 1.0 and transition to ATSC 3.0 would be a major expense for LPTV Station licensees, placing a huge financial burden on small, local businesses. Because there is no demonstrated consumer demand, there is no proven financial benefit to transition to ATSC 3.0 (further proven by television manufacturers withdrawing from ATSC 3.0-enabled models). Frankly, the Commission should take note of the fact that only a very tiny percentage of LPTV Stations have converted to ATSC 3.0 (and some of those have already converted back to 1.0!), despite (1) having the ability to flashcut for seven years, (2) many having received repack funding to build out new facilities during this period (thus softening the financial blow to convert), and (3) having none of the burdens of 1.0 simulcasting required of full-power stations. LPTV Station owners must be nimble and responsive the audience, but there just simply is not an audience for 3.0. If anything, the Worldwide consumer electronics market will see the addition of 5G chips being placed in television sets starting in 2026, which paves the way for the worldwide standard as set by 3gpp, 5G Broadcasting, to be delivered not only into a television set, but a smartphone as well.

With the decline in traditional linear television viewership, LPTV operators need to be on the forefront of new technologies and community solutions that give access to the greatest number of OTA viewers, which then translates into a business plan. The cost of a voluntary transition to 5G Broadcast is far more reasonable than the transition to ATSC 3.0. LPTV Stations need the flexibility to invest in 5G Broadcast that embraces technological advances (i.e., transmitting directly into smartphones without the need of another chip or a SIM card). In contrast, ATSC 3.0 is a cumbersome and glitchy technology that has been difficult to deploy and has failed to offer sufficient value for consumers to outweigh the costs of upgrading household television sets. The FCC should not be in the business of picking technological winners and losers at all, much less when doing so will cause disruption to the public and possibly hasten the demise of the LPTVBA industry and independent TV voices generally.

LPTV plans to continue broadcasting in ATSC 1.0 to the hundreds of millions of existing television sets with that standard and to the millions of new ATSC 1.0 televisions sets in the production pipeline already. In addition, 5G-enabled sets will begin to be sold in 2026. It makes no sense to force the public to bear the financial burden of buying a 3.0 converter box or purchasing a television set for a standard that has not proven valuable and may quickly become obsolete in a 5G world.

However, if the FCC does mandate LPTV Stations sunset ATSC 1.0 and transition to ATSC 3.0, we must respectfully insist on a fund to cover the cost of this transition from either the FCC/government or from a fund financed by the full power broadcasters that are so adamant about a transition.

If LPTV makes any step to adopt “new technology,” then there should be a choice of ATSC 3.0 or 5G Broadcast, which will in the future deliver content and emergency alerts straight into a smartphone or home television set. By delivering pertinent linear program streams, emergency alerts in under ½ second, and new life saving solutions for public safety and first responders, 5G Broadcast is the worldwide standard of the future that can be deployed for the majority of LPTV broadcasters at a very reasonable cost. We urge the Commission not to get distracted by the potential for Broadcast Positioning System technology within ATSC 3.0. As will be demonstrated in the Commission’s “Promoting the Development of Positioning, Navigation, and Timing Technologies and Solutions” proceeding (WT Docket 25-110), there are other viable technologies to improve and strengthen the PNT system—including 5G Broadcast. Likewise, 5G Broadcast has already demonstrated its emergency alerting and public safety abilities, so NAB’s arguments about ATSC 3.0’s potential in this space is also unpersuasive. 3

In conclusion, the LPTVBA strongly opposes a mandatory conversion to ATSC 3.0, an almost outdated, 15-year-old standard. Broadcasters should be allowed to decide which broadcast standard best suits their community as they must financially survive based on those decisions. The LPTVBA bottom line: No mandatory transition, no sunset of ATSC 1.0, and promote standard flexibility to serve the public interest.