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 Federal  Communications  Commission  FCC  00-  184 
 Before  the 
 Federal  Communications  Commission 
 Washington,  D.  C.  20554 

 In  the  Matter  of 
 Technical  Standards  for  Determining  Eligibility 
 For  Satellite-  Delivered  Network  Signals  Pursuant 
 To  the  Satellite  Home  Viewer  Improvement  Act 

 ) 
 ) 
 ) 
 ) 
 ) 
 ET  Docket  No.  00-  90 

 NOTICE  OF  INQUIRY 
 Adopted:  May  22,  2000  Released:  May  26,  2000 

 Comment  Date:  June  27,  2000 
 Reply  Comment  Date:  July  12,  2000 
 By  the  Commission: 
 1.  In  this  proceeding,  we  are  opening  an  inquiry  to  obtain  information  for  evaluating  whether  the 
 signal  intensity  standard  used  to  determine  the  eligibility  of  satellite  television  subscribers  to  receive 
 retransmitted  distant  signals  of  network  stations  should  be  modified  or  replaced.  The  existing  standard 
 uses  the  Grade  B  signal  intensity  values  that  have  long  been  used  within  the  television  broadcast  service.  1 
 We  are  not  considering  alteration  of  the  Grade  B  standard  for  any  purpose  other  than  determining  eligibility 
 to  receive  retransmitted  distant  network  signals.  We  seek  information  and  comment  in  this  Notice  of 
 Inquiry  on  all  technical  parameters  that  scientifically  could  be  considered  to  affect  the  quality  of  over-  the-air 
 reception  of  television  pictures.  We  also  seek  information  and  comment  on  an  appropriate  eligibility 
 standard  for  digital  signals.  Based  on  the  record  that  will  be  developed,  we  will  submit  our  findings  on  this 
 issue  to  the  Congress.  We  initiate  this  proceeding  in  response  to  the  recently  enacted  Satellite  Home 
 Viewer  Improvement  Act  of  1999  (SHVIA).  2 

 1  See  Section  73.683  of  the  Commissions  Rules,  47  C.  F.  R.    73.683. 
 2  See  Consolidated  Appropriations  Act  for  2000,  Pub.  L.  106-  113,    1000(  9),  113  Stat.  1501  (enacting  S.  1948, 
 including  the  Satellite  Home  Viewer  Improvement  Act  of  1999,  Title  I  of  the  Intellectual  Property  and 
 Communications  Omnibus  Reform  Act  of  1999,  relating  to  copyright  licensing  and  carriage  of  broadcast  signals 
 by  satellite  carriers,  codified  in  scattered  sections  of  17  and  47  U.  S.  C.).  Section  1008(  a)  of  SHVIA  added,  inter 
 alia,  new  Section  339  (  Carriage  of  Distant  Television  Stations  by  Satellite  Carriers)  to  the  Commissions 
 statutory  charter,  the  Communications  Act  of  1934,  47  U.  S.  C.    151  et  seq. 
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 Federal  Communications  Commission  FCC  00-  184 
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 BACKGROUND 
 2.  The  broadcast  television  industry  has  the  right,  through  the  Copyright  Act  3  and  private 
 contracts,  to  control  the  distribution  of  the  national  and  local  programming  that  it  transmits.  4  In  1988, 
 Congress  adopted  the  Satellite  Home  Viewer  Act  (SHVA)  as  an  amendment  to  the  Copyright  Act  in  order  to 
 protect  the  broadcasters'  interests  while  simultaneously  enabling  satellite  carriers  to  provide  broadcast 
 programming  to  those  satellite  subscribers  who  are  unable  to  obtain  broadcast  network  programming 
 over-  the-  air.  These  subscribers  were  generally  considered  to  be  "unserved"  by  their  local  stations. 
 Pursuant  to  the  requirements  of  this  statute,  which  linked  the  definition  of  unserved  households  to  a 
 Commission-  defined  measure  of  television  signal  strength  known  as  Grade  B  intensity,  5  the  Commission 
 adopted  rules  for  determining  whether  a  household  is  able  to  receive  a  television  signal  of  this  strength.  6  In 
 particular,  the  Commission  adopted  rules  establishing  a  standardized  method  for  measuring  the  strength  of 
 television  signals  at  individual  locations  and  endorsing  a  method  for  predicting  the  strength  of  such  signals 
 that  could  be  used  in  place  of  actually  taking  measurements.  7  For  Digital  Television  (DTV)  stations,  the 
 counterpart  to  the  Grade  B  signal  intensities  for  analog  television  stations  are  the  values  in  Section 
 73.622(  e)  of  the  Commissions  Rules  describing  the  DTV  noise-  limited  service  contour.  8 

 3.  Grade  B  Contours  and  Signal  Intensity.  The  Grade  B  signal  intensity  standard,  which  is  the 
 key  to  the  SHVA's  definition  of  "unserved  households"  in  Section  119(  d)(  10)(  A),  is  a  Commission-  defined 
 measure  of  the  strength  of  a  given  television  station's  over-  the-  air  signal.  9  This  standard  was  developed  in 
 the  early  days  of  television  as  a  key  component  of  the  Commission's  channel  allotment  protocol.  10 
 Generally,  if  a  household  receives  a  television  signal  of  Grade  B  intensity,  it  should  receive  an  acceptable 
 television  picture  at  least  90%  of  the  time.  11  More  specifically,  Grade  B  represents  a  field  strength  that  is 
 strong  enough,  in  the  absence  of  man-  made  noise  or  interference  from  other  stations,  to  provide  a  television 
 picture  that  the  median  observer  would  classify  as  "acceptable"  using  a  receiving  installation  (antenna, 

 3  17  U.  S.  C.    119.  The  Satellite  Home  Viewer  Act  is  part  of  this  copyright  statute. 
 4  Satellite  Delivery  of  Network  Signals  to  Unserved  Households  for  Purposes  of  the  Satellite  Home  Viewer  Act, 
 CS  Docket  No.  98-  201,  Report  and  Order,  14  FCC  Rcd  2654  at    2  (1999)  (  SHVA  Report  and  Order). 
 5  See  17  U.  S.  C.    119(  d)(  10)(  A);  47  C.  F.  R.    73.683(  a). 

 6  SHVA  Report  and  Order  at    4,  supra  note  4. 
 7  Id.  at    8. 
 8  47  C.  F.  R.    73.622(  e).  See  also  47  C.  F.  R.    73.625(  b)  (determining  coverage). 
 9  17  U.  S.  C.    119(  d)(  10)(  A);  47  C.  F.  R.    76.683. 
 10  See  Television  Broadcast  Service,  Third  Notice  of  Further  Proposed  Rule  Making,  Appendix  B,  16  Fed.  Reg. 
 3072,  3080  (April  7,  1951)  ("  TV  Allocations  Third  Notice"),  adopted  by  Amendment  of  Section  3.606  of  the 
 Commission's  Rules  and  Regulations,  Amendment  of  the  Commission's  Rule,  Regulations  and  Engineering 
 Standards  Concerning  the  Television  Broadcast  Service,  Utilization  of  Frequencies  in  the  Band  470  to  890  mcs 
 for  Television  Broadcasting,  Sixth  Report  and  Order,  41  FCC  148,  FCC  52-  294  (1952)  ("  TV  Allocations  Sixth 
 Report  and  Order"). 

 11  See  O'Connor,  Robert  A.,  "Understanding  Television's  Grade  A  and  Grade  B  Service  Contours,"  IEEE 

 Transactions  on  Broadcasting  at  139  (December  1968)  ("  O'Connor,  Understanding  Television's  Grade  A  and 
 Grade  B  Service  Contours"). 
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 Federal  Communications  Commission  FCC  00-  184 
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 transmission  line,  and  receiver)  typical  of  outlying  or  near-  fringe  areas.  12  The  Grade  B  signal  contour  is 
 used  to  define  a  television  stations  service  area. 

 4.  The  Grade  B  contours  (which  represent  the  required  field  strength  in  dB  above  one  micro-  volt 
 per  meter,  or  dB/  P  v/  m)  are  defined  in  Section  73.683  of  the  Commissions  rules  for  each  television 
 channel,  as  follows: 

 Channels  2-  6  ................  47  dB/  v/  m 
 Channels  7-  13  ..............  56  dB/  v/  m 
 Channels  14-  69  ............  64  dB/  v/  m 

 Section  73.684  sets  forth  the  Commission's  methodology  for  predicting  a  TV  stations  Grade  B  service  area 
 coverage.  13  Section  73.686  describes  a  procedure  for  making  field  strength  measurements.  14 

 5.  A  signal  of  Grade  B  intensity  is  defined  as  a  discrete  value  measured  in  units  of  dB/  v/  m. 
 However,  the  absolute  intensity  of  broadcast  signals  at  particular  locations  and  at  particular  times  cannot 
 be  precisely  determined  through  predictive  means,  regardless  of  the  predictive  method  used.  Signal 
 strength  varies  randomly  over  location  and  time,  so  signal  propagation  must  be  considered  on  a  statistical 
 basis.  This  is  true  regardless  of  whether  the  signal  intensity  is  predicted  at  a  fixed  location  (such  as  an 
 individual  household)  or  over  an  area.  Some  prediction  methods,  including  the  Commissions  propagation 
 curves,  predict  the  occurrence  of  median  signal  strengths  (i.  e.,  signal  strengths  predicted  to  be  exceeded  at 
 50%  of  the  locations  in  a  particular  area  at  least  50%  of  the  time).  Under  this  approach,  location  and 
 time  variability  factors  are  added  to  the  signal  level  for  an  acceptable  picture  so  that  the  desired 
 statistical  reliability  is  achieved.  The  values  chosen  for  the  Grade  B  signal  intensity  account  for  this 
 variability  and,  therefore,  as  indicated  above,  predict  that  at  least  50%  of  the  locations  along  the  Grade  B 
 contour  will  receive  an  acceptable  picture  90%  of  the  time.  15 

 12  The  "median  observer"  is  not  the  "average"  observer;  rather,  it  is  the  observer  who  provides  the  middle  value  of 
 data  when  all  values  of  data  from  all  observers  are  ranked  in  order.  In  other  words,  50%  of  the  observers 
 recorded  values  equal  to  or  higher  in  value  and  50%  of  the  observers  recorded  values  equal  to  or  lower  in  value 
 than  the  median  observer.  See  TV  Allocations  Third  Notice,  16  Fed.  Reg.  3072,  3080  and  TV  Allocations  Sixth 
 Report  and  Order,  41  FCC  148.  See  also  NAB  Comments  Attachment  C,  Jules  Cohen  Statement,  at  2  and 
 Network  Affiliate  Associations  Comments  at  3  and  n.  110. 

 13  47  C.  F.  R.    73.684. 

 14  47  C.  F.  R.    73.686. 
 15  The  "time  variability"  planning  factor  used  in  the  determination  of  the  Grade  B  standard  may  be  a  source  of 
 some  confusion.  In  the  TV  Allocations  Sixth  Report  and  Order,  41  FCC  at  177,  the  Commission  adopted  the 
 initial  television  station  allocation  rules  and  stated,  "in  the  case  of  Grade  B  service  the  figures  are  90  percent  of 
 the  time  and  50  percent  of  the  locations."  See  also  TV  Allocations  Third  Notice,  16  Fed.  Reg.  3072,  Appendices 
 A  and  B.  In  CS  Docket  No.  98-  201,  supra  note  4,  both  the  broadcast  and  satellite  parties  stated  the  time 
 variability  factor  differently  than  above.  They  described  the  field  strength  at  the  Grade  B  contour  as  being 
 available  to  at  least  50%  of  the  locations  at  least  50%  of  the  time.  This  apparent  inconsistency  arises  from  an 
 adjustment  the  Commission  adopted  for  the  Grade  B  signal  strength  values  when  it  originally  established  them. 
 This  adjustment  results  in  a  Grade  B  value  that  predicts  reception  of  an  acceptable  picture  90%  of  the  time.  For 
 example,  on  channels  2-  6,  a  signal  strength  of  41  dB/  Pv/  m  is  needed  for  an  acceptable  picture.  In  order  for  this 
 signal  strength  to  be  available  90%  of  the  time,  the  median  or  F(  50,50)  field  strength  is  set  at  47  dB/  Pv/  m,  which 
 includes  the  addition  of  a  time  variability  planning  factor  of  6  dB. 
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 6.  The  acceptable  quality  contemplated  when  the  Grade  B  standard  was  developed  was  based 
 on  picture  quality  levels  used  by  the  Television  Allocation  Study  Organization  (  TASO).  16  TASO  used 
 data  from  actual  viewers.  These  viewers  were  shown  television  pictures  and  were  asked  to  rate  them  on  a 
 scale  from  1  (excellent)  to  6  (unusable).  Level  3,  on  which  the  Grade  B  service  level  was  based,  was 
 defined  as  (  Passable)  -  The  picture  is  of  acceptable  quality.  Interference  is  not  objectionable.  17  Based  on 
 the  results  of  viewer  ratings,  a  specific  signal-  (or  carrier-)  to-  noise  (S/  N)  ratio  at  the  television  receiver 
 was  found  to  correspond  with  the  level  3  picture  grade.  That  is,  a  specific  level  of  signal  corresponded  to  a 
 picture  quality  that  the  median  observer  identified  as  acceptable.  Given  this  correspondence,  and  with  the 
 primary  goal  of  creating  service  areas  with  minimal  interference  and  maximum  coverage,  the  Commission 
 developed  certain  assumptions,  generally  described  as  planning  factors,  regarding  the  environment  in  which 
 acceptable  viewing  would  take  place.  18 

 7.  Use  of  Grade  B.  The  Commissions  rules  use  values  for  Grade  B  signal  intensity  in 
 connection  with  the  authorization  of  television  stations  and  the  determination  of  stations  service  areas  or 
 contours.  19  This  measure  was  not,  however,  created  for  evaluating  service  quality  in  individual 
 households.  Rather,  the  system  was  developed  to  address  the  problem  of  defining  station  service  areas  and 
 to  determine  the  proper  allotments  for  television  channels,  especially  in  the  early  days  of  television.  The 
 Commission  created  two  grades  of  service.  20  Grade  A  service  connotes  that  a  quality  [of  service] 
 acceptable  to  the  median  observer  is  expected  to  be  available  for  at  least  90  percent  of  the  time  at  the  best 
 70  percent  of  receiver  locations  at  the  outer  limits  of  [the  service  area].  21  For  Grade  B  service,  acceptable 
 service  is  expected  90  percent  of  the  time  at  50  percent  of  the  locations.  The  service  areas  were  established 
 to  effectuate  the  Commissions  stated  twofold  purpose  to  provide  television  service,  as  far  as  possible,  to 
 all  people  of  the  United  States  and  to  provide  a  fair,  efficient  and  equitable  distribution  of  television 
 broadcast  stations  to  the  several  states  and  communities.  22  The  signal  intensity  values  (also  referred  to  as 
 field  strengths)  were  determined  based  on  certain  assumptions,  which  differ  for  the  Grade  A  service  area, 
 typically  urban  and  suburban,  and  the  Grade  B  service  area,  which  includes  rural  areas.  For  example,  the 
 type  of  receiving  antenna  assumed  for  Grade  A  service  is  smaller  than  the  receiving  antenna  assumed  for 
 Grade  B,  and  the  definition  of  Grade  A  service  takes  into  consideration  man-  made  urban  electrical  noise.  23 

 16  See  Engineering  Aspects  of  Television  Allocation,  Report  of  the  Television  Allocations  Study  Organization, 
 March  16,  1959. 
 17  See  O'Connor,  supra  note  11.  The  interference  referred  to  here  was  from  random  noise. 

 18  Assumptions  were  made  as  to  the  quality  of  the  television  receiver  used;  the  signal  losses  that  take  place  in  the 
 wire  connection  from  the  receiver  to  the  antenna;  the  gain  of  the  antenna  to  be  used;  the  amount  of  electrical 
 noise  in  the  environment  that  the  signal  would  have  to  overcome  to  be  viewable;  and  the  variability  of  radio 
 signal  propagation. 

 19  See  Section  73.683(  a)  of  the  Commissions  Rules,  47  C.  F.  R.    73.683(  a). 

 20  TV  Allocations  Third  Notice,  supra  note  10,  16  Fed.  Reg.  at  3075. 
 21  Id. 
 22  Id.  See  Section  307(  b)  of  the  Communications  Act,  47  U.  S.  C.    307(  b). 
 23  16  Fed.  Reg.  at  3080.  The  receiving  antenna  assumed  in  the  planning  factors  for  Grade  A  is  a  half-  wave  dipole 
 antenna  for  VHF  and  a  8  dB  gain  antenna  for  UHF,  but  for  Grade  B  it  is  a  directional  antenna  with  6  dB  gain  for  VHF 
 and  13  dB  gain  for  UHF. 
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 Federal  Communications  Commission  FCC  00-  184 
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 DISCUSSION 
 8.  The  recently  enacted  SHVIA  revises  and  extends  the  statutory  provisions  of  the  SHVA.  With 
 regard  to  the  signal  standard  used  for  satellite  carrier  purposes,  SHVIA  adds  a  new  section  339(  c)(  1)  to  the 
 Communications  Act  of  1934,  as  amended.  24  Pursuant  to  this  new  section,  the  Commission  must  conduct 
 an  inquiry  to  evaluate  all  possible  standards  and  factors  for  determining  eligibility  for  retransmissions  of 
 network  station  signals.  If  appropriate,  the  Commission  is  to  recommend  modification,  or  alternative 
 standards  or  factors,  to  the  Grade  B  intensity  standard  for  analog  television  signals  set  forth  in  47  C.  F.  R.   
 73.683(  a)  and  to  make  a  further  recommendation  relating  to  an  appropriate  standard  for  digital  television 
 signals.  Our  goal  in  this  inquiry  is  to  identify  more  accurately,  and  consistent  with  the  SHVA,  those 
 consumers  who  can  and  cannot  receive  their  local  television  network  stations  over-  the-  air. 

 9.  We  will  begin  our  discussion  by  reviewing  the  technical  factors  used  to  develop  the  Grade  B 
 standard.  We  then  will  discuss  some  modifications  to  those  factors  that  may  be  useful  in  developing  a  new 
 or  modified  signal  intensity  standard  that  could  serve  as  an  eligibility  criterion  for  distant  TV  network 
 signal  reception.  Nonetheless,  as  Section  339(  c)  indicates,  there  may  be  alternative  standards  or  factors, 
 of  which  we  are  currently  unaware,  that  may  be  superior  to  the  existing  methodology  for  determining  signal 
 intensity  standards.  Therefore,  in  addition  to  seeking  comment  on  how  a  signal  intensity  standard  should  be 
 derived  from  the  methodology  employed  to  develop  the  Grade  B  standard,  we  seek  comment  as  to  what 
 alternative  standards  or  factors  would  prove  superior  to  such  standards  for  the  purpose  of  determining 
 eligibility  under  SHVIA.  Finally,  we  seek  information  and  comments  on  establishing  an  appropriate 
 eligibility  standard  applicable  to  digital  television  (DTV)  signals.  In  all  cases,  we  request  commenters  to 
 submit  a  substantive  technical  justification  for  their  proposals.  Where  alternative  standards  are  proposed, 
 commenters  should  include  in  their  technical  showing  a  methodology  for  predicting  eligibility  and  for 
 verifying  such  predictions  and  should  provide  information  on  the  accuracy  and  costs  of  the  prediction 
 model  proposed. 

 10.  Modification  of  the  Grade  B  Standard.  In  paragraph  7  above,  we  observed  that  the 
 Commissions  television  broadcast  service  rules  refer  to  Grade  A  and  Grade  B  field  intensities,  which  are 
 based  on  different  assumptions.  Grade  A  service  areas  assume  an  urban  or  suburban  environment  and  take 
 into  account  environmental  man-  made  electrical  noise.  Grade  B  service  areas,  unlike  Grade  A  service 
 areas,  include  rural  areas  and  presuppose  the  use  of  larger,  directional  receiving  antennas.  The  planning 
 factors  used  in  deriving  the  Grade  A  and  B  field  intensity  values  for  analog  TV  service  are  shown  in  the 
 following  tables. 

 24  Section  339(  c)  addresses  the  standards  for  DBS  subscribers  to  be  eligible  to  receive  retransmission  of  distant 
 TV  station  signals.  Of  particular  note,  section  339(  c)(  1)  requires  the  Commission  to  conduct  an  inquiry  to 
 evaluate  all  possible  standards  and  factors  for  determining  eligibility  for  [satellite]  retransmissions  of  the  signals 
 of  network  stations.  This  section  further  provides  that  the  Commission  is  to  if  appropriate  --  (A)  recommend 
 modifications  to  the  Grade  B  intensity  standard  for  analog  signals  set  forth  in  [47  C.  F.  R.    73.683(  a)],  or 
 recommend  alternative  standards  or  factors  for  purposes  of  determining  such  eligibility;  and  (B)  make  a  further 
 recommendation  relating  to  an  appropriate  standard  for  digital  signals. 
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 Table  1.  Grade  A  Planning  Factors 
 Factors  Units  Channels 
 2-  6 
 Channels 
 7-  13 
 Channels 
 14-  69 
 1.  Thermal  Noise  @  300  ohms  dB/  1v  7  7  7 
 2.  Receiver  Noise  Figure  DB  12  12  15 
 3.  Peak  Visual  Car./  rms  Noise  DB  30  30  30 
 4.  Transmission  line  loss  DB  1  2  5 
 5.  Receiving  Ant.  Gain  DB  0  0  8 
 6.  Dipole  Factor  DB  -3  6  16 
 7.  Local  Field  dB/  1v/  m  47  57  65 
 8.  Terrain  Factor  (70%)  DB  4  4  6 
 9.  Time  Fading  Factor  (90%)  DB  3  3  3 
 10.  Median  Field  F(  50,50)  dB/  1v/  m  54  64  74 
 11.  To  overcome  Urban  Noise  DB  14  7  0 
 12.  Required  Median  Field  dB/  1v/  m  68  71  74 

 Table  2.  Grade  B  Planning  Factors 
 Factors  Units  Channels 
 2-  6 
 Channels 
 7-  13 
 Channels 
 14-  69 
 1.  Thermal  Noise  @  300  ohms  dB/  1Pv  7  7  7 
 2.  Receiver  Noise  Figure  DB  12  12  15 
 3.  Peak  Visual  Car./  rms  Noise  DB  30  30  30 
 4.  Transmission  line  loss  DB  1  2  5 
 5.  Receiving  Ant.  Gain  DB  6  6  13 
 6.  Dipole  Factor  DB  3  6  16 
 7.  Local  Field  dB/  1Pv/  m  41  51  60 
 8.  Terrain  Factor  (50%)  DB  0  0  0 
 9.  Time  Fading  Factor  (90%)  DB  6  5  4 
 10.  Median  Field  F(  50,50)  dB/  1Pv/  m  47  56  64 
 11.  To  overcome  Urban  Noise  DB  0  0  0 
 12.  Required  Median  Field  dB/  1Pv/  m  47  56  64 

 11.  We  seek  comment  on  whether  there  have  been  any  technological  developments  in  television 
 system  equipment,  over-  the-  air  television  viewer  installations  or  picture  quality  expectations  that  would 
 warrant  a  significant  modification  to  the  planning  factors  on  which  the  current  Grade  B  standard  for 
 household  eligibility  for  distant  TV  network  signal  reception  under  SHVA  is  based.  Also,  are  any  of  the 
 planning  factors  for  Grade  A  more  appropriate  than  the  corresponding  Grade  B  factors  for  determining 
 distant  signal  reception  eligibility?  Comments  should  be  supported  by  technical  showings  evidencing  the 
 need  to  make  the  suggested  changes.  In  addition,  we  invite  the  submission  of  evidence  that  documents  any 
 significant  changes  in  the  television  reception  environment,  and  significant  changes  in  viewer  expectations, 
 that  have  not  been  documented  in  previous  Commission  proceedings.  In  this  regard,  analog  TV  Table  2 
 above,  identifies  all  of  the  physical  factors  which  to  date  have  been  generally  considered  to  influence  the 
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 quality  of  television  pictures  viewed  by  home  audiences  through  the  reception  of  over-  the-  air  transmissions. 
 In  this  inquiry,  we  intend  to  re-  examine  each  of  these  factors  to  determine  if  the  current  values  for  the 
 analog  Grade  B  field  intensity  standard  are  valid  for  the  purposes  of  determining  whether  a  satellite  TV 
 subscriber  is  eligible  to  receive  transmissions  of  distant  network  signals  under  the  SHVA.  25  We  now 
 specifically  discuss  some  of  the  key  factors  about  which  commenters  may  wish  to  submit  further  technical 
 analysis. 

 12.  Receiver  Noise  Figure.  The  receiver  noise  figure  is  a  measure  of  the  amount  of  electronic 
 noise  produced  by  the  components  in  the  television  set.  An  appropriate  allowance  for  this  receiver  noise,  as 
 well  as  an  allowance  for  man-  made  noise,  must  be  included  in  the  signal  budget.  The  choice  of  an 
 adequate  signal  budget  that  accounts  for  the  overall  noise  level  that  must  be  overcome  is  necessary  in 
 designing  TV  sets.  In  the  1950s  low  cost  electronic  technology  for  television  frequencies  was  not 
 commonly  available  initially.  Television  tuner  technology  then  consisted  of  noisy,  low  cost  tubes  and 
 related  components.  Therefore,  the  figure  initially  used  for  the  receiver  noise  planning  factor  was  chosen  to 
 minimize  costs  for  TV  set  manufacturers,  so  as  to  ensure  that  television  sets  would  be  affordable  by  the 
 public.  Today,  however,  TV  tuner  technology  has  progressed  dramatically  from  those  early  days  in  TV 
 history,  and  tuners  contain  modern  solid  state  components  that  produce  lower  set  noise.  Thus,  in  MM 
 Docket  No.  87-  268,  dealing  with  the  planning  factors  for  DTV,  the  Commission  recognized  that  receivers 
 have  in  many  cases  improved  beyond  the  current  Commission  requirements  26  and  will  probably  get  even 
 better  in  the  future.  In  that  proceeding,  for  the  purpose  of  allotting  DTV  channels,  the  Commission  used 
 noise  figure  planning  factors  for  DTV  receivers  that,  for  the  UHF  band  of  operation,  are  some  7  dB  better 
 than  the  current  requirement  set  forth  in  Section  15.117  of  our  rules. 

 13.  We  ask  for  comment  on  whether  the  television  receiver  noise  figures  used  in  the  planning 
 factors  shown  in  Tables  1  and  2  are  still  valid  for  the  average  television  receiver  employed  in  the  home 
 today.  If  not,  what  values  should  be  used  and  are  these  new  values  substantiated  by  technical  data?  Have 
 advances  in  the  technology  of  television  receivers,  at  minimum,  kept  pace  with  todays  consumer 
 expectations  for  better  reception  of  television  service? 

 14.  Signal-  to-  Noise  Ratio  and  Service  Quality.  Signal-  to-  Noise  Ratio,  in  the  context  here,  is 
 the  ratio  of  the  amplitude  of  the  signal  after  detection  in  the  receiver  to  the  amplitude  of  the  noise 
 accompanying  the  signal.  In  an  analog  television  receiver  a  significant  level  of  noise  manifests  itself  in  the 
 viewed  picture  as  what  is  commonly  called  snow.  The  higher  the  signal-  to-  noise  ratio,  the  less  snow  is 
 visible.  We  note  that  comments  submitted  in  the  SHVA  Proceeding  urged  recognition  that,  for  many 
 people,  the  existing  Grade  B  signal  intensity  values  no  longer  equate  to  truly  acceptable  picture  quality.  In 
 other  words,  the  commenters  suggested  that  viewers'  expectations  as  to  what  level  of  signal  quality  is 
 acceptable  have  increased  over  time.  If  this  were  the  case  and  the  issue  were  an  inadequate  signal-  to-noise 
 ratio,  a  stronger  signal  or  a  receiver  with  a  lower  noise  figure  would  be  needed  to  produce  a  picture 
 that  would  now  be  regarded  as  acceptable.  Although  there  was  some  speculation  in  the  comments  filed  in 
 the  SHVA  Proceeding  that  viewer  expectations  have  indeed  changed,  no  current  study  documents  this 
 purported  change  or  replicates  the  methodology  of  the  initial  TASO  study  that  correlated  viewer  judgments 

 25  We  note  that,  in  the  proceeding  to  develop  an  appropriate  Individual  Location  Longley-  Rice  (ILLR)  predictive 
 model  for  field  strength  at  individual  locations,  pursuant  to  SHVIA,  we  are  considering  related  signal  propagation 
 factors.  See  Establishment  of  an  Improved  Model  for  Predicting  the  Broadcast  Televison  Field  Strength  Received 
 at  Individual  Locations,  ET  Docket  No.  00-  11,  Notice  of  Proposed  Rulemaking,  FCC  00-  17,  released  January  20, 
 2000,  at    6-  12. 

 26  See  Section  15.117  of  the  Commissions  Rules,  47  C.  F.  R.    15.117  (TV  receiver  requirements). 
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 of  television  picture  quality  with  specific  signal  levels.  27  Some  research  on  subjective  evaluations  of 
 television  pictures  may  show  that  viewers  have  raised  their  level  of  expected  performance,  but  the  results  of 
 any  subjective  testing  are  dependent  on  the  testing  methodology  and  conditions.  For  example,  several 
 recent  tests  were  conducted  by  cable  television  sponsors  using  as  subjects  viewers  who  may  have  expected 
 to  receive,  and  to  pay  for,  higher  quality  pictures.  28  Those  subjects,  however,  may  not  be  representative  of 
 audiences  relying  on  over-  the-  air  reception  for  their  television  viewing.  Nonetheless,  one  of  the  specific 
 purposes  of  this  inquiry  is  to  ascertain  whether  the  signal  intensity  standard  for  SHVA  purposes  needs  to  be 
 updated  to  reflect  consumers  current  expectations  of  what  is  acceptable  picture  quality.  29  Thus,  the  results 
 from  an  updated  study  of  viewer  expectations  based  on  scientifically  valid  methods,  such  as  ITU 
 Recommendation  500-  4,  30  could  be  valuable  in  this  regard. 

 15.  We  request  information  and  comments  on  whether  viewer  expectations  of  acceptable  television 
 picture  quality  have  changed  and,  if  so,  how  any  such  changes  should  be  accounted  for  in  revising  the 
 Grade  B  standard  for  SHVA  purposes.  Should  television  pictures  received  by  over-  the-  air  reception  be 
 comparable  to  those  received  from  satellite  when  developing  an  eligibility  standard  for  SHVA  purposes? 
 Have  there  been  any  current  studies  made  of  todays  home  television  viewer  expectations  of  picture  quality 
 using  scientifically  valid  subjective  methods?  If  so,  what  are  the  results  of  these  studies? 

 16.  Transmission  Line  Loss  and  Antenna  Gain.  The  original  analog  TV  planning  factors  were 
 developed  for  300-  ohm  impedance  systems  using  open  twin  lead  cabling.  On  the  plus  side  these  early 
 systems  had  less  attenuation  of  signal  due  to  the  connecting  cabling  and  impedance  transfer  at  both  the 
 antenna  and  receiver.  On  the  negative  side,  the  open  twin  line  cabling  was  prone  to  pick  up  electrical  noise 
 and  RF  interference.  Today,  most  antenna  systems  use  75-  ohm  coaxial  cabling.  Although  these  75-  ohm 
 systems  are  more  immune  to  electrical  noise  and  RF  interference  pickup,  their  signals  are  more  highly 
 attenuated  due  to  the  connecting  cabling.  An  NTIA  Report  (81-  68),  published  in  1981,  evaluated  a  study 
 of  home  TV  UHF  antenna  installations  located  at  50  distinct  sites  between  Chicago  and  Peoria,  Illinois. 
 The  report  concluded  that  the  median  antenna  system  gain  for  systems  using  a  75-  ohm  transmission  line 
 was  lower  than  that  for  systems  using  a  300-  ohm  transmission  line.  In  addition,  the  report  found  that,  for 
 the  more  modern  75-  ohm  transmission  line  installations,  the  median  estimated  antenna  system  gains,  as 
 classified  by  frequency  and  service  area  (Grade  A  or  Grade  B),  were  less  than  system  gains  that  were 
 applied  as  planning  factors  in  defining  required  field  strengths. 

 27  PrimeTime  24's  consulting  engineer,  William  Hassinger,  pointed  to  two  viewer  studies,  one  by  Neil  Smith  in 
 1971  and  another  conducted  in  Charlotte  in  1996.  See  CS  Docket  No.  98-  201,  PrimeTime  24  Comments, 
 Declaration  of  William  Hassinger,  Neil  Smith  Study,  and  ex  parte  presentation  of  January  14,  1999.  Neither 
 study  was  conducted  in  accordance  with  the  accepted  standard  for  viewer  studies,  ITU  Recommendation  500-  4, 
 "Method  for  the  Subjective  Assessment  of  the  Quality  of  Television  Pictures,"  infra  note  28.  Neil  Smith 
 acknowledged  that  his  sample  was  too  small  to  be  sufficient  for  any  generalizations.  See  id.,  Neil  Smith  Study  at 
 18-  19.  The  Charlotte  study  did  not  use  study  subjects  from  the  general  public  and  viewing  conditions  were  not 
 appropriate  for  a  scientific  study. 

 28  Recommendation  500-  4,  "Methods  for  Subjective  Assessment  of  Picture  Quality  of  Television  Pictures," 

 Recommendations  and  Reports  of  the  CCIR,  Vol.  XI,  Part  1,  Dubrovnik,  1986,  and  Subjective  Assessment  of 
 Cable  Impairments  on  television  Picture  Quality,  Bronwen  Lindsay  Jones,  1992  NCTA  Technical  Papers. 

 29  See  Letter  to  Chairman,  FCC  from  Senator  McCain  and  Representatives  Bliley,  Oxley,  and  Markey,  dated 

 December  8,  1999. 
 30  See  Recommendation  500-  4,  supra  note  28. 
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 17.  We  request  comment  regarding  the  appropriateness  of  the  receiving  antenna  system  gains  and 
 losses  set  forth  in  Tables  1  and  2  for  todays  analog  television  reception.  Because  reception  of  satellite 
 delivered  television  is  generally  based  on  the  installation  of  a  directional  outdoor  antenna,  we  ask  comment 
 on  whether  it  is  also  appropriate  to  expect  viewers  to  put  forward  a  comparable  effort  to  achieve  adequate 
 over-  the-  air  terrestrial  television  reception.  In  particular,  we  request  comment  regarding  the 
 appropriateness  of  assuming  an  outdoor,  directional  gain  antenna  model  for  over-  the-  air  reception  of 
 television  when  determining  eligibility  under  SHVA.  We  also  seek  comment  on  whether  there  have  been 
 more  current  studies  of  typical  home  television  receiving  installations  than  the  one  cited  in  the  paragraph 
 above.  If  so,  how  extensive  were  these  studies  and  what  are  the  results? 

 18.  Section  1005(  a)  of  SHVIA  amended  the  Copyright  Act  to  define  a  household  as  unserved 
 with  respect  to  a  particular  TV  network  if  that  household,  inter  alia,  cannot  receive,  through  the  use  of  a 
 conventional,  stationary,  outdoor  rooftop  receiving  antenna,  an  over-  the-  air  signal  of  a  primary  network 
 station  affiliated  with  that  network  of  Grade  B  intensity.  31  We  seek  comment  and  information  as  to  the 
 methodology  that  could  be  used  to  incorporate  a  stationary  antenna  model  into  the  modification  of  the 
 Grade  B  field  intensity  standard.  The  current  Grade  B  standard  assumes  that  the  antenna  is  pointing 
 toward  the  desired  station,  and  as  such,  the  maximum  gain  of  the  antenna  provides  a  signal  level  at  the 
 receiver  that  will  produce  an  acceptable  picture  quality.  For  the  purpose  of  determining  SHVA  eligibility, 
 how  should  the  antenna  gain  be  modified  for  those  network  stations  not  in  the  center  of  the  main  beam  of  a 
 stationary  directional  antenna?  Which  station  location  should  be  considered  the  pointing  direction  of  the 
 antenna  when  making  such  determinations?  32 

 19.  Dipole  Factor.  Another  planning  factor  is  the  mathematical  relationship  between  the  signal 
 strength  output  of  the  receiving  antenna  and  the  strength  of  the  electromagnetic  field  in  which  the  antenna  is 
 located.  This  relationship  is  known  as  the  dipole  factor.  The  current  Grade  B  planning  factors  are  based 
 on  dipole  factors  determined  at  the  geometric  mean  frequency  of  each  of  the  three  television  bands.  That  is, 
 for  the  entire  Low  VHF  band,  a  single  dipole  factor  was  computed  based  solely  on  the  mid  band  frequency 
 of  69  MHz.  Similarly,  the  High  VHF  band  dipole  factor  was  based  on  the  frequency  of  194  MHz;  and  the 
 UHF  band  dipole  factor  was  based  on  the  frequency  of  645  MHz.  In  MM  Docket  No.  87-  268,  which  dealt 
 with  planning  factors  for  DTV,  however,  the  Commission  used  the  precise  value  of  the  dipole  factor  for 
 each  UHF  DTV  channel.  Had  the  previous  methodology  been  used  for  DTV,  a  single  dipole  factor  would 
 have  been  computed  based  solely  on  the  allotment  for  the  DTV  mid-  band  channel  38  frequency  of  617 
 MHz  for  all  UHF  DTV  channels.  The  computation  of  distinct  DTV  dipole  factors,  however,  reveals  that 
 reception  on  DTV  channel  14  needs  2.  3  dB  less  field  strength,  and  DTV  channel  69  needs  2.  3  dB  more, 
 than  the  field  strength  value  for  the  DTV  mid-  band  channel.  33  For  the  purpose  of  achieving  consistent 
 service  replication  data  for  DTV,  this  same  methodology  was  used  to  modify  the  Grade  B  field  strength 
 values  (set  forth  in  47  C.  F.  R.    73.683)  applicable  to  existing  analog  UHF  stations.  34  Because  the  VHF 

 31  17  U.  S.  C.    119(  d)(  10)(  A)  as  amended  by  SHVIA    1005(  a)  (emphasis  added). 
 32  We  note  that  the  SHVIA  requires  a  determination  of  household  eligibility  for  each  network  station  considered 
 individually.  That  is,  a  household  could  be  served  with  respect  to  a  NBC  affiliate  if  the  household  could  receive 
 the  NBC  signal  from  any  NBC  affiliate  at  Grade  B  intensity  with  a  stationary  outdoor  antenna.  But  the  same 
 household  could  be  considered  unserved  with  respect  to  the  Fox  network  because  it  cannot  receive  any  Fox 
 affiliate's  signal  at  Grade  B  intensity  with  a  stationary  outdoor  antenna.  Each  network  station's  signal  intensity 
 must  be  independently  considered. 

 33  In  particular,  the  dipole  factor  modification  used  for  the  DTV  Table  of  Allotments  equaled  20  times  log10  of 

 the  ratio  of  the  center  frequency  of  the  UHF  channel  of  interest  to  the  center  frequency  of  channel  38. 
 34  Since  this  modification  to  the  planning  factors  does  not  produce  significant  differences  in  the  VHF  television 

 (continued.) 
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 television  band  covers  a  much  smaller  range  of  frequencies,  this  methodology  does  not  produce  significant 
 differences  in  the  dipole  factor  for  VHF  television  reception. 

 20.  We  seek  comment  on  whether  the  modifications  to  the  dipole  factor  applied  to  the  DTV 
 planning  factors  should  be  extended  to  also  apply  to  modification  of  the  analog  television  Grade  B  standard 
 for  the  purposes  of  SHVA.  We  also  ask  whether  these  theoretical  calculations  of  the  dipole  factor  and  the 
 resulting  system  gains  used  in  the  Grade  B  planning  factor  are  reflective  of  the  actual  energy  transference 
 of  todays  home  receiving  antennas. 

 21.  Field  Strength  Variability.  VHF  and  UHF  field  intensities  vary  not  only  with  time,  but  also 
 with  location.  By  virtue  of  the  relatively  short  wavelengths  involved,  it  is  common  for  field  strength  levels 
 to  vary  several  dB  over  relatively  short  distances  of  a  few  yards  for  VHF  frequencies  and  a  few  feet  for 
 UHF  frequencies.  This  variation  is  a  function  of  frequency  and  terrain.  The  location  variability  factor  is 
 expressed  in  dB  and  represents  the  difference  between  the  median  field  that  is  exceeded  at  50  percent  of  the 
 locations  and  the  field  exceeded  for  some  other  percent  of  the  locations.  One  way  to  account  for  these 
 variability  factors  is  to  build  them  directly  into  signal  strength  values.  The  Grade  B  intensity  levels  are 
 actually  median  signal  strengths  --  i.  e.,  50%  of  locations  in  a  particular  area  should  receive  a  Grade  B 
 signal  or  higher  at  least  50%  of  the  time.  However,  this  does  not  mean  that  50%  of  the  locations  will 
 receive  an  acceptable  picture  only  50%  of  the  time.  As  discussed  above  the  Grade  B  values  have  a  built-  in 
 time  factor  so  that  an  acceptable  picture  is  predicted  at  least  90%  of  the  time.  For  example,  a  signal 
 strength  of  41  dB/  P  v/  m  provides  an  acceptable  picture  for  channels  2-  6.  To  ensure  that  a  location  receives 
 such  a  signal  90%  of  the  time,  the  Grade  B  value  for  those  channels,  47dB/  P  v/  m,  includes  an  added  time 
 factor  of  6  dB.  35  Thus,  although  a  location  receiving  a  Grade  B  signal  of  47  dB/  P  v/  m  will  only  get  that 
 signal  50%  of  the  time,  that  same  location  will  receive  a  41  dB/  P  v/  m  signal  90%  of  the  time. 

 22.  We  seek  comment  on  the  appropriateness  of  the  field  strength  variability  factors  used  in  the 
 Grade  B  field  intensity  standard  when  determining  eligibility  under  SHVA.  Because  SHVA  eligibility  is 
 determined  by  use  of  the  ILLR  propagation  predictive  model  for  individual  locations,  we  ask  if  the  current 
 location  variability  factor  used  in  the  Grade  B  standard  is  appropriate.  36  We  also  seek  comment  on  the 
 appropriateness  of  the  field  strength  time  variability  factor  used  in  the  Grade  B  standard  when  determining 
 eligibility  under  SHVA.  In  other  words,  is  the  prediction  of  an  acceptable  picture  at  least  90%  of  the  time 
 an  inadequate  standard  for  the  average  television  viewer?  We  seek  information  regarding  the  results  of  any 
 technical  studies  and  analysis  of  those  studies  that  would  clearly  support  a  different  value  for  the  time 
 variability  factor  for  the  purposes  of  determining  SHVA  eligibility.  In  addition,  in  those  cases  where 
 comments  support  a  time  variability  factor  for  signal  levels  greater  than  the  90  th  percentile,  we  seek 
 information  regarding  the  availability  of  propagation  data  that  clearly  supports  the  proposed  value  of  time 
 variability. 

 23.  Environmental  Noise.  Environmental  noise  is  generated  by  noise  sources  external  to  the 
 receiver  that  are  generally  located  in  the  area  around  the  receiver  location.  Unlike  internal  noise  discussed, 
 above,  in  relation  to  the  receiver  noise  factor,  external  noise  is  generally  highly  non-  Gaussian  and  tends  to 

 (Continued  from  previous  page) 
 bands,  DTV  allotment  planning  used  this  modification  only  for  the  UHF  band. 

 35  See  discussion  at    5  n.  15  supra. 

 36  We  note  that  the  50%  of  locations  factor  was  intended  to  produce  a  contour  that  identifies  the  edge  of  a  TV 
 service  area.  For  SHVA  purposes,  however,  contours  are  irrelevant  and  what  instead  matters  is  TV  reception  at 
 each  household  considered  individually.  Thus,  in  the  SHVIA  ILLR  Proceeding,  ET  Docket  No.  00-  11,  supra  note 
 25,  the  Commission  is  considering  an  ILLR  model  for  determining  whether  each  individual  household  will,  with 
 50%  confidence,  receive  a  Grade  B  signal. 
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 be  impulsive  in  nature.  External  noise  can  be  divided  into  several  categories.  Usually,  external  noise  is 
 categorized  according  to  whether  it  is  of  atmospheric,  galactic,  or  man-  made  origin.  Since  atmospheric 
 noise  usually  predominates  at  frequencies  below  30  MHz,  it  generally  disturbs  only  the  television  reception 
 within  the  low  VHF  band,  but  even  that  disturbance  is  only  sporadic  in  nature.  The  major  source  of 
 atmospheric  noise  is  lightning.  For  instance,  low  VHF  band  disturbances,  particularly  on  channel  2,  can  be 
 noted  during  strong  local  thunderstorms.  Generally,  galactic  noise  levels  exceed  atmospheric  noise  levels  in 
 the  overall  low  VHF  band.  Nevertheless,  with  the  rapid  growth  of  man-  made  noise  sources  (e.  g.,  emissions 
 from  automobile  ignitions,  electric  motors,  electric  power  transmissions,  fluorescent  lights,  computers  and 
 other  electronic  equipment),  man-  made  noise  levels  generally  exceed  both  atmospheric  and  galactic  at  all 
 television  frequencies. 

 24.  We  seek  comment  on  whether  the  planning  factor  values  currently  used  to  account  for 
 environmental  noise  levels  values  (i.  e.,  planning  factor  11  in  Table  2)  are  appropriate  for  a  standard  to 
 determine  SHVA  eligibility.  For  example,  have  environmental  noise  levels  increased  (or  decreased)  and,  if 
 so,  how  should  this  affect  any  SHVA  eligibility  standard?  We  seek  information  regarding  the  results  of  any 
 technical  studies  that  might  indicate  that  there  is  need  for  a  Grade  B  environmental  noise  factor,  i.  e.,  a 
 counterpart  to  the  urban  noise  factor  value  used  in  determining  the  Grade  A  field  intensity  levels,  for  the 
 purposes  of  determining  SHVA  eligibility. 

 25.  Multipath  Interference.  Although  not  considered  in  the  original  service  planning  factors, 
 multipath  distortion,  or  ghosting,  has  been  a  pernicious  problem  since  the  beginning  of  television  broadcast 
 service.  Ghosting  is  the  reception  of  at  least  two  recognizable  images  of  the  desired  picture,  with  each 
 succeeding  image  displaced  horizontally  by  an  amount  corresponding  to  the  echo  delay.  An  echo  is  usually 
 caused  by  the  existence  of  another  transmission  path  that  parallels  the  main  path.  Ghosting  can  consist  of 
 multiple  echoes,  and  individual  echoes  may  be  leading  or  lagging  the  main  signal  image  received.  The 
 range  of  possible  echoes  is  large,  but  when  the  delay  is  close  to  zero,  the  echo  image  cannot  be  resolved, 
 and  the  effect  is  to  impair  the  picture  definition  (i.  e.,  blurring).  Echoes  with  delays  up  to  tens  of 
 microseconds  occur  in  television  broadcasting,  because  of  its  vulnerability  to  reflections  from  building  and 
 other  structures  away  from  the  direct  path  between  the  transmitter  and  receiver.  Included  in  this  problem 
 are  moving  ghosts  or  picture  flutter,  which  is  caused  by  reflections  from  passing  airplanes.  In  recent 
 years  much  concern  has  been  raised  regarding  television  signal  intensity  levels  and  their  affect  on  receiver 
 picture  quality.  This  has  been  true  even  though  multipath  impairments  are  generally  independent  of  field 
 strength  levels  at  the  receiver.  However,  until  recent  works  on  ghost  canceling  technology,  models  for 
 predicting  over-  the-  air  received  television  picture  quality  have  generally  ignored  the  impact  of  ghosting  on 
 television  reception.  While  many  improvements  to  the  television  broadcasting  system  have  been 
 implemented  over  the  years,  degraded  images  associated  with  multipath  ghosting  have  not  diminished,  and 
 ghosting  continues  to  reign  as  the  most  annoying  impairment  of  the  over-  the-  air  television  service.  The 
 viewer,  nonetheless,  can  take  certain  actions,  such  as  turning  or  moving  the  antenna,  to  minimize  ghosting. 

 26.  It  has  been  suggested  that,  in  analog  television,  a  desired-  to-  undesired  signal  ratio  of  at  least  32 
 dB  must  be  maintained  between  the  direct  and  reflected  television  signal  to  reduce  ghost  images  to  less 
 than  a  perceptible  impairment.  This  value  applies  where  the  time  separation  is  at  least  2  P  s,  but  may  be 
 less  for  smaller  time  separations.  37  Although  ghosting  is  one  of  the  most  serious  causes  of  poor  picture 
 quality  or  loss  of  service  in  television  reception,  no  significant  studies  of  television  picture  impairment  by 
 ghosting  have  been  made,  except  in  the  case  of  relatively  simple,  single  ghost  images.  38  However,  in  most 

 37  CCIR,  1990,  Annex  to  Volume  XI-  Part  1,  Report  478-  2. 
 38  See  Recommendation  654,  "Subjective  Quality  of  Television  Pictures  in  Relation  to  the  Main  Impairments  of 
 Analogue  Composite  Television  Signal,"  ITU,  CCIR  XI-  1,  Broadcasting  Service  (Television),  Dubrovnik,  1986; 
 (continued.) 
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 cases,  ghost  images  are  multiple  and  complex.  Simply  expressing  the  desired-  to-  undesired  signal  ratio,  as 
 is  done  in  most  interference  analyses,  is  insufficient  to  quantify  the  impact  of  ghosting  because  the  number 
 of  echoes,  their  phase  relationships,  and  resultant  delay  are  also  important  physical  characteristics  of 
 ghosting.  To  completely  analyze  the  impact  of  ghosting,  these  quantitative  measures  of  multiple  ghosts 
 must  be  correlated  with  a  subjective  evaluation  of  the  resultant  impairment.  To  make  things  even  more 
 difficult,  in  order  to  use  any  quantitative  value  of  ghosting  for  the  purpose  of  developing  a  signal  standard 
 for  SHVIA,  a  method  of  predicting  these  values  at  a  specific  location  must  be  available.  However,  we  are 
 not  aware  of  any  methodology  for  predicting  the  specifics  of  ghosting  at  a  given  location.  We  seek 
 comment  on  whether  the  eligibility  standards  should  account  for  ghosting  and,  if  so,  what  methods  and 
 values  should  be  used.  Are  there  scientifically  accepted  models  for  predicting  ghosting  that  should  be  used 
 in  determining  eligibility  standards? 

 27.  We  seek  comment  on  whether  the  effects  of  multipath  interference  should  be  included  in  the 
 eligibility  standards.  If  so,  how  should  they  be  accounted  for?  Should  the  eligibility  standards  presume 
 that  the  viewer  will  act  to  minimize  ghosting  and,  if  so,  what  viewer  actions  should  be  presumed,  and  how 
 should  the  standards  account  for  those  presumptions?  We  also  seek  information  regarding  the  results  of 
 any  technical  studies  of  television  picture  impairment  by  ghosting.  Such  studies  should  include  quantitative 
 measures  of  multiple  ghosts  correlated  with  a  subjective  evaluation  of  the  resultant  impairment. 

 28.  Replacement  of  the  Grade  B  Standard.  We  recognize  that  it  is  possible  that  adoption  of  an 
 alternative  standard,  rather  than  a  modification  of  the  current  Grade  B  field  intensity  standard,  may  be  the 
 more  appropriate  way  of  determining  satellite  TV  subscriber  eligibility  for  reception  of  distant  network 
 signals.  Therefore,  we  seek  comment  on  an  alternative  analog  TV  standard  for  purposes  of  determining 
 eligibility  pursuant  to  SHVA.  Commenters  who  recommend  alternative  ways  of  determining  satellite  TV 
 subscriber  eligibility  for  reception  of  distant  network  signals  should  explain  the  technical  justification  for 
 their  proposal  and  include  a  methodology  of  predicting  eligibility  and  verification  of  such  predictions.  All 
 comments  should  be  substantiated  with  a  technical  showing  and  should  explain  why  any  recommended 
 alternative  standard  is  superior  to  the  current  Grade  B  approach. 

 29.  Eligibility  Standard  for  Digital  Television  Signals.  Section  73.622(  e)  of  our  Rules  defines  the 
 Digital  Television  (DTV)  service  area  as  the  geographic  area  within  which  the  predicted  F(  50,  90)  field 
 strength  of  the  stations  signal,  expressed  in  dB/  P  v/  m,  exceeds  the  levels  shown  below  in  Table  3.  The 
 values  shown  are  the  levels  at  which  reception  of  DTV  service  is  limited  only  by  receiver  and  channel 
 noise.  Within  the  contours  established  by  these  values,  service  is  considered  available  at  locations  where 
 the  stations  signal  strength,  as  predicted  using  the  terrain  dependent  Longley-  Rice  point-  to-  point 
 propagation  model,  exceeds  these  values.  39  These  values,  in  turn,  are  based  on  the  DTV  planning  factors 
 shown  below  in  Table  4. 

 Table  3.  DTV  Service  Area  Contours 
 DB/  P  v/  m 
 (Continued  from  previous  page) 
 Report  478,  "Ghost  Images  in  Television,"  Questions  6/  11  Study  Programme  6A/  11,  ITU,  CCIR  XI-  1, 
 Broadcasting  Service  (Television),  Dubrovnik,  1986. 

 39  47  C.  F.  R.  73.622(  e)(  2). 
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 Channels  2-  6  28 
 Channels  7-  13  36 
 Channels  14-  69  41 

 Table  4.  DTV  Planning  Factors 
 Factors  Units  Channels 
 2-  6 
 Channels 
 7-  13 
 Channels 
 14-  69 
 1.  Thermal  Noise  @  75  ohms  dB/  1Pv  1.75  1.75  1.75 
 2.  Receiver  Noise  Figure  DB  10  10  7 
 3.  Signal  to  Random  Noise  Ratio  DB  16  16  16 
 4.  Transmission  line  loss  DB  1  2  4 
 5.  Receiving  Ant.  Gain  DB  4  6  10 
 6.  Dipole  Factor  DB  3  12  22 
 7.  Local  Field  dB/  1Pv/  m  28  36  41 
 8.  Terrain  Factor  (50%)  DB  0  0  0 
 9.  Time  Fading  Factor  (90%)  DB  0  0  0 
 10.  Median  Field  F(  50,50)  dB/  1Pv/  m  28  36  41 
 11.  To  overcome  Urban  Noise  DB  0  0  0 
 12.  Required  Field  dB/  1Pv/  m  28  36  41 

 It  should  be  noted  that  the  time  fading  factors  for  DTV  are  not  included  in  the  determination  of  the  DTV  minimum  field  intensities.  Therefore,  time  fading  factors  must  be  added  to  the  minimum  required  field 
 intensities  to  obtain  values  for  median  field  intensities  when  making  field  strength  measurements.  The  accountability  for  time  fading  should  also  be  included  in  the  field  strength  prediction  methodology. 

 30.  It  should  also  be  noted  that  the  planning  factors  in  Table  4  for  digital  television  are  the  same 
 physical  factors  which  to  date  have  been  generally  considered  to  influence  the  quality  of  reception  of  over-the- 
 air  transmissions  of  analog  television  pictures  by  home  audiences,  e.  g.,  thermal  and  receiver  noise, 
 signal-  to-  noise  ratio,  transmission  line  loss,  antenna  gain/  dipole  factor,  and  propagation  variability  factors. 
 Therefore,  we  seek  comment  in  this  inquiry  regarding  whether  the  DTV  noise-  limited  service  contour 
 values  shown  in  Table  3  above  are  valid  for  the  purposes  of  determining  whether  a  DTV  viewer  is  eligible 
 to  receive  satellite  transmissions  of  distant  network  signals  under  the  SHVA.  If  not,  what  specific 
 modifications  to  this  standard  should  be  considered?  Comments  should  be  supported  with  a  sound 
 technical  justification.  Additionally,  we  seek  comment  on  an  alternative  DTV  standard  for  purposes  of 
 determining  eligibility  pursuant  to  SHVA. 

 PROCEDURAL  MATTERS 
 31.  Ex  Parte  Status  of  Proceeding.  Subject  to  the  provisions  of  47  C.  F.  R.    1.1203  concerning 
 Sunshine  Period  prohibitions,  this  proceeding  is  exempt  from  ex  parte  restraints  and  disclosure 
 requirements,  pursuant  to  47  C.  F.  R.    1.1204(  b)(  1). 

 32.  Filing  of  Comments  and  Reply  Comments.  Pursuant  to  Sections  1.415,  1.419,  and  1.430  of 
 the  Commissions  rules,  47  C.  F.  R.    1.415,  1.419,  1.430,  interested  parties  may  file  comments  on  or 
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 Federal  Communications  Commission  FCC  00-  184 
 14 
 before  June  27,  2000,  and  reply  comments  on  or  before  July  12,  2000.  Comments  may  be  filed  using  the 
 Commissions  Electronic  Comment  Filing  System  (ECFS)  or  by  filing  paper  copies.  See  Electronic  Filing 
 of  Documents  in  Rulemaking  Proceedings,  63  Fed.  Reg.  24,121  (1998). 

 33.  Comments  filed  through  the  ECFS  can  be  sent  as  an  electronic  file  via  the  Internet  to 
 http://  www.  fcc.  gov/  e-  file/  ecfs.  html.  Generally,  only  one  copy  of  an  electronic  submission  must  be  filed.  In 
 completing  the  transmittal  screen,  commenters  should  include  their  full  name,  Postal  Service  mailing 
 address,  and  the  applicable  docket  number.  Parties  may  also  submit  an  electronic  comment  by  Internet  e-mail. 
 To  get  filing  instructions  for  e-  mail  comments,  commenters  should  send  an  e-  mail  to  ecfs@  fcc.  gov, 
 and  should  include  the  following  words  in  the  body  of  the  message,  get  form  <your  e-  mail  address>.  A 
 sample  form  and  directions  will  be  sent  in  reply. 

 34.  Parties  who  choose  to  file  by  paper  must  file  an  original  and  four  copies  of  each  filing.  All 
 filings  must  be  sent  to  the  Commissions  Secretary,  Magalie  Roman  Salas,  Office  of  the  Secretary,  Federal 
 Communications  Commission,  445  12  th  Street,  S.  W.,  Room  TW-  A325,  Washington,  D.  C.  20554. 

 35.  Parties  who  choose  to  file  by  paper  should  also  submit  their  comments  on  diskette.  These 
 diskettes  should  be  submitted  to:  Charles  J.  Iseman,  Deputy  Chief,  Electromagnetic  Compatibility 
 Division,  Office  of  Engineering  and  Technology,  Federal  Communications  Commission,  The  Portals,  445 
 Twelfth  Street,  S.  W.,  Room  7-  A363,  Washington,  D.  C.  20554.  Such  a  submission  should  be  on  a  3.5-  inch 
 diskette  formatted  in  an  IBM-  compatible  format  using  Word  for  Windows  or  compatible  software.  The 
 diskette  should  be  accompanied  by  a  cover  letter  and  should  be  submitted  in  read  only  mode.  The 
 diskette  should  be  clearly  labeled  with  the  commenters  name,  proceeding  (including  the  docket  number,  in 
 this  case  ET  Docket  No.  00-  90,  type  of  pleading  (comment  or  reply  comment),  date  of  submission,  and  the 
 name  of  the  electronic  file  on  the  diskette.  The  label  should  also  include  the  following  phrase,  Disk  Copy 
   Not  an  Original.  Each  diskette  should  contain  only  one  partys  pleadings,  preferably  in  a  single 
 electronic  file.  In  addition,  commenters  must  send  diskette  copies  to  the  Commissions  copy  contractor, 
 International  Transcription  Service,  Inc.,  1231  20  th  street,  N.  W.,  Washington,  D.  C.  20036. 

 36.  Comments  and  reply  comments  will  be  available  for  public  inspection  during  regular  business 
 hours  in  the  Reference  Information  Center  (Room  CY-  A257)  of  the  Federal  Communications  Commission, 
 The  Portals,  445  Twelfth  Street,  S.  W.,  Washington,  D.  C.  20554.  Copies  of  comments  and  reply 
 comments  will  also  be  available  through  the  Commissions  duplicating  contractor,  International 
 Transcription  Service,  Inc.  (ITS,  Inc.),  1231  20  th  Street,  N.  W.,  Washington,  D.  C.  20036,  (202)  857-  3800, 
 TTY  (202)  293-  8810. 

 37.  Alternative  formats  (computer  diskette,  large  print,  audiocassette  and  Braille)  are  available  to 
 persons  with  disabilities  by  contacting  the  Consumer  Information  Bureau,  Consumer  Education  Office,  at 
 (202)  418-  2514,  TTY  (202)  418-  2555,  or  at  fccinfo@  fcc.  gov.  The  Notice  can  also  be  downloaded  at 
 www.  fcc.  gov/  dtf/. 

 38.  Additional  Information.  For  additional  information  regarding  this  proceeding,  contact  Charles 
 J.  Iseman,  Deputy  Chief,  Electromagnetic  Compatibility  Division,  Office  of  Engineering  and  Technology, 
 at  202-  418-  2444  or  ciseman@  fcc.  gov. 

 ORDERING  CLAUSE 
 39.  IT  IS  ORDERED  that,  pursuant  to  section  339(  c)(  1)  of  the  Communications  Act  of  1934,  as 
 amended  by  the  Satellite  Home  Viewer  Improvement  Act  of  1999,  this  Notice  of  Inquiry  IS  ADOPTED. 
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 Federal  Communications  Commission  FCC  00-  184 
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 FEDERAL  COMMUNICATIONS  COMMISSION 
 Magalie  Roman  Salas  Secretary 
15