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NTIA Set-Top Box Feedback Submitted

Washington — A number of electronics manufacturers and interested industry associations filed comments with the U.S. Commerce Department this week addressing the National Telecommunication and Information Administration’s (NTIA) notice of proposed rule making on the digital television transition, including the NTIA’s converter box coupon program.

In an unusual joint filing, the Consumer Electronics Association (CEA), the National Association of Broadcasters (NAB) and the Association for Maximum Service Television (MSTV) urged the NTIA to expand its proposed eligibility requirements to include all Americans with analog televisions that depend on over-the-air broadcasts.

In a similar separate filing, LG Electronics said the set-top converter program should include coupons for up to two DTV set-top boxes per household “with an analog-only set reliant on over-the-air television service.”

In approving the federal budget, Congress authorized spending up to $1 billion to help cover the digital to analog TV converter box coupons. The expense is expected to be paid out of the proceeds collected through the auction of reclaimed analog TV broadcast spectrum to commercial wireless service providers.

LG’s filing urged that cable and satellite TV homes should not automatically be exempted from the program, as many such homes have television sets in secondary rooms that are not connected to multichannel TV services and still receive broadcasts using traditional antennas.

“NTIA’s proposed eligibility requirements … are contrary to the DTV Act’s twin goals of minimizing disruption to the public and maximizing the number of analog-only sets that will continue to receive television service when analog broadcasting ends,” LG’s statement read.

LG, CEA, NAB and MSTV all urged the NTIA to expand the capability of its proposed bare bones converter box requirements to permit manufacturers to include a limited range of “no-frills” functions in eligible devices so that they will be easy to use and perform well.

The CEA/NAB/MSTV joint filing recommended expanding features to include electronic program guide navigation and “smart antenna” interfaces. The joint associations also recommended the following core requirements of a converter box program:

* The NTIA’s administration of the digital to analog (DTA) converter coupon program must effectively ensure continuity of service to existing analog television sets.

* Consumers’ out-of-pocket expenses for DTA converters must be minimized and the converter boxes must be intuitive and work properly in the myriad of challenging installation configurations in which they will be placed.

* The NTIA’s administration of the program must strive for simplicity. For consumers and others involved, the program must also be easy to understand and follow.

* The program should be structured to facilitate equitable distribution of coupons to all Americans with analog televisions that depend on over-the-air broadcasts, while preventing abuses and waste.

* The government, broadcasters, manufacturers and retailers must provide consumers with the tools and information necessary to make effective use of the converter box program.

LG suggested that minimum performance requirements be adopted for eligible boxes to ensure reliable reception and ease of consumer use.

LG also called for the adoption of minimum energy efficiency standards for eligible boxes; and for education programs to notify consumers about applying for coupons and using converter boxes.

LG said a multiplatform consumer education effort should be focused on those groups most likely to need a converter box, including emphasis on lower-income and older Americans.

For its part, LG Electronics said it is “intensifying its sales training efforts with retailers and collaborating with broadcasters to promote DTV technology.”

LG said it favors adoption of minimum performance requirements for eligible boxes to ensure reliable reception and ease of consumer use.

Meanwhile, CE components manufacturer Microtune submitted comments saying the guidelines should ensure that converter boxes meet the A/74 performance guidelines and receiver standard adopted by the ATSC.

Microtune said the A/74 guideline is a “significant step in ensuring that set-top boxes deliver high quality signals to those that rely on them,” and added that the A/74 standard be extended to tuners in all U.S. DTV products.

The company also recommended requiring product labeling to help consumers quickly identify products that meet the standard.