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Consumers Union
is extremely grateful to Chairman Tauzin and members of the Committee for
their leadership on digital television issues.
As the Chairman’s Draft suggests, we also agree that the transition
to digital has been a failure. From
a consumer’s perspective, the current incentives to make the jump to digital
television are small. Digital
televisions are extremely expensive, and only a small portion of all broadcast
programming is available digitally.
Consumers will not thank Congress for digital
television if it also means they have Congress to thank for higher prices and
inconvenience when they buy new TVs and new computers, or integrate their home
entertainment systems. Neither
will they thank Congress for rolling out digital content if they cannot do the
kinds of routine personal copying under the “broadcast flag” scheme that
they have grown to expect in the analog television era.
We certainly agree with the Chairman and the
committee that it is unacceptable to have two incredibly valuable blocks of
spectrum—for which the broadcast industry paid nothing—remain
underutilized. It is high time to
make more spectrum available to promote competition to cable television, local
telephone monopolies, and to promote new services.
Digital television is a positive technology that can
benefit consumers and it should be rolled out in accordance with competitive
market principles. Freeing up the
analog spectrum would allow that spectrum to be auctioned for innovative uses
that would serve consumers, and some of the revenue from auctions could also
be used to meet local programming needs.
Where Consumers Union respectfully disagrees with the staff discussion
Draft is over the manner in which we should accomplish such a transition.
The Draft legislation mandates the transition to
digital by 2007, and ends all analog transmissions at that time.
Such a requirement would place the digital changeover squarely on the
backs of consumers. Consumers
would have to own digital televisions by then or they would be forced to buy
new ones, or they would have to purchase converter boxes for existing analog
TVs. Otherwise they would be out
of luck. Old TV sets—regardless
of how many features they have or how much they cost—would simply not
receive TV signals.
Requiring consumers to purchase additional TV sets or
additional digital tuner hardware may have the benefit of allowing economies
of scale to bring down the price of these electronics in the long run, but it
is undeniable that this mandate will impose significant new costs on consumers
in the short run.
It has been argued by some that the transition will
not be overly costly for consumers to convert to digital because the
transition could be made by purchasing an inexpensive converter box.
But the plain language of the Draft provides the “termination of the
manufacture of equipment that has analog outputs by July 1, 2005.”
This seems to eliminate the very possibility of a converter box because
by definition such a converter would have to have an analog output.
In addition, this termination of analog outputs seems to have the
effect not only of forcing consumers to buy new television sets, but also
could force them to buy new home entertainment systems.
The Draft would ignore existing legal requirements
that 85 percent of the country own digital televisions BEFORE analog
transmissions are ended. Why does
it makes sense to turn this concept on its head and require consumer to buy
fancy equipment designed for High Definition television if High Definition
isn’t worth it to them? How
much will consumers be forced to spend to make this transition possible?
Is it fair to place the burden of this transition on consumers when it
is broadcasters who received an enormous public benefit when Congress gave
them this spectrum, and broadcasters will reap financial benefits should the
transition finally occur? Why not
have the broadcasters and others who will benefit from the shift to digital
share the expense of the digital conversion?
The Draft also attempts to deal with the serious
problem of Internet piracy, which some argue has slowed the transition to
digital television. The Draft
language gives broadcasters content protection in both their signal and the
hardware that receives that signal in order to prevent piracy. Unfortunately, such a “broadcast flag” may prevent quite
a few of today’s practical uses, such as taping programming and watching it
on another device, in another place, or at another time.
Consumers Union cannot support any legislation
involving a broadcast flag that dictates equipment manufacturing
specifications and software compliance standards unless it can be demonstrated
that before Congress imposes such standards:
1.
Consumers will be able to use current television and recording
equipment, without excessive complication or cost, to continue to make
personal copies and record broadcast programming as the equipment was designed
to;
2.
Congress can demonstrate that the price of television sets will not
increase appreciably as a result of such mandates;
3.
The open architecture of innovation for consumer electronics and
computers will not be harmed; and
4.
The imposition of a broadcast flag will not be overbroad, sweeping into
its reach, for example, general purpose personal computers, and other devices
that should remain open and unburdened by such copyright controls.
The Draft would have Congress regulate the
manufacturing process of consumer electronics, micromanaging this industry to
meet the supposed goals of getting broadcasters to use digital spectrum and
return analog for other uses. The
professed aim is to protect copyright, but we fear that the Draft may go too
far in restricting day to day enjoyment of broadcast programming that involves
neither copyright infringement nor piracy of any sort.
As the Committee contemplates burdening consumers
with additional costs and complexity in their uses of electronic products,
policymakers should ask themselves what the consumer benefit is to this course
of action. Again, it was the
government, driven by an industry seeking free spectrum, that promoted the
digital transition. At no point
was there a consumer outcry for High-Definition or digital television.
Until recently, public policy for telecommunications
involved handing out public benefits or assets, such as the airwaves or local
cable and telephone monopoly franchises, in return for commitments to meet
public needs. Broadcasters were
to meet local civic and educational needs, and telephone companies were to
ensure universally affordable telephone service.
This straightforward quid pro quo left companies that were dependent on
public assets obligated to meet public needs that market forces failed to
satisfy.
Now, in the era of deregulation, public benefits or
assets have increasingly been handed out in return for nothing more than
corporate promises – promises to deliver High Definition television,
promises of cross-industry competition, and promises to expand availability of
open platforms providing broadband services.
Unfortunately, this new approach has resulted in many broken promises,
inadequate industry accountability, anti-competitive behavior and consumer and
investor abuse. Clearly, we need
to restore accountability by reinforcing the principle that the distribution
of public assets or subsidies requires significant public benefit in return.
Unfortunately, this Draft goes in the opposite
direction. Congress let the
broadcast industry dig a deep public policy and marketplace ditch by giving
away an enormous amount of valuable spectrum for free, while imposing no
meaningful penalties for failing to deliver digital television to the public.
Let’s not dig a deeper ditch.
The Draft—while attempting to deliver on the promise of digital
TV—places the burden not on broadcasters who received this valuable subsidy,
but instead on consumers.
Please consider several possible scenarios if this
draft becomes law.
First, suppose a few years from now your daughter’s
game-winning soccer goal was broadcast on a local television station (which is
neither news nor “public information programming,” both of which would be
exempt from flag protection in the staff Draft). If you record it on a television in your living room, will
you be able to view it on the upstairs television?
Can you show it to your colleagues in your office?
Second, if you recorded a copy of your mother’s
favorite show on your home VCR (or one of the devices that will eventually
replace VCRs), would you be able to take that copy and watch it with her at
her house? Is there technology
that would allow you to do this that is not invasive of privacy?
Third, let us suppose that you are adept with
computers; you buy an off-the-shelf computer and download the GNU project’s
open source digital television demodulator.
This makes your computer a “digital device capable of demodulating an
incoming modulated digital terrestrial broadcast signal.”
According to the Draft, it would require your computer to recognize the
flag. Does the Committee really
intend for that device to contain copyright policing hardware and software?
Could the GNU project’s tuner and other open source initiatives
possibly meet the technical standards for the broadcast flag?
At several points in the Draft, staff were careful to
try and ensure that the implementation of the flag does not result in
diminished functionality of consumers’ electronic equipment; we are
extremely appreciative of the staff’s effort to protect consumers in this
manner. However, the mere
implementation of the broadcast flag makes this an unsolvable—or at least
unsolved—paradox.
If the flag exists to protect digital television content, how can it
allow for customary and legitimate consumer uses, such as the time-shifting
and space-shifting described above, while denying pirates the ability to
distribute their content over the Internet, without invasions of users’
privacy?
In summary, Consumers Union wishes to work with the
committee in stimulating a rapid transition to digital television broadcast,
but we believe that the onus of the digital transition properly rests on the
broadcast industry, not on consumers. Instead
of simply shutting off analog broadcast by a date certain, policymakers should
consider charging broadcasters who fail to relinquish their analog spectrum by
2007 an annual spectrum fee in order to promote their transition to digital.
And perhaps the cost of the digital tuner mandate should be borne by
the broadcasters, through revenues received by charging broadcasters an annual
spectrum fee for their use of digital spectrum.
Furthermore, in our opinion, industry has not yet
made a compelling case that the sweeping broadcast flag mandate would expedite
digital television rollout. We
fear that the flag will not hit where it aims, stopping potential
redistribution of digital television content on the Internet, nor is it clear
that such technology can be deployed without disrupting consumers’ and other
public entities (especially libraries) ability to use digital content in a
flexible manner. We believe that
further analysis of the consumer impacts of such legislative mandates should
be completed before Congress puts consumers at risk of paying higher prices
and faces greater inconveniences in using electronic equipment.
We have attached more detailed questions and comments
regarding the broadcast flag (submitted to Committee earlier this year in
conjunction with Public Knowledge and the Center for Democracy and Technology)
as Appendix A. We hope to
continue working with the Committee to craft legislation that will resolve
these important issues for both consumers and affected industries.
Appendix
A
Date:
July 10, 2002
To:
House Commerce Committee Staff
From:
Center for Democracy and Technology, Consumers Union, and Public
Knowledge
Re:
Consumer Policy Questions and Issues Regarding the BPDG Proposal for
Protecting DTV Content
We have been asked by
Committee staff to provide a preliminary analysis from a consumer perspective of
the Broadcast Protection Discussion Group’s (BPDG) Final Report on the
protection of digital television. We also have been asked to suggest questions
that the Committee should consider with regard to the broadcast-flag standard
and related legislation and/or regulation.
Introduction
We support the goal
of promoting DTV
and recognize that the resolution of certain
copyright issues could be important to achieving that goal.
Further, we are committed to the protection of copyright, and we support
creators’ and publishers’ prerogative to protect their copyright interests
through technical means. Consumers have valid interests in this issue as well
— in rewarding artists to ensure the availability of a rich variety of
content, and also in the cost and convenience of new DTV technology and its
impact on other media, like the Internet.
From a consumer
perspective, key issues posed by the broadcast-flag proposal include —
- How
will the proposed solution affect consumers?
Will they have to buy substantial new equipment? Will they be able to
exercise the fair use rights they have reasonably come to expect?
- Are
there downstream impacts on other computing technologies?
For example, will the BPDG’s restrictions have a negative impact on
innovation and the growth of the Internet? Will it set a precedent for
broader government standard setting?
- Will
it be effective? Will the
proposal sufficiently diminish the copyright infringement at issue, or will
additional steps be needed? Can it be implemented fast enough to promote
greater DTV adoption?
- What
are the costs for
consumers? How much will implementing the BPDG proposal add to the
economic and convenience costs of DTV and of other consumer technologies?
- Do
the likely benefits of the proposal outweigh the likely costs?
In general, we believe that serious questions remain as to
whether the broadcast flag proposal will
be sufficiently effective. Congress
should seek assurance that it will not have adverse consequences on consumers,
including their ability to use their existing products, their ability to
exercise legal and reasonably expected fair uses of content, and their access to
future innovative technologies that might allow them to manipulate content in
creative ways that are legal under copyright law.
Broader dialog is in
order. The Committee should seek more information and use its standing to
promote a fuller exploration of the consumer implications of implementing a
broadcast flag, and to ensure protections for consumers in any legislative or
regulatory endorsement of a solution like the broadcast flag. We believe that
all sides in the debate would benefit from developing much clearer answers to
these questions. We are eager to work with you, your staff, and the affected
stakeholders to ensure greater involvement of the consumer perspective in these
important deliberations.
I. Consumer Impact Analysis
The BPDG Final
Report represents the deliberations of a group that was expressly limited in its
mission, which was to "evaluat[e] technical
solutions for preventing unauthorized redistribution"[6]
of digital TV content (emphasis added). By
intention, the Report did not seek to present a comprehensive means of
controlling copying and transmittal of DTV content.
By and large, we think that is a good thing — Congress should be highly
skeptical about comprehensive solutions, and prefer incremental approaches
undertaken by the private sector.
Over time, however,
as other technical and policy issues are dealt with, a broader consideration of
consumer concerns will be needed, and this process must include consumer
organizations as well as industry. Such a broader assessment of consumer impact would:
-
Address
the question of impact on legitimate
consumer uses and compatibility
of the proposal with home entertainment and computer equipement that
consumers have already bought and will want to buy.
-
Consider
the impact on innovation and on
computing technologies, and particularly whether a precedent is being
set for government involvement in setting standards.
-
Estimate
the cost to consumers and other
users of the new devices that may incorporate this standard.
-
Fairly
appraise the effectiveness of
such a standard.
-
Identify
alternatives that may serve
copyright and consumer interests.
As we recommend
below, the Committee is now in a position to encourage broader dialog with
consumer groups and other stakeholders about these impacts.
II. Compatibility, Consumer
Inconvenience and Fair Use
The Report does not
fully address the potential inconvenience and disappointment that implementation
could visit upon consumers. In fairness, it would have been difficult for the
Report as conceived to discuss fair use in detail. A copyright protection system
should not deprive consumers of the ordinary, commonly accepted uses of their
current products. People should not be expected to be required to go out and buy
new products in order to conduct the legal activities they are currently able to
conduct. And such a system should
not limit innovation, especially innovation in rapidly evolving technologies
such as the Internet.
-
For
example, if the proposal were implemented, could the Chairman record a show
over the weekend at home and ask a staffer to watch it on Monday at work?
Could the Chairman’s staff record a DTV news show on which the Chairman
appeared and send it electronically to the Chairman’s district office, so
he could watch it there? Could the staffer burn a news program onto a CD and
give it to the Chairman to watch on his laptop computer in an airport?
-
Today,
a consumer can record a DTV show with her DTV-equipped computer on a
recordable DVD, then watch it at night in her bedroom on a popular DVD
player purchased years ago. She
could also bring it to the home of a friend or family member and watch the
show there. Will these instances of “fair use” be curtailed under the
BPDG proposal?
-
Is
legacy equipment protected? That
is, will consumers be able to get full use of their old TVs and VCRs? Will
enforcement of the Requirements Document limit consumers’ use of equipment
they already own?
-
To
what extent will compliance with the Report conflict with reasonable
consumer expectations about fair use, such as the ability to time-shift,
play a recording on multiple devices, play a recording on device either
inside the home or outside the home, etc?
-
In
terms of future equipment, although a variety of different Authorized
Technologies for output and recording would be permitted under the
Requirements Document, it is not clear how they would interoperate.
Issues that need clarification include:
-
How
will devices with different Authorized Technologies interoperate, e.g., a DTCP-equipped DTV set-top receiver and an OCPS recorder? (See
proposed Authorized Technologies.)[7]
-
Will
there be converters between different Authorized Technologies and, if so,
what will they cost?
Congress ought to
have a clear understanding of whether existing devices owned by consumers will
work under the proposal, whether reasonable expected fair uses will be allowed,
and whether technologies will interoperate. Overall, how much work needs to be
done to understand how consumers will be educated as to these new requirements
when, throughout the history of commercial television, interoperability and
integration of television systems has been relatively seamless?[8]
III. Impacts on Other Technologies
In order to fully
protect DTV content across a range of future platforms, the BPDG plan
necessarily impacts a broad variety of devices that might someday receive and
distribute DTV broadcasts. Importantly, these include general-purpose computers
and the Internet.
- What
impact will implementation of the Report have on general-purpose computers?
Will compliance require substantial changes to computing architecture, or
diminish future innovation in technologies not contemplated in the BPDG
model?
- What
impact would compliance have on open source systems?
- Will
the report set a precedent for government mandates of security standards
with broad applicability, and with ramifications for future Internet
development? The Internet’s growth and development took place with
relatively few government constraints —
especially technical constraints. The result of that policy choice
has been unexpected growth in applications of the Internet, including the
World Wide Web, and rapid adoption of Internet technologies and applications
by the public.
The Committee ought
to have a clear understanding of whether substantial changes are contemplated in
computing architecture, and whether the BPDG proposal would be viewed as setting
a precedent for government involvement in setting computing standards.
IV. Effectiveness
Any Congressional
action on the BPDG report would appear to have two primary goals: protection of
DTV content from certain illegal copying and redistribution, and accelerating
the rollout of DTV by providing such protections.
To what extent will
the BPDG proposal diminish the copyright infringement in question?
Implementation will no doubt deter many users of compliant equipment from
massive redistribution of DTV content. But questions remain about the extent to
which illegal copying will be curtailed.
Analog
Hole: Section 2.5 of the Report
states that it does not address the so-called “analog hole” — the copying
of DTV content after it is sent to an analog component. If the BPDG proposal is
adopted, illegal copying could continue through the analog hole.
-
In terms of quality, is
there really a significant difference in quality between DTV content captured
from digital receivers and DTV content captured from analog receivers and
redigitized? (Generally speaking,
the quality degradation of single digital-to-analog-to-digital conversion is
unlikely to be to significant, and the degradation in quality of content
currently traded on the Internet typically occurs not in the copying, but in the
compression necessary for most Internet transmissions, whether captured from
analog or from digital sources.)
-
The Report and the
Requirements Document also do not mention peer-to-peer networking, one of the
key problems listed in the studios' April and June reports to Congress.[9]
-
What precedent does the
broadcast flag set for the peer-to-peer problem?
Will the content providers be pushing to close all the holes and address
all these issues before releasing DTV content?
-
Legacy products will
also diminish the effectiveness of the proposal:
-
DTV receivers sold today do
not have restricted outputs, and will not unless some protection system is
implemented in coming years. Millions of unprotected legacy receivers — all
allowing digital redistribution — will be in the public's hands before this
system can be implemented.
-
Within a few years it will
be possible to do software-based demodulation of the DTV signal on a PC,
potentially allowing millions to access DTV signals on computers without the
broadcast flag requirements.
Together, these
factors would appear to leave substantial possibilities for copying of protected
DTV content, including allowing bad actors to obtain content and then
redistribute it globally or over P2P networks. Congress should have a clear
understanding of whether efforts to address these issues will be sought —
either by negating the use of legacy products already owned by consumers, or by
somehow retroactively addressing issues of the “analog” hole.
Security:
A related question is the
security of the proposal. A
proposal is less desirable if it can be easily defeated, especially if it can be
defeated in ways that allow large scale violations while the average consumer is
still inconvenienced.
Even on systems for
which the Report is implemented, computer security experts commonly believe that
most copy protection systems can and will be broken, and that 'marking'-based
systems such as the broadcast flag are comparatively weak, in general. Footnote
3 in the Report states that “a
more effectual technical and enforcement solution would be to encrypt DTV
content at the source (i.e., the transmitter).” We are not suggesting that
encryption would be more desirable, but
footnote 3 reminds us that a system that fails to protect content adequately at
the source is fundamentally vulnerable. Moreover,
current DTV receivers do not have protected outputs today and will not in the
future — unless some additional protection system is retrofitted for those
legacy devices some years from now. By
then, it is possible that millions of unprotected DTV receivers will be in the
public's hands.[10]
Accordingly, the Committee should consider the following:
-
How will this system prevent
unauthorized redistribution of content when: potentially millions of unprotected
DTV receivers will be in the public's hands before this system can be
implemented[11]
and, within a few years it will be possible to do software-based demodulation of
the unprotected DTV signal in PCs?[12]
-
How else can the flag be
defeated or evaded?
Impact
on DTV Rollout:
The Committee should explore in greater depth the premise behind the
broadcast flag proposal - that DTV adoption will increase as high-value
programming is put on DTV, and that this will happen once content is protected
from unauthorized redistribution through systems such as that proposed by the
BPDG.[13]
The Committee should pursue the following question related to this premise:
-
Can it be shown that the
BPDG scheme will deter enough illegal copying to expedite the deployment of DTV,
given that a significant amount of illegal copying will occur even if the
proposal is implemented?
-
Allowing for an FCC
administrative process required by law and sufficient time for implementation,
it seems unlikely that the first "compliant" and secure devices would
be distributed before mid-2006.[14]
Will adoption of the Report result in additional DTV content being released in
time to aid in a transition by 2006?
The key question
seems to be this:
The answers to
these questions could help the Committee evaluate the extent to which the BPDG
proposal would be effective in moving this nation to transition from analog
over-the-air television to digital television.
The consumer benefits from this transition (not just in better pictures,
but also from the release of spectrum for important public-safety,
technological, and economic benefits) could be significant.
If, however, the BPDG proposal will not result in a significantly
accelerated DTV transition, this casts the proposal in a different light.
IV. What Is the Monetary Cost to
Consumers?
The Committee
should evaluate the impact of the BPDG proposal in terms of the additional
expense it may entail for the 107 million American TV households, both in terms
of the cost of DTV products and in terms of the costs of other digital products. Those costs may be felt by consumers both directly (in terms
of the need to buy new products) and indirectly (in terms of various ways
increased product-development costs may be passed along to consumers).
These costs may well delay rather than expedite the transition to DTV.
For these reasons, the Committee should ask the commercial stakeholders
to provide cost estimates for implementing the solution evaluated in the Report.
These questions here are for the consumer-electronics
companies (CE) and information-technology companies ( IT).
-
Section X-3 of the
Requirements Document details a number of requirements for protecting Unscreened
DTV data. Section X-4 provides similar requirements for protecting Marked
Content.[15]
The Committee should seek:
-
a block diagram for
implementing the Section X-3 and X-4 requirements for protection in a typical
DTV device (e.g., a set top DTV receiver, receiver in a DTV set, or DTV receiver
card in a PC).
-
an estimate of the cost to
engineer such protection in a typical product family.
-
the total estimated
engineering cost for such protection for all company's current and planned DTV
products.
-
An estimate of the cost that
will be passed on to consumers in order to comply with Sections X-3 and X-4.[16]
In addition, we understand
that technologies proposed as Authorized Technologies are governed by license
agreements and require the payment of licensing fees both by implementers and
Studios. (See Report Section 6.6.1
and Tabs F-1, H-1, and H-2.) The Committee should seek answers to the following
questions regarding licensing fees and related costs:
-
What are the estimated
annual costs of license fees for DTV product lines assuming adoption of the BPDG-evaluated
technology and Authorized Technologies?
-
What other costs associated
with adopting and utilizing Authorized Technologies are not included in the
questions above?
V. What Are the Alternatives?
The Report is
silent with respect to alternatives.[17]
Value-added, competitively priced video distribution systems may well
stem the need to deploy a complex broadcast protection system.
With an eye to preserving trade-secret and other confidential
information, we suggest that the Committee ask MPAA to confidentially survey its
members and answer the following questions as completely as possible without
revealing individual company plans:
-
Are Studios planning to roll
out digital distribution systems on the Internet and elsewhere, apart from their
DTV plans?
-
Will these systems include
content slated to be protected under the system contemplated by the Requirements
Document?
-
If few digital distribution
launches are planned, why not?
VI. Conclusion
More dialog must be
had with stakeholders, including consumer representatives, to determine the
costs and inconvenience of the proposed broadcast flag system, and to determine
whether it can be structured in such a way that responds to consumer interest in
flexibility and backwards compatibility. Such
a dialog will contribute to another crucial goal: evaluating the Report within a
broader context. Some of these larger questions include: what is the precedent
for the computer and the Internet; how
could a broadcast flag evolve in ways that more deeply constrain consumer
control; how does the broadcast flag fit with other DRM ideas, and what are the
reasonable alternatives for protecting copyright interests, both in terms of
business models and in terms of technology?
In summary, then, we
seek to raise the following three sets of issues regarding the BPDG proposal:
-
What impact will it have on
consumers’ ability to use their existing and future electronic equipment in
ways consistent with copyright protection, including time shifting and moving
legally acquired content from one device to another as they go about their daily
lives? To what extent will it
affect the development and deployment of new consumer and information
technologies?
-
There needs to be a
realistic assessment of the cost-benefits: (a) how effective will the measure be
at solving an identified and documented problem compared with
(b) the costs in terms of product costs, limits on legitimate consumer
activity, and convenience?
-
Finally, from a consumer
perspective, what assurance is there that the proposal, if implemented, would
lead to the substantial release of digital content and the greater availability
and affordability of DTV?
We hope that the
Committee will ask the above questions and carefully consider whether enough is
yet known about the possible impacts on consumers of implementing the proposal
described in the Report. We do not
stand in opposition to the principle of content protection for digital
television, and we embrace the general principle of the need to protect
copyright in the digital age. But we also believe that Congress, in its
factfinding and legislative role, must vet and consider the impact on consumers
of any content-protection system imposed by regulation. We stand ready to help
address these questions.
Alan Davidson,
Associate Director, Center for Democracy and Technology, 202-637-9800, abd@cdt.org
Chris Murray,
Telecommunications and Internet Counsel, Consumers Union, 202-462-6262, murrch@consumer.org
Gigi Sohn, President,
Public Knowledge, 202-518-0020, gbsohn@publicknowledge.org
Consumers Union is a nonprofit membership organization chartered in 1936
under the laws of the State of New York to provide consumers with
information, education and counsel about goods, services, health, and
personal finance; and to initiate and cooperate with individual and group
efforts to maintain and enhance the quality of life for consumers.
Consumers Union's income is solely derived from the sale of Consumer
Reports, its other publications and from noncommercial contributions,
grants and fees. In addition to
reports on Consumers Union's own product testing, Consumer
Reports (with approximately 4.5 million paid circulation) regularly
carries articles on health, product safety, marketplace economics and
legislative, judicial and regulatory actions which affect consumer welfare.
Consumers Union's publications carry no advertising and receive no
commercial support.
[13]
It is important to note that most experts cite numerous
reasons for the slow rollout and adoption of DTV.
At a recent Cato Institute Conference, Richard E.
Wiley, former Chair of the FCC’s Advisory Committee on DTV, listed
seven “hurdles” other than the lack of copy protection, including: 1)
the debate over “progressive” versus “interlaced” scanning; 2) the
problems with VSB modulation standard and the effort to replace it with the
COFDM standard; 3) the lack of DTV monitors that also include DTV receivers;
4) the lack leadership of the broadcast networks in providing HDTV
programming, including programming for which there are minimal copy
protection concerns (e.g.,
sporting events); 5) the inability of cable set-top boxes to pass through
HDTV programming and the lack of cable ready digital television receivers;
6) the FCC’s decision not to require cable systems to carry both analog
and digital broadcast stations during the transition period, along with the
related decision to require cable systems only to carry a digital
broadcaster’s “primary video” program stream; and 7) the lack of
consumer awareness about the transition and its ramifications.
Remarks of Richard E. Wiley,
“A Progress Report on the DTV Transition,” Cato Institute, May 1, 2002,
found at http://www.cato.org/events/020501pf.html.
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