Policy

Comcast Questions NBC’s Multicasting Analysis

9/17/2004 3:52 AM Eastern

Comcast Corp. is challenging NBC’s claims that cable’s channel capacity, boosted by digital upgrades, will easily accommodate multiple digital-programming services that TV stations now have on the drawing board.

In a letter filed Thursday night, Comcast told the Federal Communications Commission that NBC’s assertions were wrong because the network’s analysis assumed that cable operators will be able to reclaim analog bandwidth within a few years.

Comcast said that although it is a digital-television leader, nearly two-thirds of its 22 million subscribers are analog-only and will remain so until they acquire digital-TV sets or digital converters for each analog-TV set.

With such a large installed analog base, Comcast said it is at least five years away from shutting down analog transmission, going all-digital and freeing up the channels TV stations are eyeballing for themselves.

“The need to deliver many channels in analog will continue for years to come,” the MSO said in a six-page letter prepared by outside counsel James Casserly.

Because so much legacy analog equipment remains in the market, Comcast said it will need to continue analog service even after TV stations have ceased analog transmission -- which, under a current FCC proposal, would occur Dec. 31, 2008.

“The need to deliver signals over the cable in analog format will be eliminated only when the cable operator is able to place some sort of digital-decoder functionality on every TV of every cable subscriber -- a development that is not contemplated in the near- or medium-term future,” the operator added.

NBC is seeking a multicast must-carry rule from the FCC. Digital spectrum permits TV stations to segment their bandwidth into five or six services -- a vast improvement over analog technology that limits a station to one service.

Along with other broadcasters, NBC has argued that because a TV station’s digital signal -- whether a single HDTV service or multiple programming streams -- can squeeze into a space one-half the size of an analog cable channel, cable operators are unable to claim that a digital-multicast must-carry requirement would impose additional burdens on cable-channel capacity.

Comcast noted that it would have to set aside substantial bandwidth for TV stations after the transition and the burden would only grow if cable had to carry more than a single digital-TV service.

After broadcasters make the transition, Comcast said, “marketplace forces alone” would require it to carry a digital-TV signal in analog to serve millions of analog-only subscribers and in HDTV to serve a growing number of subscribers with HDTV receivers.

Comcast also indicated that it would carry digital-TV stations in a “compressed digital” format to accommodate subscribers with non-HD set-top boxes. This is perhaps an indication that the MSO is considering carrying all digital-TV stations in both analog and standard digital format, or dual carriage on a voluntary basis.

“All of this bandwidth, it should be noted, is needed to carry a single stream of broadcast programming, and all of this carriage will occur without government coercion. A carriage requirement applicable to multiple streams of video programming per broadcast licensee would obviously compound the bandwidth demands further,” the operator added.

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