Comcast’s DTV Triple Play

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Comcast Corp. is indicating that market forces alone could prompt the country’s largest cable company to carry three versions of a single broadcast-TV signal on a voluntary basis.

Comcast included the carriage scenario in letter to the Federal Communications Commission last Thursday that was primarily devoted to rebutting claims by NBC and other broadcasters that $85 billion cable spent on digital upgrades will easily accommodate multiple programming streams generated by a single DTV station.

For a DTV station transmitting a high-definition picture, Comcast said, negotiations could result in the following: carriage of the HD signal; analog carriage of the HD signal (because nearly two-thirds of Comcast subscribers are still analog-only); and simulcast carriage of the HD signal in “compressed digital” format to accommodate subscribers without HD boxes.

Comcast said it would have to set aside 6 Megahertz for the analog feed, between 2 and 4 MHz for the HD feed, and 0.6 MHz for each compressed digital version — a 10-1 digital-to-analog ratio that suggests that only one or two 6 MHz analog channels would be needed in most markets to carry every DTV station in that compressed digital format.

By offering this scenario, Comcast’s point was that during and after the broadcasters’ transition to digital, cable companies would have to set aside substantial bandwidth to ensure that its subscribers received broadcast programming in a manner compatible with the equipment in their homes.

Comcast’s scenario was also intended to demonstrate that a requirement that cable companies carry every programming service that a DTV station can cram into its digital bitstream would place additional burdens on cable’s channel capacity, notwithstanding NBC’s claims.

“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,” Comcast said.

DTV stations can’t elect must-carry under current FCC rules until they surrender their analog licenses. Comcast did not outline a scenario for stations electing digital must carry. However, it seems likely that DTV stations that elect must carry would also be carried in analog for the benefit of Comcast subscribers that didn’t have digital reception equipment.

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.

In 2001, the FCC said broadcasters were entitled to carriage of single service as a matter of law. The cable industry supports that policy, adding that carriage of additional services should be negotiated.

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 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

NBC’s analysis of cable’s bandwidth requirements was contained in April 2004 report submitted to the FCC. Joining NBC in the study were its independent affiliates and the independent affiliates of ABC and CBS.

Comcast said NBC’s bandwidth assumptions were wrong because of the company’s ongoing need to service its installed analog base while rolling out digital service to subscribers that have purchased digital TV sets or have digital set-tops.

“What … NBC demonstrates is that NBC’s lawyers and technical adviser have a seriously flawed understanding of cable system operations,” Comcast told the FCC in a six-page letter signed by outside counsel James Casserly.

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