5 7 Joint Comments Opposing Nab Petition For A Mandatory Transition To

Leo Migdal

-Dec 6, 2025, 5:03 AM

5 7 joint comments opposing nab petition for a mandatory transition to

OTI, along with Public Knowledge, Consumer Reports, and other public interest groups, oppose the National Association of Broadcaster’s (NABO) proposal to mandate a nationwide transition to a new digital over-the-air TV standard (ATSC 3.0)—thereby... NAB’s plan is deeply flawed and prioritizes broadcaster profits and control at the expense of the public interest. The Commission must not authorize this under the guise of modernization. The public interest cannot be served by creating technological barriers to reception of free broadcast signals. Historically, the Federal Communications Commission's (FCC) broadcast priorities have included the universality, affordability, and openness of access to over-the-air content. Any mandatory transition to a new standard must preserve these values.

It must ensure universal and equitable access to service; strong and enforceable public interest obligations; affordable and interoperable reception equipment; non-discriminatory access to devices and content; robust privacy protections; and the safeguarding of fair... Unless these concerns are addressed, we urge the Commission to reject the NAB petition. The proposal by NAB to mandate a nationwide transition to ATSC 3.0 by 2030 imposes significant and unjustifiable burdens on American consumers. While broadcasters stand to benefit from expanded commercial opportunities—including targeted advertising, datacasting, and retransmission fees—consumers are asked to absorb the costs of new equipment, navigate technical complexities, and potentially lose access to free over-the-air... This cost-shifting is neither equitable nor consistent with the Commission’s longstanding obligation to ensure universal, affordable access to essential communications services. It also marks a shift in policy from the previous analog-to-digital broadcast transition, where Congress, in the Digital Transition and Public Safety Act of 2005, made a subsidy available to every household to cover...

For millions of Americans—particularly those in low-income households, rural communities, tribal areas, or elder populations—broadcast television remains a primary or exclusive source of news, educational content, emergency alerts, and entertainment. These communities are least likely to upgrade their hardware frequently and are disproportionately affected by costs associated with new tuners, incompatible televisions, or internet-enabled features. These issues are compounded by the pervasive and inappropriate incorporation of Digital Rights Management (DRM) into the ATSC 3.0 standard, which fundamentally contradicts the Commission’s mandate to promote access, localism, and diversity. To that end, while the NAB’s petition should be denied, the FCC should condition any eventual transition on the implementation of a robust consumer protection plan, including: A coalition of six industry groups representing consumer electronics, pay-TV operators and broadcasters formally opposed the National Association of Broadcasters’ petition for a mandatory transition to ATSC 3.0 during a June 27 meeting with... The stakeholders, including the Consumer Technology Association, Public Knowledge, NCTA, ACA Connects, American Television Alliance and LPTV Broadcasters Association, detailed their objections to NAB’s February petition in a July 1 letter to the FCC.

The petition requests a two-phase transition deadline that would require full-power stations in the top 55 markets to end ATSC 1.0 simulcasting by February 2028, with remaining markets following by February 2030. The Consumer Technology Association reiterated its position that the transition to ATSC 3.0 should remain voluntary, arguing that “a mandatory transition to ATSC 3.0 would harm consumers by imposing real costs for consumers, stifling... Brian Markwalter, CTA’s senior vice president of research and standards, and Rachel Nemeth, senior director of regulatory affairs, represented the organization at the meeting. Six groups said they had different perspectives but ‘one goal’ in urging the regulator to ‘deny NAB’s requests’ When you purchase through links on our site, we may earn an affiliate commission. Here’s how it works.

WASHINGTON—Representatives from six trade groups representing tech, pay TV, broadband, LPTV and other sectors recently met with Federal Communications Commission staff to detail their opposition to the "Petition for Rulemaking and Future of Television... “This diverse group of stakeholders represents different aspects of the television marketplace, and each is on record individually opposing NAB’s Petition,” the groups said in a letter to the FCC summarizing the meeting. “Each participating organization has a different perspective, but we all have a common goal. We respectfully urge the Commission to deny NAB’s requests.” In a February filing, the NAB proposed the FCC mandate a two-phase transition deadline. In the first phase of the NAB proposal, full-power stations in the top 55 markets (reaching about 70% of viewers) would be required to transition fully to ATSC 3.0 (i.e., end ATSC 1.0 simulcasting)...

In the second phase of the NAB proposal, stations in the remaining markets would be required to transition fully to ATSC 3.0 in February 2030. The NAB is also asking that ATSC 3.0 tuners be mandated in all new TV sets. We, the undersigned organizations, urge you to reject the National Association of Broadcasters’ petition to force competitors to use their preferred technology. While broadcasters operate under the strain of onerous regulation dating from the Second World War, new mandates on other technologies are not the solution. NAB petitioned the Commission to mandate the adoption of Next Generation Television (Next Gen TV) with Advanced Television Systems Committee (ATSC) standards, despite widespread adoption already. Next Gen TV is already operating on ATSC 1.0 to ATSC 3.0 technologies available for broadcasters and multichannel video programming distributers (cable and satellite) should they choose to use it.

And they have chosen. More than three out of every four Americans have access to ATSC 3.0. It is available in more than 80 markets in parallel to ATSC 1.0 technology delivering digital television. The argument that this is even a problem demanding the Commission’s intervention is flimsy given this fact. By any reasonable standard, this is a success. Under the Commission’s original 2017 report and order authorizing ATSC 3.0, broadcasters are allowed use the new standard on a “voluntary, market-driven basis.” The Commission should maintain its voluntary, market-driven adoption policy that has...

NAB effectively asks the FCC to do their job for them by mandating ATSC adoption in the remaining markets to reach the untapped 25 percent or so of the population. In what is unfortunately a tale as old as time, they would rather use the government to limit genuine competition by forcing their competitors to adopt their standards, ironically in the name of “competition,”... Save this article for later! Login or create a Free Member Profile to bookmark it. A coalition of six industry groups representing consumer electronics, pay TV operators and broadcasters formally opposed the National Association of Broadcasters’ petition for a mandatory transition to ATSC 3.0 during a June 27 meeting... This article was originally posted on newscaststudio.com

The National Association of Broadcasters responded sharply to industry opposition against its ATSC 3.0 transition petition, accusing cable companies and consumer electronics groups of “protecting their turf” rather than serving the public interest. In a July 7 blog post, NAB Chief Legal Officer Rick Kaplan dismissed objections raised by six industry groups during a recent Federal Communications Commission meeting as “reflexive, innovation-blocking” efforts from “the usual suspects.”... Six industry groups tell FCC to reject NAB’s ATSC 3.0 transition plan NAB’s petition requests a two-phase timeline requiring full-power stations in the top 55 markets to end ATSC 1.0 simulcasting by February 2028, with remaining markets following by February 2030. The proposal also seeks mandatory ATSC 3.0 tuners in new television sets. Kaplan challenged the coalition’s cost arguments, particularly CTA’s analysis showing ATSC 3.0-capable televisions cost an average of $157 more than ATSC 1.0-only models.

In its petition, the National Association of Broadcasters (NAB) asks the Commission to mandate the transition of broadcast signals to the ATSC 3.0, a departure from the voluntary transition agreed to in 2017.[2] NAB... Undoubtedly, ATSC 3.0 has new functionalities that benefit consumers, and the Commission should encourage the continued deployment of next-generation technology to allow competition on the merits, but mandating the transition has significant costs that... If consumers demand ATSC 3.0 functionality, broadcasters would make the transition with little hesitation. But while some consumers will choose this service, the market is flooded with video options including internet-based streaming services, cable television, and satellite. By mandating a transition, the Commission would essentially require equipment manufacturers and alternative video distribution providers such as cable and satellite television to add additional costs to new devices and services, regardless of whether... Instead of mandating the transition to ATSC 3.0, the Commission should continue with the voluntary transition but also remove restrictions on broadcasters that make it more difficult for the industry to compete with alternative...

Most important, the Commission should continue its work easing the ownership restrictions, allowing firms with multiple stations in a market to make the transition all at once. Also, the Commission should eliminate the mandatory simulcasting requirement that forces broadcasters to maintain an ATSC 1.0 signal. Finally, the Commission should ease content-based restrictions such as the news distortion rule and children’s programming requirements, allowing broadcasters to deliver the content that best suits their viewers’ needs. If done right, the Commission can allow ATSC 3.0 to compete with alternative video options without forcing consumers to pay the price for products and services they do not want. The Commission Should Maintain the Voluntary Transition to ATSC 3.0 To Allow the Market To Decide Its Value In its petition, NAB argues that an industry-wide mandate is necessary to fully transition to ATSC 3.0, but instead many broadcasters are choosing not to transition because the small consumer demand does not justify...

If consumers value the enhanced capabilities of ATSC 3.0, they will purchase the necessary equipment to receive those signals and tune into the stations that deliver the services they desire. If consumers do not value those services over existing quality, they will not. Broadcast television has many unique benefits, but the Commission should not artificially prop up the industry, especially when so many rival video services exist.

5 7 Joint Comments Opposing Nab Petition For A Mandatory Transition To

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OTI, Along With Public Knowledge, Consumer Reports, And Other Public

It Must Ensure Universal And Equitable Access To Service; Strong

For Millions Of Americans—particularly Those In Low-income Households, Rural Communities,

The Petition Requests A Two-phase Transition Deadline That Would Require

WASHINGTON—Representatives From Six Trade Groups Representing Tech, Pay TV, Broadband,