Group Comments On Atsc 3 0 Proposal Public Knowledge

Public Knowledge, along with Open Technology Institute at New America (OTI), Electronic Frontier Foundation (EFF), Consumer Reports, Access Humboldt, and Media Council Hawaii, filed comments before the Federal Communications Commission (FCC) regarding the Petition... The comments urge the FCC to not allow the NAB’s proposal for a nationwide transition from ATSC 1.0 to ATSC 3.0, highlighting the proposal’s potential harms to competition and to consumers. In February, the National Association of Broadcasters (NAB) asked the FCC to set a deadline for shutting down ATSC 1.0 and transitioning to ATSC 3.0, also known as NextGen TV. Now, the FCC is seeking comments on the proposal, as well as any other potential issues that should be discussed before the transition. The NAB suggested a two-phase plan. First, they asked that stations in the top 55 markets, which cover about 70% of U.S.

households, switch to ATSC 3.0 by February 2028. The second phase would have all remaining markets make the switch before February 2030. Comments can be submitted here, where you can also read the comments of other interested parties. In the document seeking comments, the FCC notes that it received thousands of complaints from consumers about Digital Rights Management encryption on ATSC 3.0 signals which could block consumers from watching programming. The FCC asks “What steps can or should the industry and/or the Commission take to ensure broadcasters are able to protect their content and signal, while also ensuring viewers are able to continue to... Individuals and companies are also seeking comments about additional issues with moving to ATSC 3.0, specifically mentioning a few potential barriers to the transition, 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. The voluntary, market-by-market transition to the ATSC 3.0 standard has reached a critical juncture, and the broadcast industry’s leading advocate is now demanding a finite end to the process.

The NAB’s Petition marks the official start of a new, potentially contentious, phase in the evolution of over-the-air television, shifting the debate from "how" to "how soon." If you need to stay up to date with live email updates when filings hit the FCC's ECFS, check out docket-rocket.io. Create an account to set up email alerts for dockets or filers you care about. For instance, if you want an email alert when the NAB files in any proceeding on ECFS, Docket Rocket alerts will send you an email to access an AI-generated summary of the filing as... Thanks for reading Docket Rocket’s Substack! Subscribe for free to receive new posts and support my work.

The National Association of Broadcasters (NAB) has formally asked the Federal Communications Commission to set a hard deadline to shut down legacy ATSC 1.0 broadcasts. On February 26, 2025, the NAB submitted a detailed Petition for Rulemaking in the Authorizing Permissive Use of the “Next Generation” Broadcast Television Standard proceeding (GN Docket No. 16-142). 1 Arguing that the transition risks stalling without decisive Commission action, the NAB proposes a coordinated, industry-wide plan to complete the migration to ATSC 3.0. The petition asserts that while Next Gen TV service is now available to over 75% of the U.S.

population, the parallel requirement to maintain ATSC 1.0 simulcasts creates spectrum constraints and market uncertainty that stifle investment and innovation. A major filing was submitted just before the ATSC 3.0 public comment deadline by a coalition including Public Knowledge, the Electronic Frontier Foundation, Consumer Reports, and several other organizations. Their message to the FCC is clear: DRM has no place in public broadcast spectrum. You can read the document here and watch my analysis piece here. Their argument centers around the idea that mandatory encryption under ATSC 3.0 fundamentally conflicts with the legal and constitutional frameworks that have long governed broadcast TV. One case they point to is American Library Association v.

FCC, where a rule that would have forced devices to honor a broadcast flag was overturned. The court concluded that the FCC had no authority to regulate what happens inside consumer devices once a signal is received. That precedent is particularly relevant as we now face a situation where encryption could prevent people from exercising their long-established right to record broadcasts. The filing emphasizes that public spectrum isn’t a private asset—it’s a shared, collectively owned resource managed under a mandate to serve the public interest. That’s different from how spectrum is handled in industries like mobile phones, where companies purchase and control allocated spectrum. Here, broadcasters are allowed to profit, but only as trustees serving the public.

What stood out in this filing was how thoroughly it outlined the risks to consumers. Many certified ATSC 3.0 devices are already showing their flaws—most require Internet access to tune televisions, others are running outdated software, and few give users any meaningful flexibility. If encryption becomes the norm, gateway devices, DIY DVRs, open-source solutions, and even basic home recording could vanish. In February, the National Association of Broadcasters (NAB) asked the FCC to set a deadline for shutting down ATSC 1.0 and transitioning to ATSC 3.0, also known as NextGen TV. Now, the FCC is seeking comments on the proposal, as well as any... Google's tensor processing units (TPUs) have generated excitement as an alternative to Nvidia's GPUs, but a RAN role for them is unlikely.

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. Conservative groups and the Consumer Technology Association argued in reply comments filed by Friday’s deadline that a mandatory transition to ATSC 3.0, as NAB proposed, would fly in the face of FCC Chairman Brendan...

In its own comments, NAB argued that a mandate is necessary for broadcast competition, saying it's no different from the DTV transition. Communications Daily is required reading for senior executives at top telecom corporations, law firms, lobbying organizations, associations and government agencies (including the FCC). Join them today! “At a moment when Chairman Carr and the FCC seek to slash regulatory red tape, the NAB proposal would encumber one of the most dynamic sectors of America’s economy in more red tape,” said... NAB’s plan “imposes a heavy-handed regulatory scheme that conflicts with the Trump Administration and FCC’s laudable commitment to deregulation, competition, and market innovation,” said the Taxpayers Protection Alliance. Digital Liberty pointed out that NAB’s call to force a transition runs exactly counter to its arguments for ownership deregulation.

"Granting the petition would only impose on other market actors the same type of outdated, needless regulation that afflicts the broadcast industry at present, a regulatory capture play that no agency of the federal... Let’s call this what it is: An assault on consumer freedom.”

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