SEPARATE STATEMENT OF 
COMMISSIONER MICHAEL J. COPPS, APPROVING
Re: In the Matter of Third Periodic Review of the Commission’s Rules and Policies 
Affecting the Conversion to Digital Television – MB Docket No. 07-91.
One year earlier would have been the charm.  Sometimes timing is everything, 
and here a year's earlier start might have been the difference between a seamless and a 
chaotic Digital TV Transition.  Had we acted then, we could have established a far more 
measured and orderly switch-over process, and the difficult trade-offs and compressed 
schedules contained in this Order could have been largely avoided.  If a dissent could 
legitimately be based on frustration at being stuck in this situation, I would dissent 
today—I am that frustrated by our inaction.
But we are where we are. Given that fact, I think the Order does an acceptable job 
of balancing the various technical and policy factors in play.  Unfortunately, at this point, 
the transition will not be as smooth as it might have been.  Not every consumer will have 
access to all of their analog broadcast channels on February 17, 2009 and then wake up 
happily the next morning to those same stations in digital.  There will be some period of 
time—perhaps before the transition date and almost certainly after—in which some 
stations may not be able to provide service to all of their viewers.  Thankfully, the Order 
adopts our earlier proposal to require every broadcast station in the country to file a DTV 
status report this February—telling us where they are, what more they need to do, and 
how they plan to get there.  Those reports should give us a much better picture of specific 
issues that may arise—hopefully, with enough time to address them.
Pulling the switch on stations all across the land at one and the same time in 
February 2009 is going to be a real throw of the dice.  It is unfathomable to me that we 
are planning to turn off every full-power analog signal in the country on a single day 
without running at least one test market first. Other countries are transitioning over time, 
with phased schedules.  The United Kingdom, for example, is transitioning between 2007 
and 2012, region-by-region, learning at every step along the way and making the 
necessary adjustments.  The UK recently transitioned the small town of Whitehaven as 
the first step in a multi-year transition plan; a few years ago, Germany took a similar step 
in Berlin.  The lessons learned from those initial test markets doubtless will prove 
invaluable to those countries’ broader transition efforts.  We need some of that real-world 
experience here. Why in the world aren't we doing that?  I am encouraged that the 
Chairman and my colleagues are willing to sit down now and begin exploring the idea of 
one or more DTV demonstration projects around the country.   I recognize there may be 
legal, technical, and practical challenges with planning and conducting such a test this 
close to the national transition date.  But I believe it can be done.  At least—for the sake 
of a successful DTV transition—let’s hope it can.