Federal Communications Commission FCC 08-256
STATEMENT OF 
COMMISSIONER ROBERT M. McDOWELL
Re: Digital Television Distributed System Technologies; MB Docket No. 05-312
By adopting rules that allow broadcasters to take advantage of Distributed Transmission 
System (“DTS”) technology, we hope to help consumers who may find themselves without over-
the-air access to one or more of their favorite broadcast stations after February 17, 2009, the 
nation’s digital television transition deadline.
DTS is not a new concept.  The technology relies on use of a series of transmitters 
located throughout a station’s authorized service area – rather than the traditional, centrally 
located single “stick” – to broadcast a digital television signal.  Because of the flexibility 
provided by multiple transmitters, broadcasters who choose to make use of DTS will be able to 
reach viewers whose TV receivers might otherwise be blocked by terrain or other sources of 
interference.  And because the multiple transmitters are technically capable of using the same 
frequency throughout the TV station’s service area, DTS makes more efficient use of spectrum 
than do the comparable analog TV booster stations (which must employ different frequencies to 
improve the main analog station’s reach).
Plainly, the new DTS rules can assist television broadcasters in overcoming the so-called 
“digital cliff” problem within their authorized DTV service areas, i.e., the abrupt loss of the 
signal due to interference within the station’s service area.  But our action today goes a step 
further to address a different concern highlighted by the early DTV transition in Wilmington, 
N.C.  As our DTV call center’s data from September reflect, some viewers in the outer edges of 
the Wilmington region were unhappily surprised to learn that one local station’s authorized DTV 
service area is notably smaller than its old analog service area.  In response to that situation, our 
Report and Order allows licensees to seek a waiver, during a limited window of time, to apply 
for DTS facilities that would extend the station’s digital signal out to the old analog Grade B 
contour.  I hope that this limited waiver mechanism will help over-the-air viewers in more distant 
locations to continue to receive broadcast programming that they have long enjoyed.  
I note, however, that nothing in our decision today requires broadcasters to make use of 
DTS technology – and even those licensees who are interested in it are unlikely to be able to 
construct DTS facilities before February 17.   I therefore renew my call to broadcasters to work 
diligently, starting now, to inform their viewers about any technical issues that may affect over-
the-air reception in their communities.  In particular, I urge stations in each market to consider 
jointly producing and airing a local “infomercial” about how their viewers should prepare for the 
DTV transition.  Such locally focused programs, especially if they feature engaging on-air 
personalities, could be an ideal, user-friendly way to convey important information about 
specific technical issues confronting a community, such as digital cliff problems or a station’s 
smaller DTV service area.  A local infomercial also could greatly assist consumers grappling 
with tasks that people in many markets may confront, including converter box connections and 
antenna positioning.  It is past time for DTV education efforts to move from generalized 
messaging to targeted assistance for consumers.