Federal Communications Commission FCC 08-278
1
STATEMENT OF
COMMISSIONER ROBERT M. McDOWELL
RE: Amendment of Parts 73 and 74 of the Commission’s Rules to Establish Rules for Replacement 
Digital Low Power Television Translator Stations (MB Docket No. 08-253)
I support this new rulemaking as another potential means of helping 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.  Like the rules we adopted in November 2008 
for Distributed Transmission System (“DTS”) technology, these proposed rules for establishing a new 
DTV “replacement” translator service could assist television broadcasters in overcoming two types of 
technical issues that may limit the reach of their over-the-air digital signals.  First, new translator facilities 
may help TV broadcasters solve a “digital cliff” problem, i.e., the abrupt loss of the signal due to 
interference within their authorized DTV service area.  Second, those broadcasters whose digital signals 
are designed to cover a smaller territory than their old analog signals might use these new DTV 
translators to push their signals out to regain lost ground.
It remains to be seen, however, just how feasible – both technically and financially – this new TV 
translator service may be.  For example, in contrast to DTS technology which operates on the same 
frequency as the broadcaster’s existing TV station, the proposed TV translators must use different 
frequencies.  How much room, particularly in big-city markets, will there be for such new facilities?  And 
what effect, if any, would the new TV translator service have on the future use of “white spaces” for other 
wireless services?  From the financial perspective, some posit that the proposed DTV replacement service 
is a more economically attractive option than DTS.  Even if that is so, are financially strapped 
broadcasters today going to spend their money on these new facilities when it is tough enough to keep the 
core service going?  I look forward to reviewing comments on these questions and the many others posed 
in the Notice.
No matter how this rulemaking ends, it will not resolve all DTV coverage problems by February 
17.  Those issues have been troubling to me for awhile.  During my DTV outreach trips, I have made a 
special point of urging each local TV station to educate its own audience now about any known technical 
issues that may deprive some viewers of access to a good over-the-air signal after the transition.  Whether 
a broadcaster chose to contract its DTV signal or was forced by technical circumstances to do so, I 
believe that the station’s public interest obligation includes informing its local audience, directly and 
plainly, about any predicted loss of over-the-air service.  
And all broadcasters need to keep up – and, in fact, step up – the pace to educate and assist the 
approximately 12 percent of the nation’s households that rely solely on rabbit-ear or rooftop antennas to 
obtain television service.  It is these viewers who most concern me now.  There are some hopeful 
developments on this front.  Recent NTIA statistics show that a growing number of Americans are 
applying for the government coupons to help subsidize the purchase of DTV converter boxes that will 
keep analog sets operating after February 17.  TV broadcasters in many markets are jointly running “soft 
tests” in their communities to warn consumers with analog sets about the need to take action.  I hope that 
stations continue to run such tests, and that they do so for increasingly longer intervals to make sure that 
the message gets heard.  I continue to encourage broadcasters in each market to band together to operate 
local phone banks and work with third-party groups to assist those who need help installing converter 
boxes or adjusting antennas.  I also applaud NAB for recently announcing the establishment of a 
nationwide hotline to answer consumer calls about the transition.  And I’m pleased that Congress has 
passed the SAFER Act – the so-called “DTV Analog Nightlight” legislation – that will allow broadcasters 
to continue to provide DTV education and public safety information in analog format for 30 days after the 
transition deadline. 
Federal Communications Commission FCC 08-278
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Despite these signs of progress, it appears likely that the DTV transition will be messy for those 
who, by choice or circumstance, must depend on converter boxes to keep TV service in their homes.  For 
that reason, I strongly encourage everyone to join the government and industry to help those most at risk 
of being left behind when the change comes:  the elderly, the infirm, low-income individuals, and non-
English speakers.  People should not wait until February 17 to help themselves and their neighbors, 
friends, and family get ready for DTV.  I particularly urge those who don’t need the government subsidy 
not to wait on that process before purchasing a converter box for themselves or as a gift for someone else.  
During the weeks it takes for the government to process coupon requests, you will lose precious time to 
hook up the box, check antenna connections, and start enjoying free digital broadcast TV right away.