FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the Matter of
Advanced Television Systems
and their Impact on the
Existing Television Broadcast
Review of Technical and
Part 73-E, Television Broadcast
Reevaluation of the UHF Television
Channel and Distance Separation
Requirements of Part 73 of the
Federal Coml1lun.callulb Lomrnls:>lull
Office 01 the Secretary
RE: FCC 88-288
COMMENTS OF A-VISIONTM
A-VISIONTM (I Ken Lager)
Boston, USA (617) 646-0300
Washington, DC (703) 237-2623
Chairman & CEO
October 31, 1988
75 Marathon Street
Arlington, MA 02174
A-VISIONTM, an ATV proponant engaged in the development of advanced
television (ATV) and media related systems, hereby submits the following
comments relative to the Tenative Decision and Further Notice of Inquiry
(Further Notice or FN) in MM Docket No. 87-268 released by the Commission
on September 1, 1988.
~5-2 ATV SYSTEMS FOR TERRESTRIAL BROADCAST
A-VISION TM is developing the A-VISION TM A1? Family of Single
Channel 6 MhZ Systems. The first A1? ATV systems are for single channel
NTSC compatible terrestrial broadcast. These ATV systems compatibly
provide significantly improved audio and video performance with reduction
of artifacts and improved resolution, options for current standard aspect
ratio and wider aspect ratios, interlaced or progressive scanning, and are
both compatible and extensible with A-VISIONTM A2? systems' spectrum
-compatible augmentation channels. Funding, however, is very critical.
~5-3 ALLOCATION OPTIONS
Option (a) - Within existing 6 MhZ:
A-VISION TM A1TM Single Channel Compatible 6 MhZ Systems
Option (b) - Additional 3MHz for augmentation signal
Option (c) - Additional 6MHz for augmentation signal, or for dual
non-compatible ATV signal:
A-VISION TM A2? Dual Channel Spectrum Compatible Systems
1f 5-4 ATV AND NTSC STANDARDS
The opportunity for thorough development, experimentation and testing
of ATV including modified NTSC systems should be provided. Therefore
carefully relax NTSC standards early to permit early testing of alternatives.
Early spectrum availability for testing should be accomodated.
1f 5-6 ADJUSTMENTS
In order to encourage the prompt and efficient introduction of ATV, the
possibility of making adjustments should be left open.
1f 21 COMPATIBILITY AND WORLD-WIDE PRODUCTION STANDARDS
Although present ATV systems and world-wide production standards as
now proposed do not yet seem to have the degree of compatibility that
would encourage international agreement on a single world-wide HDTV
production standard (or heirarchy of extensible standards), the difficult
goal is technically possible if its development is properly funded.
From a global perspective, the first goals of globally converging
compatible architecture systems (as suggested in the November 17,1987
FCC NOI Comments by A-VISION TM and in part restated here) are as follows:
A primary goal and requirement of the global system architecture
should be the evolutionary compatible convergence of the various
significant systems (television, film, computer graphics and related media
systems) toward a common globally-compatible but extensible
open-architecture integrated system.
The advanced television global system architecture (ATV GSA) system
should be compatible with the human visual system, compatible with and
extensible to NTSC and other existing and anticipated systems, and be
bandwidth efficient, friendly, and cost effective.
The ATV GSA should not only provide the anticipated video/audio
performance quality improvements with artifact-free, flicker-free TV
display, but also should provide a way to more easily integrate any of the
present global systems (both the 525-line NTSC systems and the 625-line
systems), as well as more easily accommodate the various frame rates of
television, film and computer graphics related industries (including, for
example, 24, 25, 30, 50, 59.94, 60, 66, 72 Hz and other frame rates).
A-VISION has been actively developing just such ATV technologies and
systems, but critically needs the necessary funding to make them available
to the industry.
~119 OPEN ARCHITECTURE AND RECEIVER COSTS
Hopefully the receiver manufacturer can find cost-effective ways to
provide sufficient powerful modular interfaces and to consider options such
as multi-sync to preclude being obsolete early, and find ways to market
these capabilities as advantages and features if appropriate.
~120 TIMING OF ADOPTION OF STANDARDS
Sufficient funding for the development of the powerful new ATV
technologies needs to be provided first. Some of the potentially most
powerful technologies seem to be coming from some of the least well
funded groups. Next sufficient time to develop and test needs to be provided
for. After thorough testing of really superior ATV technologies, we would
then be in a good position to select and adopt significantly better standards.
~122-1 ATV TRANSMISSION STANDARDS
Working toward a common ATV transmission system standard, both
globally and domestically, is desirable. But until there is better support,
both financially and politically, for a better common standard, it is still too
early to determine exactly what that probably desired standard would be.
~122-4 ATV STANDARDS AND RECOMENDATIONS
Given the extent of ATV development globally, and the global number of
systems, a recommendation would be more appropriate, at least until a more
globally common system could be developed, tested, and accepted.
~122-5 OPEN ARCHITECTURE
The open architecture should be a way to provide extensibility into the
future, and not be an alternative or a substitute for evolving a good system
architecture. Hopefully the preferred systems as they evolve both have
extensibility for the future as well as potentially allow the presently used
global systems to better integrate and converge toward more powerful
common systems. Similarly, hopefully the open architecture receiver is not
a substitute for the evolving standards setting, but rather a powerful
implememtation option with a great deal of future reach.