Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of )
)
Amendment of Parts 73 and 74 of the )
Commission’s Rules to Establish Rules )
For Digital Low Power Television, ) MB Docket No. 03-185
Television Translator, and Television )
Booster Stations and to Amend Rules )
For Digital Class A Television Stations )
)
To: The Commission
COMMENTS OF HARRIS CORPORATION
December 17, 2010
i
TABLE OF CONTENTS
I. HARRIS IS COMMITTED TO FACILITATING ALL
BROADCASTERS CONVERSION TO DIGITAL
BROADCASTING IN ORDER TO PROVIDE VIEWERS
WITH NEW INNOVATIVE SERVICES ………………………………………………..2
II. TO COMPLETE THE TRANSITION OF ALL
TELEVISION STATIONS TO DIGITAL
BROADCASTING THE COMMISSION SHOULD
ESTABLISH A HARD TRANSITION DATE FOR
CONVERTING LOW POWER TELEVISION STATIONS
TO DIGITAL OPERATIONS…………………….……………………………….……...3
III. THE COMMISSION SHOULD WAIT TO TAKE ANY
ACTION THAT WOULD REPACK OR REALLOCATE
CURRENT BROADCASTING SPECTRUM UNTIL ALL
TELEVISION SERVICES ARE CONVERTED TO DIGITAL
OPERATIONS………………………..…………...……………………………………...6
IV. DIGITAL BROADCASTING TRANSMISSION EQUIPMENT
IS READILY AVAILABLE AND MANUFACTURERS ARE
PREPARED TO WORK WITH LOW POWER TELEVISION
STATIONS ON THEIR DIGITAL TRANSITION. ……. …………….………………….7
V. HARRIS PROVIDES COMMENT ON A NUMBER OF
ADDITIONAL TECHNICAL AND PROCEDURAL QUESTIONS
POSED BY THE COMMISSION’S FURTHER NOTICE OF
PROPOSED RULEMAKING……………………………………………………………. ..9
1. Harris Endorses the Proposed Commission Filing Freeze on
Certain Analog and Digital LPTV Applications……………………………………….9
2. Holders of Active Digital Construction Permits Should Not
Be Required to Surrender Their Permit Because of the
Expiration of an Associated Analog Construction Permit
That Was Not Utilized……………… …………………………………………………9
3. Class A Stations Should Be Extended Primary,
Protected Status for their Digital Allocation After
Ceasing Analog Operations……………………………………………………………10
ii
4. Harris Endorsees the Commission’s Proposal to
Expand the “30 Mile Rule” to Determine What is
Considered a Low Power Television Minor
Application Change………………………………………………………………….. .10
5. The Commission Should Obtain Actual Vertical
Radiation Patterns for All Low Power Television
Stations to Maximize Use of Broadcasters Spectrum………………… ………………11
6. The Commission Should Maintain Full Power Emission
Masks for Low-Power Television Stations to
Prevent Interference… … … … … … … … … … … … … … … … … … … … … … … … … ...12
VI. CONCLUSION...…………………………………………………………………………12
iii
EXECUTIVE SUMMARY
The benefits that will be provided to the low power television (“LPTV”) community
through the transition to digital broadcasting will be immense. Digital television (“DTV”) will
afford LPTV broadcasters the opportunity to offer viewers new services with added public
interest benefits and become more competitive in the media marketplace. Harris believes the
time is ripe for LPTV stations to complete the process of transitioning to digital broadcasting.
There is a readily available supply of modestly priced broadcast equipment that would enable
LPTV stations to complete their DTV transition over the course of the next two to three years
without detrimentally impacting LPTV broadcasters’ services or viewers. In fact, many LPTV
stations have already voluntarily started the process of making their DTV transition. In addition,
there is currently grant funding available through the National Telecommunication and
Information Administration’s LPTV and Translator Upgrade Grant Program to reimburse LPTV
stations for certain upgrade costs. However, since only LPTV stations in “rural communities”
are eligible to receive grant funding from the LPTV Grant Program, Harris recommends that the
Commission submit a request to Congress to expand the eligibility of the program to include all
LPTV stations.
To provide LPTV broadcasters with a reasonable amount of time to complete their DTV
transition, the Commission should work quickly to conclude the current proceeding and establish
a hard transition deadline. Harris believes that an out of core low-power digital television
(“LPDTV”) transition date of December 31, 2011 and a complete LPDTV transition date of
December 31, 2012, would be reasonable. However, Harris would also support a final LPDTV
transition date in 2013 if the Commission determines, based on the input of the LPTV
community, that such a transition date is more appropriate.
1
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of )
)
Amendment of Parts 73 and 74 of the )
Commission’s Rules to Establish Rules )
For Digital Low Power Television, ) MB Docket No. 03-185
Television Translator, and Television )
Booster Stations and to Amend Rules )
For Digital Class A Television Stations )
)
To: The Commission
Comments of Harris Corporation
Harris Corporation (“Harris”) respectfully submits these comments in response to the
Federal Communications Commission’s (“Commission”) Further Notice of Proposed
Rulemaking1 (“FNPRM”) to consider issues that need to be resolved to complete the low power
television digital television transition (hereinafter “LPDTV transition”). Harris commends the
Commission on issuing this FNPRM. The benefits that will be provided to the low power
television (“LPTV”) community through the transition to digital broadcasting will be immense.
Transitioning to digital broadcasting will provide LPTV stations with many of the same business
opportunities that have been afforded to full power television stations following the completion
of their digital television (“DTV”) transition 18 months ago. Harris encourages the Commission
to complete the transition of all television broadcasting services to digital operations before
1 Amendment of Parts 73 and 74 of the Commission’s Rules to Establish rules for Digital Low Power Television,
Television Translator and Television Booster Stations and to Amend Rules for Digital Class A Stations, MB Docket
No. 03-185, Further Notice of Proposed Rulemaking and Memorandum Opinion and Order, 25 FCC Rcd. 13833
(rel. Sept. 17, 2010) (“LPDTV Transition FNPRM”).
2
taking on any efforts to reallocate or repack television broadcasters existing spectrum allocation,
as proposed in the National Broadband Plan.
Broadcasters’ ability to serve one-to-many is unique across all communications services
and the hyper local benefits provided by both full-power and LPTV broadcasters cannot be
overlooked. There is a readily available supply of modestly priced broadcast equipment that
would enable LPTV stations to complete their DTV transition over the course of the next two to
three years without detrimentally impacting LPTV broadcasters’ services or viewers. Harris
believes that an out of core LPDTV transition date of December 31, 2011 and a complete
LPDTV transition date of December 31, 2012, would be reasonable. However, Harris would
also support a final transition date in 2013 if the Commission determines, based on the input of
the LPTV community, that such a transition date is more appropriate.
I. HARRIS IS COMMITTED TO FACILITATING ALL BROADCASTERS
CONVERSION TO DIGITAL BROADCASTING IN ORDER TO PROVIDE
VIEWERS WITH NEW INNOVATIVE SERVICES.
Harris is an international communications and information technology company serving
government and commercial markets in more than 150 countries. Harris Broadcast
Communications, a division of Harris, is headquartered in Mason, Ohio, and operates the world’s
largest transmitter manufacturing facility in Quincy, Illinois. As the world’s leading broadcast
transmission equipment supplier, Harris is the leader in digital solutions for television and radio
broadcasting.
Harris Broadcast Communications has been at the forefront of the transition to DTV, both
domestically and internationally. During the United States full-power DTV transition Harris
supplied approximately 80% of the DTV transmitters and encoders. Harris is or has been
involved in DTV transitions throughout the world, including in Australia, Brazil, Canada,
3
Russia, Rwanda, and Vietnam. Harris is committed to facilitating technological advancement
within the broadcast industry and focused on helping broadcasters succeed as they transition to
the world of digital media. Harris Broadcast Communications Division is an active member of
industry and standard setting organizations.
II. TO COMPLETE THE TRANSITION OF ALL TELEVISION STATIONS TO
DIGITAL BROADCASTING THE COMMISSION SHOULD ESTABLISH A
HARD TRANSITION DATE FOR CONVERTING LOW-POWER TELEVISION
STATIONS TO DIGITAL OPERATIONS.
According to the Commission’s FNPRM, “56% of the existing 7,536 stations in the low
power television services have taken steps to move toward digital operation.”2 Harris believes
the time is ripe for the remaining 46% of low power stations to begin the process and all LPTV
stations to complete the transition to digital broadcasting in the immediate future. Based on the
progress of LPTV stations current voluntary digital transition efforts, combined with the need to
finish clearing out channels 52-69 and the Commission’s goal to maximize the use of
broadcasters’ spectrum, an out of core LPDTV transition date of December 31, 2011 and a final
LPDTV transition date of December 31, 2012, would be reasonable. Harris would support a
final LPDTV transition date in 2013 if, based on the comments of the LPTV broadcast
community, the Commission deems such a date to be a more suitable. However, Harris does not
believe that there is any added benefit to prolonging LPTV stations’ digital transition beyond
2013.
In 2003 the Commission issued a Notice of Proposed Rulemaking3 that set in motion
steps to “establish a regulatory framework that will hasten the transition of LPTV and TV
2 Id. at 13835, ¶ 5.
3 See Amendment of Parts 73 and 74 of the Commission’s Rules to Establish Rules for Digital Low Power
Television, Television Translator, and Television Booster Stations and to Amend Rules for Digital Class A
4
translator stations to digital operations....”4 The Commission has determined that statute compels
the various classes of LPTV broadcasters (i.e., Low Power Television, Class A, and TV
Translators) to ultimately convert to digital broadcasting.5 While in its 2004 Report and Order
the Commission adopted rules to facilitate the voluntary transition of LPTV stations to digital
operations,6 the Commission properly determined that it was not appropriate to mandate a
LPDTV transition until after the completion of the full-power DTV transition.7 In the Report
and Order the Commission aimed to facilitate LPTV stations conversion to digital operation in a
manner that was the least disruptive on LPTV broadcasters and viewers.8 In particular, the
Commission was concerned that LPTV stations may be disproportionally affected since the
Commission was unable to provide LPTV stations with the spectrum needed to continue to
provide analog and digital service to their viewers throughout the course of the DTV transition.9
However, with the completion of the full-power DTV transition many of the transition concerns
Television Stations, Notice of Proposed Rulemaking, MB Docket No. 03-185, 18 FCC Rcd 18365 (rel. Aug. 29,
2003) (“LPTV Transition NPRM”) (requesting comment on proposed rules for digital low power television).
4Id. at 18366, ¶ 2.
5 “We conclude that Sections 309(j)(14)(A) and 336(f)(4) ultimately compel LPTV, TV translator and Class A
stations to convert to digital. As an integral component of the nation’s television system, we believe that Congress
intended LPTV, TV translator and Class A stations to transition to digital service. thereby permitting their viewers to
realize the benefits of digital broadcast technology.” Amendment of Parts 73 and 74 of the Commission’s Rules to
Establish Rules for Digital Low Power Television, Television Translator, and Television Booster Stations and to
Amend Rules for Digital Class A Television Stations, Report and Order, MB Docket No. 03-185, 19 FCC Rcd.
19331, 19337, ¶ 13 (rel. Sept. 30, 2004) (“LPTV Transition Report and Order”); See 47 U.S.C. § 336(f)(4)(2006)
and 47 U.S.C. § 309(j)(14)(A)(2006).
6 See Id. at 19374-19384, ¶¶ 127-159 (establishing the rules for converting LPTV stations through digital companion
channels and digital flash cut).
7 “We conclude that the better, less disruptive, approach would be for the low power television digital transition to
be completed at some fixed time after the deadline for full-service television stations.” Id. at 19338, ¶ 17.
8 “Our goals in this proceeding are to establish a regulatory framework that will hasten the transition of LPTV and
TV translator stations to digital operations and do so in a manner that minimizes disruption of existing service to the
consumers served by analog LPTV and translator stations.” LPTV Transition NPRM, supra note 4.
9 See LPTV Transition Report and Order, supra note 7, at 19337, ¶ 15.
5
expressed by the Commission in its Report and Order are no longer applicable.10 By waiting
until after the full-power television transition was complete to mandate a LPDTV transition, the
Commission can now provide LPTV stations the “opportunity to operate dual analog and digital
operations for some period of time, thereby creating an incentive and opportunity for their
viewers to transition to digital service without loss of their existing analog service.”11
LPTV broadcasters provide a unique hyper-local service to many unserved communities,
underserved communities, and niche viewers. Converting LPTV broadcasters from analog to
digital operations will afford LPTV stations the opportunity to offer viewers new services with
added public interest benefits. Through the utilization of digital technology LPTV broadcasters
will be able to take advantage of a number of new and innovative service offerings, just as full
power broadcasters have started to do, in addition to their traditional broadcasting services. For
example, digital broadcasting could enable LPTV stations to offer High Definition programming,
multicasting, Mobile DTV, real time and non-real time data services, interactive wireless
services, and many other ancillary services including Internet access. In addition, providing
LPTV stations the ability to offer advanced digital services to viewers will increase their
competiveness in the media marketplace.
In order to provide LPTV broadcasters with a reasonable amount of time to complete
their DTV transition, especially those that have not yet started the transition process, the
Commission should act expeditiously to conclude the current proceeding and establish a hard
transition deadline. Due to the constraints and nature of LPTV broadcasters (i.e., low revenue,
niche viewership, and hyper-local content) Harris believes the Commission should establish a
10 Id. at 19337-19338, ¶¶ 15-17.
11 Id. at 19338, ¶ 17.
6
process to address “hardship” cases.12 The Commission should require LPTV stations requesting
an extension of the mandated LPDTV transition deadline to file a Request for Waiver in
accordance with the Commission’s waiver rules.13 In addition to meeting the Commission’s
threshold waiver requirements, Petitioners should be required to demonstrate that they have
made a good faith effort to make a timely transition and provide detailed information, financial
or otherwise, as to why they will be unable to meet the mandated deadline.
III. THE COMMISSION SHOULD WAIT TO TAKE ANY ACTION THAT WOULD
REPACK OR REALLOCATE CURRENT BROADCASTING SPECTRUM
UNTIL ALL TELEVISION SERVICES ARE CONVERTED TO DIGITAL
OPERATIONS.
Harris does not believe that the Commission should delay the LPDTV transition until
2015, following the conclusion of any reallocation or repacking of the broadcast television bands
as proposed in the National Broadband Plan.14 In fact, the Commission’s approach should be the
opposite. The Commission should wait until the completion of the LPDTV transition before
taking any steps to repack or reallocate existing broadcast television spectrum. Doing so will
provide the Commission with a full understanding of television broadcasters’ digital spectrum
allocations and capabilities. It will also allow the Commission to better determine precisely what
efficiencies can be gained from the broadcast spectrum that may not require repacking or
reallocation.
Broadcasters’ ability to serve one-to-many is unique across all communications services.
Broadcasting provides the public with a hyper-local, free, ubiquitous, point-to-many
12 “Furthermore, we seek comment on how to address “hardship” cases for those stations that, despite their best
efforts, are unable to make a timely conversion.” LPTV Transition FNPRM, supra note 2, at 13838, ¶ 16.
13 47 C.F.R. § 1.925(b)(3) (2009).
14 See Report to Congress, A National Broadband Plan for Our Future, Federal Communications Commission, pgs.
88-93 (rel. Mar. 16, 2009) (discussing methods to repack and reallocate existing television broadcast spectrum
allocations).
7
communications network that is distinct from any other wireless service. The LPDTV transition
will not only provide additional spectral efficiencies, but new service opportunities through the
utilization of digital spectrum and digital broadcasting infrastructure. As previously advocated
for by Harris, the Commission should provide broadcasters, low-power and full-power, the
opportunity to take advantage of new digital broadcasting capabilities prior to pursuing any
reallocation or repacking of broadcasters existing spectrum allocations.15
IV. DIGITAL BROADCASTING TRANSMISSION EQUIPMENT IS READILY
AVAILABLE AND MANUFACTURERS ARE PREPARED TO WORK WITH
LOW POWER TELEVISION STATIONS ON THEIR DIGITAL TRANSITION.
The full-power DTV transition has provided the broadcast manufacturing industry the
experience and knowledge to swiftly transition LPTV stations to digital broadcasting technology.
Harris stands ready to work with the LPTV community to facilitate a prompt and problem free
transition. Harris’ position as the leading supplier in the United States of broadcast transmission
equipment uniquely qualifies Harris to comment on the cost of paying for a complete LPDTV
transition.
Today, the cost of converting LPTV broadcasting facilities from analog to digital is less
expensive than it cost during the full-power DTV transition. Digital broadcasting technology is
in the mass adoption stage of its technology cycle, making equipment less costly for new
adopters. LPTV stations will have the opportunity to benefit from economies of scale and cost
efficiencies that have resulted from the full-power DTV transition in the United States and
ongoing DTV transition efforts taking place throughout the world. In moving forward with the
proposed LPDTV transition the Commission should also consider the energy consumption
15 See Comments of Harris Corporation, A National Broadband Plan for Our Future, Data Sought on Uses of
Spectrum Public Notice 26, pgs. 7-13 (discussing new digital applications currently being rolled-out by broadcasters
and encouraging the Commission to allow broadcasters time to develop and deploy new innovative digital
applications).
8
efficiencies provided by new digital broadcast transmission equipment. Energy efficient DTV
equipment will not only reduce LPTV stations impact on the environment, but will likely reduce
operating costs.
While Harris will not provide comment on the financial ability of LPTV stations across
the country to pay for converting their facilities to digital, a transition on or around December 31,
2012, would coincide with the availability of funding through the National Telecommunication
and Information Administration’s (“NTIA”) LPTV and Translator Upgrade Grant Program
(hereinafter “LPTV Grant Program”).16 Funding is available through the LPTV Grant Program
until September 30, 2012.17 Establishing a transition date of December 31, 2012, would
incentivize LPTV stations to take advantage of the NTIA grant funding. Harris acknowledges
that if a later LPDTV transition date is set LPTV stations will undoubtedly take advantage of the
LPTV Grant Program, as is evidenced by the approximately $10 million in fund already
awarded. However, as seen during the full-power DTV transition, many LPTV stations will
likely put off purchasing equipment for their transition as long as possible and potentially miss
out on the opportunity to apply for grant funding and reduce their transition costs.
Incentivizing LPTV stations to utilize the LPTV Grant Program by setting a final LPDTV
transition deadline for December 31, 2012, will ensure that the use of grant funding is
maximized, reduce the number of waivers filed as a result of hardship, and promptly move the
entire television broadcast industry to the efficiencies of digital technology. However, since only
LPTV stations in “rural communities” are eligible to receive grant funding from the LPTV Grant
16 The Digital Television and Public Safety Act of 2005, § 3009 of Pub. L. No. 109-171 (Deficit Reduction Act of
2005), 120 Stat. 4, 26 (Feb. 8, 2006) (establishing the LPTV Translator Upgrade Program) amend by Section 2(b) of
the DTV Transition Assistance Act, Pub. L. No. 110–295, 122 Stat. 2872 (July 30, 2008) (amending Section 3009 to
clarify the period during which NTIA could make awards for the LPTV and Translator Upgrade Program); See 74
F.R. 22402 (May 12, 2009) (announcing the availability of funding in the amount of $44 million for the LPTV and
Translator Upgrade Program).
17 Id. at § 3009(a).
9
Program, Harris recommends that the Commission submit a request to Congress to expand the
eligibility of the program to include all LPTV stations. At minimum, the Commission should
recommend to Congress that the LPTV Grant Program be expanded to include any LPTV
station, regardless of location, that can demonstrate an inability to meet the Commission’s
mandated LPDTV Transition date due to financial hardship.
V. HARRIS PROVIDES COMMENT ON A NUMBER OF ADDITIONAL
TECHNICAL AND PROCEDURAL QUESTIONS POSED BY THE
COMMISSIONS FURTHER NOTICE OF PROPOSED RULEMAKING.
1. Harris Endorses the Proposed Commission Filing Freeze on Certain Analog and Digital
Low-Power Television Applications.18
Harris believes the Commission should dismiss pending applications for new analog
LPTV felicities that have not amended their applications to specify digital facilities after May 24,
2010. In addition, Harris endorses the Commission’s initiation of a filing freeze on applications
for new analog LPTV facilities and new or modified analog or digital LPTV facilities in
channels 52-69. Instituting this filing freeze is important if the Commission is to promptly begin
the process of converting LPTV stations from analog to digital operations and facilitate the
deployment of new services in the 700 MHz spectrum band.
2. Holders of Active Digital Construction Permits Should Not Be Required to Surrender
Their Permit Because of the Expiration of an Associated Analog Construction Permit
That Was Not Utilized.19
An entities active digital construction permit should not be forfeited because of the
expiration of an associated analog construction permit that was not utilized. The holder of an
active digital construction permit should be allotted the time to build-out their digital facility as
specified in the permit. However, it would be appropriate for the Commission to send a letter of
18 LPTV Transition FNPRM, supra note 11, at 13842-13843, ¶¶ 26-28.
19 Id. at 13843-13844, ¶¶ 29-31.
10
inquiry to the holder of an expired analog construction permit but active associated digital
construction permit seeking written confirmation that they still plan on building out a digital
facility within the timeframe specified by their digital construction permit. Should the
Commission fail to receive confirmation from the permit holder within a reasonable period of
time, for example 60 days, then the Commission should initiate a proceeding to rescind the
digital construction permit.
3. Class A Stations Should Be Extended Primary, Protected Status for their Digital
Allocation After Ceasing Analog Operations.20
Harris agrees with the Commission that Class A stations’ digital channels should be
extended primary, protected status. Harris also agrees with the Commission’s proposed process
for Class A TV stations to obtain their primary, protected status, including the filing of a minor
change application and certification that their proposed facilities meet Class A interference
protection requirements. However, Class A stations digital channels should only receive
primary, protected status when the station completes its digital transition and ceases analog
operations.
4. Harris Endorsees the Commission’s Proposal to Expand the “30 Mile Rule” to Determine
What is Considered a Low Power Television Minor Application Change.21
The use of the “30 mile rule” to determine what constitutes a LPTV minor application
change is an appropriate threshold. Harris believes that the “30 mile rule” provides LPTV
stations with sufficient flexibility to adjust their transmitter site, if necessary, without violating
the intent of the Commission’s minor change rule. Adoption of the “30 mile rule” will also help
ensure that broadcasters spectrum allocations are maintained in a manner that allows for the
greatest utilization of the spectrum band.
20 Id. at 13844, ¶¶ 32-33.
21 Id. at 13845-13846, ¶¶ 37-39.
11
5. The Commission Should Obtain Actual Vertical Radiation Patterns for All Low Power
Television Stations to Maximize Use of Broadcasters Spectrum.22
Harris agrees with the Commission that the use of actual vertical patterns would be a
more accurate predictor of vertical radiation patterns. If you use something other than the actual
pattern of the antenna (i.e., the current estimated model) it could impact the amount of coverage
prediction. The use of actual vertical patterns would be much more accurate. If adopted Harris
would support the framework proposed by the Commission for collecting proposed LPTV
facilities actual vertical radiation patterns and allowing existing stations to voluntarily submit
minor change applications to provide actual vertical radiation patterns. However, to obtain the
full benefits of actual vertical radiation patterns and maximize the utilization of broadcasters
existing spectrum allocations Harris would encourage the Commission to dedicate the resources
to obtain all existing LPTV stations actual antenna vertical radiation patterns. Prior to
reallocating or repacking any of broadcasters’ current spectrum allocations the Commission
should make all efforts to facilitate the maximum utilization of broadcaster’s spectrum. The
Commission could do this by engaging in an effort to collect existing stations actual vertical
radiation patters as part of the LPTV digital transition process. For stations that have already
filed for digital flash cut and digital companion channels the Commission could require those
stations submit a minor change application. For stations that have yet to start the digital
transition process the information could be collected as part of LPTV stations’ digital flash cut or
digital companion channel application process.
22 Id. at 13846-13848, ¶¶ 40-43.
12
6. The Commission Should Maintain Full Power Emission Masks for Low-Power
Television Stations to Prevent Interference. 23
The use of full-power emission mask should be maintained by LPTV stations.
Maintaining full-power emissions masks for LPTV stations will be critical to prevent
interference where multiple low power stations are placed against high power stations spectrum
allocations. Utilizing full-power emissions masks in the broadcast spectrum is crucial to
facilitate proper spectrum planning. Without requiring adherence to full-power emissions masks
the Commission increases the likelihood of creating adjacent channel interference.
VI. CONCLUSION.
For the foregoing reasons, Harris recommends an out of core LPDTV transition date of
December 31, 2011 and a final LPDTV transition date of December 31, 2012. However, Harris
would support a final LPDTV transition date in 2013 should the Commission determine, based
on input from the LPTV community, that such a date is more appropriate. Broadcasters’ ability
to serve one-to-many is unique across all communications services and the hyper-local benefits
provided by LPTV and full-power broadcasters cannot be overlooked. Mandating LPTV stations
to convert to digital operations will provide additional spectral efficiencies in the broadcast
spectrum band, offer innovative business opportunities to LPTV stations, and provide new public
interest benefits to viewers. Harris looks forward to working with the LPTV community to
facilitate their transition to digital broadcasting.
23 Id. at 13848, ¶ 44.
13
Respectfully submitted,
Harris Corporation
600 Maryland Avenue, S.W.
Suite 850E
Washington, D.C. 20024
(202) 729-3702
_______/s/________________
Jay C. Adrick
Vice President, Broadcast Technology
Broadcast Communications Division, Harris Corporation
Rich Redmond
Vice President, Product Management and Strategy for Transmissions Systems
Broadcast Communications Division, Harris Corporation
Evan S. Morris, Esq.
Counsel, Government Relations
Harris Corporation
December 17, 2010