Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Authorizing Permissive Use of the “Next Generation” Broadcast Television Standard GN Docket No. 16-142
Comments on the Further Notice of Proposed Rulemaking by
Americans for Tax Reform, Americans for Prosperity, Digital Liberty, Competitive Enterprise Institute, American Commitment, Citizens Against Government Waste, Taxpayer Protection Alliance, Center for Individual Freedom, Institute for Policy Innovation, Pelican Institute, Citizen Outreach, American Business Defense Council, Jersey 1st, James Madison Institute, Innovation Economy Alliance, Mackinac Center for Public Policy, American Legislative Exchange Council, Institute for Liberty, Frontiers of Freedom
Thank you for the opportunity to provide further comments on proposed “Next Generation” Broadcast Television Standards.
We, the undersigned organizations, urge the Federal Communications Commission to reject any adoption mandates for Next Generation Television. With broadcasters operating under the strain of onerous regulation dating from the Second World War, new mandates on them or device manufacturers are not the solution.
Video accessibility is a noble goal, and one that the market has already demanded thanks to the purchasing power of those in need. Next Gen TV is already operating with advanced ATSC 3.0 technologies available for broadcasters and multichannel video programming distributers (cable and satellite) should they choose to use it.
And they have chosen. More than three out of every four Americans have access to ATSC 3.0. It is available in more than 80 markets in parallel to ATSC 1.0 technology delivering digital television. By any reasonable standard, this is a success.
Under the Commission’s original 2017 report and order authorizing ATSC 3.0, broadcasters are allowed use the new standard on a “voluntary, market-driven basis.” The Commission should maintain its voluntary, market-driven adoption policy that has reached the vast majority of Americans, not embrace a mandate just to reach the small minority of markets.
The Commission should take the plight of broadcasters and those in need of accessibility features seriously. The solutions lie in deregulatory efforts, such as those the Commission is successfully pursuing through Delete, Delete, Delete that make their technologies cheaper and more widely available to consumers. They also allow genuine market competition to dictate which technologies survive and thrive. This is precisely what the FCC did in 2017 with the original ATSC 3.0 order. The FCC should stick to this roadmap that has empowered consumer choice.
We thank the FCC for its attention to this matter and urge you reject mandates and maintain market-driven approaches to new technologies.
Sincerely,
Grover Norquist
President
Americans for Tax Reform
Brent Gardner
Chief Government Affairs Officer
Americans for Prosperity
James Erwin
Executive Director
Digital Liberty
Tom Giovannetti
President
Institute for Policy Innovation
Daniel Erspamer
CEO
Pelican Institute
Chuck Muth
President
Citizen Outreach
Phil Kerpen
President
American Commitment
Dick Patten
President
American Business Defense Council
Tom Schatz
President
Citizens Against Government Waste
Deborah Collier
Executive Director
Innovation and Technology Policy Center
Citizens Against Government Waste
David Williams
President
Taxpayer Protection Alliance
Rosemary Becchi
Founder and President
Jersey 1st
Jeff Mazzella
President
Center for Individual Freedom
Edward Longe, PhD
Director of Technology and Innovation
James Madison Institute
Bartlett Cleland
Executive Director
Innovation Economy Alliance
Jessica Melugin
Director of Technology and Innovation
Competitive Enterprise Institute
Jarrett Skorup
Vice President for Marketing and Communications
Mackinac Center for Public Policy
Lisa B. Nelson
Chief Executive Officer
American Legislative Exchange Council
Andrew Langer
President
Institute for Liberty
George Landrith
President
Frontiers of Freedom