Pappas Telecasting Companies Submits Comments Regarding Federal Communications Commis

[Gregg Lengling]

Urges Adoption of Four Interference Standards by FCC to Ensure Adequate
         Over-the-Air Reception of Digital Signals for Protection of
                        Tens of Millions of Consumers

    VISALIA, Calif., July 23 /PRNewswire/ -- Pappas Telecasting Companies, the
largest privately-held, commercial television broadcast group in the United
States, yesterday filed Comments in response to the Federal Communications
Commission's ("FCC") March 24, 2003 Notice of Inquiry entitled "Interference
Immunity Performance Specifications for Radio Receivers, Review of the
Commission's Rules and Policies Affecting the Conversion to Digital
Television."  In the Notice of Inquiry, the FCC asked for public comment on
the potential benefits of adopting television receiver interference immunity
performance specifications for digital television sets.
    In its Comments, Pappas urges the FCC:

     -- To apply regulatory parity to cable interoperability and over-the-air
        reception for digital television sets, thus ensuring that cable
        viewers and over-the-air viewers are afforded the same protection and
        certainty when purchasing DTV receivers.   In this regard, Pappas
        notes that the Memorandum of Understanding on Cable Interoperability
        currently before the Commission provides clear precedent for the
        adoption by the Commission and the subsequent incorporation in the
        Commission's Rules of the minimum performance standards being
        developed by consensus among representatives of the broadcast and
        consumer electronics industries under the auspices of the Advanced
        Television Systems Committee ("ATSC");

     -- To give substantive effect to the Commission's mandate in the DTV
        Tuner Order regarding over-the-air reception of digital television
        signals by adopting the "Recommended Practices" currently in
        development within ATSC and incorporating them in the Commission's
        Rules alongside the technical rules for "plug and play" cable
        interoperability;

     -- To ensure that digital television receivers "adequately" receive
        over-the-air digital signals by meeting minimum standards for the
        following parameters relating to over-the-air reception:

        -- Sensitivity -- the ability to receive signals of low strength
        -- Selectivity -- the ability to isolate and acquire the desired
           signal from all undesired signals that may be present on other
           channels
        -- Dynamic Range -- the highest and lowest signal strength levels that
           can be received
        -- Multipath Impairments -- the fatal loss of reception caused by
           reflected signals arriving at the tuner at slightly different
           times; and

     -- To adopt a strict, uniform labeling requirement for digital television
        sets, allowing consumers to quickly ascertain not only if a set is
        digital cable-ready, but also if it is "Over-the-Air Ready," meeting
        minimum standards for over-the-air reception, thus eliminating
        consumer confusion and facilitating consumer adoption of DTV.

    Peter C. Pappas, Executive Vice President/Government, Regulatory
& Business Affairs for Pappas Telecasting Companies, said, "I believe that the
FCC acted correctly by encouraging the joint efforts of the cable industry and
consumer electronics manufacturers to adopt their 'Plug and Play' standards
for cable interoperability and to submit them for incorporation in the FCC's
rules.  The encouragement of Congress and the FCC forced cable providers and
electronics makers to agree on a single standard, a development that will
ultimately speed the transition to digital television and greatly enhance the
lives of television-viewing consumers.  Clearly, precedent has been
established for the adoption into the rules of a similar joint effort between
our industry and the consumer electronics industry to ensure adequate
over-the-air digital reception for the tens of millions of viewers who receive
their signals exclusively over-the-air.  To do otherwise would imply that
cable interoperability is of greater public interest than over-the-air
reception -- an implication clearly at odds with the Commission's ruling in
the DTV Tuner Order.  Simply put, this is a consumer protection issue of the
highest order.  The Commission should now act in a manner that promotes
consumer adoption of digital television by all consumers, and leaves no
consumer behind during the transition to digital."
    LeBon G. Abercrombie, Senior Executive Vice President/Planning
& Development, commented, "We believe that receiver standards are very
important to the future of over-the-air broadcasting.  It is our fond hope
that the Commission will recognize the danger to over-the-air broadcasters
inherent in the continued confusion and disappointment experienced by
consumers while attempting to receive a DTV picture.  Viewers of over-the-air
digital channels are entitled to the same quality of signal as that provided
to cable television viewers.  It would be a tragedy for consumers to simply
give up on over-the-air reception, frustrated by their inability to adequately
receive DTV channels."
    Dale Kelly, Director of Engineering-Emeritus, said, "As Pappas'
representative to ATSC, I truly believe that we are on the right path toward
preserving a vital service for the American public, that of free, over-the-air
television.  The unprecedented cooperation between our industry and the
consumer electronics industry puts us on the verge of creating a set of
standards that will allow broadcasters to continue serving the 'public
interest, convenience, and necessity,' as is our mandate.  I'm confident that
our partners in this effort will continue to act in good faith to finalize
these standards, and that the FCC will see the wisdom in adopting them into
the rules, for the benefit of all American consumers."

    Company Profile
    Pappas Telecasting Companies is the largest privately-held, commercial
television broadcast group in the United States in terms of U.S. Household
coverage as defined by Nielsen Media Research.  The company owns
20 market-leading Fox, WB, ABC, CBS, UPN and Azteca America affiliates, and
operates three other stations pursuant to local marketing agreements, in all
regions of the United States.  Additionally, Pappas owns 10 on-air digital
channels and operates three others under LMAs.  The company holds construction
permits to build television stations in eight markets, and has an option to
purchase a construction permit for a full-power, five million watt station.
According to statistics from Nielsen, Pappas Telecasting television stations
serve 15% of all U.S. television households.  In addition, the company owns or
operates television stations in markets reaching 32% of U.S. Hispanic
households and 35% of all U.S. Hispanic persons age 2+.  In total, Pappas
owns, operates, or is constructing stations in 24 Designated Market Areas.