Mr. Krauss:

I am disappointed and, quite frankly, alarmed with your position in your "Capital Currents" article in CED June 2006 ("Should consumer councils regulate tech standards?").

Your position is typical of the rank and file response that has been plaguing the customer service departments of this industry for decades.

First, regardless of whether the cable operator generates a signal or just "passes it on" to the viewer, the operator is ultimately responsible for the quality of the product that they are delivering directly to their customers, period. If I buy a pair of socks from a department store and I am not satisfied with the quality or workmanship of the socks, I don't expect the department store to blame the factory workers overseas who may have manufactured the socks, or the company who packed the socks in boxes, or the company who shipped the boxes to the department store. I expect the department store to remedy the purchase and take actions with their suppliers to prevent such products from being sold again, at least through their store. The point of sale, in this case, the cable operator, must accept ultimate responsibility for the quality of the products they sell, whether the product is video, high-speed data or VoIP.

Second, your reference to the various technical quality deficiencies being out of the operator's control is incorrect and insulting. The particular artifacts that you discuss–pixelization; audio/video synchronization; freeze frames; and to a great extent picture quality (although this is a nefarious and subjective artifact)–are directly influenced by the amount of compression applied to each service within the operator's plant. It is no secret that the tremendous growth of digital tier services and the increasing pressure to simulcast most of the core analog signals as digital services are making these artifacts much more apparent to the typical viewer.

The largest culprits are the cable operators who are compressing the simulcast and other digital services at 3 Mbps or less for standard definition signals (let's not even talk about over-compression of the HD signals). It is clear that the video artifacts described will be apparent when the bit-rates are reduced so much. That is the reason that VOD streams are (defacto) limited to 3.75 Mbps.

When these digital artifacts are observed, ever increasingly, on services that are delivered to the operator as an analog feed (including basic services and off-air SD signals), it is grossly unfair to shift the blame off of the operators. In fact, perhaps the FCC should adopt an addendum to Section 76.640 that specifies a minimum bit rate for SD and HD services delivered to digital set terminals (such as no less than 3.5 Mbps for SD and no less than 10 Mbps for HD services), since operators are unlikely to accept these limits independently.

To paraphrase your own closing statement: There you have it–another clueless policy wonk trying to meddle in technology.

Robert Goldfarb

NBC Universal

Director, Affiliate Projects

Jeff Krauss' response:

Thanks for your opinions, Mr. Goldfarb. My column was about technically incompetent Citizens Advisory Councils, not about the picture quality problems of digital TV broadcast stations. You've not only failed to understand the point of the column, but have made a number of unsubstantiated and insulting claims, which I will now address.

I've got some personal experience here. Your owned and operated local affiliate, WRC in Washington, D.C., had severe lip synch problems. It took them two years from the time I first complained to NBC executives to fix the lip synch problems. It was so bad that I just could not stand to watch the local news on WRC, so I watched it on your competitors' stations. And by the way, contrary to your claim, lip synch problems are not typically "directly influenced by the amount of compression"; they are largely due to poor attention to timing issues during production and post production.

You allege that cable TV operators are the "largest culprit" in poor picture quality on broadcast TV stations. But where's the evidence? TV stations are carried either under FCC Must Carry regulations or under Retransmission Consent contracts. In either case, broadcasters have the right to submit formal written complaints in case of degraded signal quality, either to the FCC or in a breach of contract lawsuit. To my knowledge, no formal written complaints have been filed anywhere. Where's the beef?

You say that a department store would stand behind the socks it sells, even if defective. In fact, the store would cancel the purchase contract and buy socks from a different supplier. But under FCC regulations, a cable operator doesn't have that choice, and must continue to carry degraded signals supplied by broadcasters.

In digital simulcast cable systems, off-air analog broadcast signals are converted to digital at the cable headend. For the most part, local broadcasters love this because it makes their analog feeds look much better. No broadcaster has complained, at least not to the FCC.

I'm not aware of any cable operator that re-compresses a digital broadcast signal that was broadcast using MPEG-2 compression. They pass it through. Of course, DirecTV, EchoStar and the AT&T IPTV service do recompress the MPEG-2 digital broadcast signals, because they deliver MPEG-4 (H.264) signals.

I have, however, heard about local broadcasters that cannot afford high-quality MPEG-2 encoders, so they buy cheap ones that make the pictures look bad even at 19.4 Mbps!

You claim that cable operators are re-encoding off-air broadcasts at 3 Mbps rather than passing them through at 3.75 Mbps. You claim that there is a significant difference in picture quality between a standard definition channel coded at 3 Mbps compared to 3.75 Mbps. Where's your evidence?

You've made a lot of insulting claims. You have even failed to provide any evidence to support your claims. So, where's the beef? But don't feel bad. I'm sure you are well-qualified to serve on any number of Citizens Advisory Councils.