Encryption

[nickk]

Our response sent to the FCC:

https://download.silicondust.com/docs/S ... 22-25).pdf

[NatHillIV]

FANTASTIC response Nick! Detailed and complete, and even I could understand it. I think any FCC commissioner could understand it as well.

I took the liberty of stealing this post from the AVS forum. I enjoyed reading them as well as your excellent response.

A couple of new public interest objections to the NAB petition have also been filed:
https://www.fcc.gov/ecfs/search/search- ... 1669608782
https://www.fcc.gov/ecfs/search/search- ... 1143994947

Here's my question. How in the WORLD can ATSC 3.0 ever gain traction when the leading selling ATSC 3.0 gateway manufacturer and the folks in charge of promoting the new standard have reached this point? We all know who the bad guys are here, I just don't understand how they can be that stupid? Makes no sense. Hopefully they come to their senses, but I'm beginning to have my doubts.

I almost wish ATSC 3.0 would just go away. I love the improved picture, but if I can't use a your gateway product, forget about it.

[techpro2004]

So my question is why not release flex 2.0 with a different chip.

[TPeterson]

So my question is why not release flex 2.0 with a different chip.

Because the goal posts would only move again. duh.

[jasonl]

So my question is why not release flex 2.0 with a different chip.

Because there's nothing wrong with the current chip. The primary law that Pearl referenced was designed to target network infrastructure and cell phones, two areas where Huawei and some of the others listed are some of the biggest players in the world. I don't know if Huawei and the others on the list have actually done anything wrong, but the possibility of them doing it is very real. The equipment that runs cell sites would have full access to everything running through it, and it would be very easy to put functions in the firmware/software to allow governments access to calls and data flowing through the equipment. A mere SoC would not have that level of exposure because the CPU doesn't have any kind of understanding of what it is doing, it's just manipulating bits that could be anything and do anything.

[techpro2004]

[removed by moderator]

[gtb]

FANTASTIC response Nick! Detailed and complete, and even I could understand it. I think any FCC commissioner could understand it as well.

Just for the record, it is likely that no commissioner will ever actually read it.

While the FCC Commissioners are the leadership, and make the decisions as to direction and policies and rules, the majority of the technical work and evaluation is done by the nonpartisan career staff (nice people (at least the few handful I have interacted with), and they really really really know their area of responsibilities and the technical details). The staff are the ones responsible for reading and fully understanding what is said, and provide an executive summary of the facts and any impacts of possible actions up the chain of command for decision making. While, from time to time, a commissioner might happen be technically competent, most of the time they are just political animals, who depend on their staff for actual detailed knowledge (I don't recall any commissioner who was able to actually understand RF physics).

[hancox]

Our response sent to the FCC:

https://download.silicondust.com/docs/S ... 22-25).pdf

This should be added to the bottom of the first post - it's basically every detail anyone would need on the subject. Well done.

[decaym]

While the FCC Commissioners are the leadership, and make the decisions as to direction and policies and rules, the majority of the technical work and evaluation is done by the nonpartisan career staff (nice people (at least the few handful I have interacted with), and they really really really know their area of responsibilities and the technical details). The staff are the ones responsible for reading and fully understanding what is said, and provide an executive summary of the facts and any impacts of possible actions up the chain of command for decision making. While, from time to time, a commissioner might happen be technically competent, most of the time they are just political animals, who depend on their staff for actual detailed knowledge (I don't recall any commissioner who was able to actually understand RF physics).

Sadly, I believe you missed a key point. The only people they (the FCC commissioners) are going to listen to are the ones who gave the biggest "donation" to their chief benefactor. To put it another way, do you believe Pearl would have tried this move if we had "President Harris" in office right now?

I'm glad I bought my current device (a FLEX 4K) for the ATSC 1 support, which replaced my CableCard model PRIME when I cut the cord, because I have no faith anymore in ATSC 3 ever working right. It truly appears to be designed to kill broadcast television instead of moving in into the next generation of technology. Beyond the DRM issues, ATSC 3 is encumbered with so many licensing issues that I fear Plex, my primary media management source, will never be able to handle the standard. There is a reason why some TV manufacturers are dropping ATSC 3 tuner support.

[SpiceWare]

To put it another way, do you believe Pearl would have tried this move if we had "President Harris" in office right now?

Considering this DRM fight started long before January 20, 2025 I don't think it matters which party holds the top office.

[Cabal]

To put it another way, do you believe Pearl would have tried this move if we had "President Harris" in office right now?

Yes.

[zippy]

Of all the possible government conspiracies and their importance, one of the top 10 that the government is working on has to be DRM. The new FCC chairman probably doesn't even know what it's all about.

[travisinfla]

July 26, 2025
Federal Communications Commission
445 12th Street SW
Washington, DC 20554
Re: Proceeding No. 16-142 – Permissive Use of the “Next Generation” Broadcast Television Standard (ATSC 3.0)
To Whom It May Concern:
As both a Florida resident and a trial attorney, I write to express serious concern over the encryption of local broadcast signals under the ATSC 3.0 “NextGen TV” standard — and its alarming implications for public safety and consumer access.
We are now deep into hurricane season. When power, internet, and cable fail — as they routinely do in natural disasters — over-the-air television is not a luxury. It is a lifeline. Yet major broadcasters affiliated with Pearl TV are encrypting their ATSC 3.0 signals, denying viewers access to emergency updates, local weather, and news. In some markets, ATSC 1.0 simulcasts have already been discontinued, making encryption the default.
Pearl TV, the industry group behind this encryption push and the A3SA DRM scheme, claims it is about:
• Preventing piracy
• Protecting retransmission rights
• Ensuring content “security”
But in practice:
• They are locking out legitimate users who rely on open home networks and gateway devices like HDHomeRun.
• They are blocking open-source and enthusiast platforms, even those compliant with ATSC standards.
• They are prioritizing content control over accessibility — at the expense of public safety.

This is not theoretical. I’ve seen it firsthand. Many residents can no longer receive stations they previously accessed for free — not because of signal loss, but because of DRM-enforced digital lockdowns, with no consumer transparency or recourse.
I urge the Commission to take swift and meaningful action:
1. Prohibit encryption of core local broadcast content — including news, weather, and EAS alerts — unless a fully functional, unencrypted ATSC 1.0 simulcast remains available.
2. Investigate the A3SA DRM structure, including its chilling effect on innovation, accessibility, and public trust.
3. Reaffirm the public’s right to free, over-the-air local broadcasting, especially during declared emergencies.
Here in the Tampa market, major broadcasters are transmitting only encrypted ATSC 3.0 signals — and have removed their ATSC 1.0 counterparts entirely. As a result, many viewers now have no access at all to local channels unless they purchase from a short list of DRM-approved devices — which excludes most open-market receivers and often requires Chinese-made televisions just to receive U.S. emergency alerts.
That is not just bad policy. It is a public safety failure. Consumers are being locked out of local news and alerts not due to distance or poor reception, but because of encryption and licensing decisions made behind closed doors.
Thank you for your time and attention to this urgent matter.


Proceeding(s):
16-142
Confirmation #:
2025072703476589
Submitted:
Jul 26, 2025 9:31:13 PM
Status:
RECEIVED
Name(s) of Filer(s)
[removed by moderator]
Law Firm(s)
Attorney/Author/Submitter Name(s)
[removed by moderator]
Primary Contact Email
[removed by moderator]
Type of Filing
COMMENT
File Number
Report Number
Bureau ID Number
Address of
Filer
Address
[removed by moderator]
Email Confirmation
Yes

[kyl416]

In some markets, ATSC 1.0 simulcasts have already been discontinued, making encryption the default
...
Here in the Tampa market, major broadcasters are transmitting only encrypted ATSC 3.0 signals — and have removed their ATSC 1.0 counterparts entirely.

You might want to resubmit that as that isn't true at all, there is no market where ATSC 1.0 simulcasts have been discontinued. That might cause them to dismiss your comments and ignore the rest of your important points about not being able to get information during emergencies:
8.1 WFLA (NBC) is still available on RF 9, using the same ATSC 1.0 signal they've had since 2020, which has a bigger coverage area than their pre-repack RF 7 signal. It is also the spectrum sharing host of their sister station 38.1 WTTW (CW) and 38.2 Cozi.
10.1 WTSP (CBS) is still available on RF 10, using the same ATSC 1.0 signal they've had since 2011
13.1 WTVT (FOX) is still available on RF 12, using the same ATSC 1.0 signal they've had since 2008
28.1 WFTS (ABC) is still available on RF 17, using the same ATSC 1.0 signal they've had since 2020, which also has a bigger coverage area than their pre-repack RF 29 signal. Last summer they had some transmitter issues that forced them to temporarily reduce power while repairs were made, but those were resolved in October.

And as for the ATSC 3.0 host WMOR:
32.1 WMOR is also on WFTS's RF 17 ATSC 1.0 signal
32.2 MeTV moved to WTSP's RF 10 ATSC 1.0 signal
32.3 Estrella moved to WTVT's RF 12 ATSC 1.0 signal

If you are missing the ATSC 1.0 versions of those .1 channels, you might have a NextGen TV that hides ATSC 1.0 duplicates by default and you have to manually enable them in the channel list. The rest of the 8.x, 10.x, 13.x, 28.x and 32.x subchannels are ATSC 1.0 only, along with the rest of Tampa's stations that aren't participating in ATSC 3.0.

[ronj]

Our response sent to the FCC:

https://download.silicondust.com/docs/S ... 22-25).pdf

Thanks for sharing this Nick. It's very well written and covers the important points. We can certainly see in this filing the "update" we've all been looking for. I can appreciate that you were sitting on this to try to nurse the A3SA relationship along; but now that your hand is forced, we can finally infer the details without any NDA points being broken. Please keep up the fight, and again, thank you.

Honestly, it seems only the FCC can correct matters at this point!

The logical best solution from the consumer point of view is (1) remove DRM, (2) remove "broadcast flag" and other restrictions, and (3) then roll it out asap and finally (4) when market saturation occurs, turn off 1.0. We could have been close to point 4 by now were it not for the apparent greed that has impeded progress to a much better standard.