Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of
Digital Audio Broadcasting Systems
And Their Impact on the Terrestrial Radio
Broadcast Service.
MM Docket No. 99-325

COMMENTS OF
STATION RESOURCE GROUP

This proceeding centers on the technical details of radio broadcasting's transition from analog to digital transmission. In framing the issues, the Commission has appropriately surfaced public service questions that range from "graceful obsolescence" of current receivers to prospects for new broadcast entrants through digital implementation strategies that would use spectrum not currently assigned for radio broadcasting

Most of these technical and public service issues play out in similar, if not identical, fashion for the nation's commercial and noncommercial radio broadcast sectors. Some issues do not. America's public radio broadcasters operate under a different regulatory, programming, and economic model, with different missions and incentives, than their commercial colleagues. Looking ahead to the technical, economic, and programmatic convergence of now- distinct electronic media, public radio broadcasting will be one of the few arenas reserved for expressly noncommercial, nonprofit public service.

The Station Resource Group (SRG) is a national membership organization of forty-five leading public radio licensees that operate some 170 stations. SRG believes the transition to digital audio broadcasting must be considered within the broader context of delivery paths for public service programming. Ten years ago SRG anticipated a future in which our member licensees would deliver multiple digital broadcast services. Using existing analog broadcast services as a launching pad and programming bed, we saw public stations developing several program streams once digital technology would expand the number of viable channels for broadcast delivery. These programming services would be complemented by national services delivered via other delivery systems.

Events unfolded along a somewhat different path. Today SRG envisions the delivery of multiple services through an array of delivery systems. In a digital broadcast context ancillary or data-type services might be able to be developed side-by-side with the primary broadcast service, but new broadcast program services will require additional broadcast outlets.

In the meantime, the Internet, direct broadcast satellite, and other delivery systems are also territory for the development of an array of public service programming services, both local and non-local in nature. Each of these delivery modes will be characterized by new economies of access to services by users. Each system will evolve with its own set of financial transactions, cost structures, and marketplace position that will, in turn, shape programming services and who has access to them. The regulatory framework that separates noncommercial and commercial broadcast services will not be the same for these other technologies. Different kinds of partnerships will flourish on these delivery systems than exist in the broadcast setting. It is uncertain how public service programming and content will play out as these new media, still in relative infancy, mature.

What is clear, however, is that the broadcast signal will remain the "mothership" of the public service radio infrastructure for years to come. It is the single service that we are assured will be freely accessible to the entire public. For at least the next decade or so, this universal access to a broadcast signal will shape the local and national dimensions of public service radio. Just as important, it will significantly affect the public service expectations we impose upon other communication media.

For these reasons there will continue to be a powerful relationship between the public services fostered over the radio broadcast airwaves and the availability of public service radio programming over all other media. From SRG's perspective, decisions that continue to foster public radio licensees' strength and capacity as broadcasters and that recognize public radio's unique responsibility to provide free and universal access to these services by the citizenry will concomitantly increase the presence of public service programming via new delivery systems.

SRG therefore sees the following issues to be of particular public service importance:

A conversion path from analog to digital that optimizes continuous universal free access by the public to the public radio program services underwritten by taxpayer dollars and public support.

A continued role for public radio (represented in this context by National Public Radio) in the National Radio Systems Committee's recommendation of a system to deliver digital radio and a timetable to adopt that system.

A timetable for conversion to digital radio that recognizes the different financing strategies of public and commercial radio. Public radio capital needs are usually addressed through a combination of government appropriations at the federal and state level and community-based capital campaigns, both of which can require multi-year efforts to achieve. Some licensees will convert transmission systems for a single station. Other licensees will need to convert state-wide systems or systems designed to their reach to rural areas via an extended system of stations, translators and repeaters.

A framework for interference protection that accommodates public radio services on the reserved portion of the FM band, which have been licensed using a protected contour basis, as well as those on the commercial bands, which are licensed under a table of allocations.

The opportunity for public radio to use any spectrum, including spectrum on which it develops services during a conversion period, to strengthen its organizational capacity to deliver public service programming over broadcast and other media.

Most broadly, SRG's concern is that the powerful public service heritage of noncommercial, educational, public service broadcasting carries forward through this transition in technology. The Commission's reservation of noncommercial channels, coupled with investments by the Corporation for Public Broadcasting and the broadcast facilities program of the National Telecommunications and Information Administration has fostered the establishment and growth of several hundred institutions devoted to public service programming. For over three decades, these investments at the national level have been complemented with state and private funds. This is a vital resource to preserve and a powerful platform from which to build still further services for the future.

SRG plans to address these issues in greater detail in its Reply Comments to the Commission. At that point there may have been progress with respect to the viability of the digital transmission systems currently in development that will inform the above and the specific technical issues raised by the Commission in this rulemaking.

Respectfully submitted,

STATION RESOURCE GROUP, INC.

Theresa R. Clifford
Co-Chief Executive Officer

Thomas J. Thomas
Co-Chief Executive Officer

January 24, 2000