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The FCC responds to my ATSC 3 encryption complaint – they want to hear from you (lon.tv)
403 points by tech234a on July 13, 2023 | hide | past | favorite | 178 comments



OTA TV is a matter of public interest.

The electromagnetic spectrum is OURS collectively. Public broadcast licenses are rooted in the idea of a well informed public is good for everyone.

Encryption is just a move to monetize what is otherwise a public resource.

I object to that and will be making a comment to that effect.

Thanks for the heads up.


Public spectrums are public goods. They're indirectly funded by our tax dollars. Putting DRM encryption on it is similar to a private company putting a gate on a national park and charging people to go into the park.


> Putting DRM encryption on it is similar to a private company putting a gate on a national park and charging people to go into the park.

Sadly not all that far from reality given how Booz Allen Hamilton has profited off of running recreation.gov. https://www.thebignewsletter.com/p/why-is-booz-allen-renting...


Funny, I see you replied the same thing! It's absolutely absurd, ludicrous, and asinine that we have to go through a private defense contractor to access PUBLIC SPACES. It makes me livid.


This is bad, so is not getting critical information without relying on a private social media company! I felt as you do when I realized my county was using Twitter for emergency alerts during a crisis. I happen not to have an account, but was fortunate to get the information from another person nearby.


To belabor the metaphor, it's like a private company putting a gate on a national park and charging people to go into the park, but also no maintenance is ever performed and there is no financial overhead to keep the park operational. It's like being charged to breathe.


You mean like Booz Allen Hamilton (CIA's private IT department) running Recreation.gov, which you MUST USE even if you show up to a park that allows reservations on the spot (they tell YOU to break out YOUR phone and go to recreation.gov), and which you CANNOT USE IF YOU DON'T WANT YOUR COMPUTER TO CONNECT TO GOOGLE'S SERVERS a la GOOGLE TRACKERS???


>The electromagnetic spectrum is OURS

But the content being played over it likely isn't.


The point is that we as a society collectively get to set the rules. For example, if you want to use OUR spectrum to play your content, that content must be accessible to anyone who has a standard-conforming implementation.


And part of that standard can be that the implementation must secure protected content from being copied by people.


DRM does not prevent copying. Everything that is broadcast or streamed is copiable. DRM has never worked.


Yeah I don't understand why it's not clear for everyone now that the only people benefiting from DRM are DRM makers. It never actually protected anything. The most outrageous example is HDCP, for which I believe one of the master key has been leaked and it's publically known (so the protection it might have offered is void), but customers still pay the HDCP tax to Intel on every device that must support it to work with other devices...


>but customers still pay the HDCP tax to Intel on every device that must support it to work with other devices...

Please do some critical thinking. There have been 3 new versions of HDCP since that leak and they have all broken backwards compatiblity. Do you think they still use that leaked key? Or do you think as they have improved the security of HDCP they have replaced the key?

If you went and looked at the security of Linux from over 10 years ago you would find some bad security vulnerabilities which have now been since patched. Similarly the security of HDCP is getting better over time and newer content is requiring the higher security that is available.


Breaking backward compatibility would be another issue if devices cannot be upgraded, some kind of planned obsolescence where you need to throw away your perfectly working device for no good reasons.

How does that work in practice though? Does it mean I cannot read recent blu-rays with older blu-ray players with the old key?


>Does it mean I cannot read recent blu-rays with older blu-ray players with the old key?

Yes, newer blurays may require a new player or a system update for your player in order to play if they require a newer security baseline than what you have.

>planned obsolescence

Intel did not plan for older HDCP to be broken.


> Intel did not plan for older HDCP to be broken.

What's the maximum time a DRM system worked before being completely broken? 2 years? 3 years? It'd be surprising that they did not anticipate that. But then again, I'm not sure why they would really care, they don't really make movies as far as I know.


>DRM does not prevent copying

Are you trying to be pedantic? Technically the MMU prevents the copying. That is just an implementation detail. To content creators the distinction isn't important.

>DRM has never worked.

The barriers have seriously increased over time. Now you have to dump or buy a L1 key to decrypt content. Devices store the key securely which means that you either need to find a hardware vulnerability to leak the key or have a man on the inside to steal keyboxes. If you get caught your key / device will get blacklisted. With each year the price to break the DRM will increase.


If we give that permission, sure. I don't see why we should do so for OTA.


I want to live in that fantasy world you live in.

Money makes the rules, the mainstream media pushes it out into the public and politicians set them in stone. The public has no say in this. At all. Any consent you perceive is either pushed hard for by the media, or is fabricated by pushing the screaming people into everyone else heads. Please stop being naive.

The only reason, why the groups in power even care about creating the illusion of massive public consent about anything, is because that's what they need to do to make sure their respective parties get re-elected.


It's not as though the encryption only kicks in when copyrighted shows/movies are on the screen; it covers the ad breaks, the breaking news/emergency alert interruptions, and everyone else on the channel too.


Actually it is. Information belongs to everyone.


The electromagnetic spectrum is used by many private companies, like carriers. Would you want to disband that as well, and make it free for everyone to use?

(I'm a huge proponent that all infrastructure should be public, but I still think that carrier usage should be paid by the users, at least beyond some minimal usage)


Apples and oranges.

Broadcasting is a "one-to-many" operation, where the target "many" is indeed the public. Concern about public interest is relevant.

Carriers create a "one-to-one" service. Users of the service are not being addressed in a public manner except in an infrastructural way (broadcast addresses in a content-oriented as well as infrastructural method). Concern about public interest can only be limited to "can any member of the public obtain this service?"


Exactly. It's also a very finite resource, and while some of the spectrum is allocated for private use, it is the FCC's job to protect that which is for public interest as well. Broadcast television is the only kind of television some people can receive, and it is in our collective interest to keep that open and accessible.


One argument that the pro-encryption camp is using is that it provides Integrity to TV. Encryption provides an important quality, such that it prevents someone from interfering with a broadcast and broadcasting their own, psuedo authoritative, pirate signal.

This can also be achieved with signing. These arguments are spurious. Please comment to oppose encryption.


The ATSC 3.0 Security Authority [1] already describes signing and encryption as separate features.

[1]: https://a3sa.com/wp-content/uploads/2022/03/Security-Systems...


You can't reasonably sign broadcast. Encryption is done at 188B packets to be robust to packet loss.

That being said that argument is still BS because the attacker can just send a non encrypted signal.


Why couldn’t a 188B packet stream be signed? If it can be encrypted, it can be signed easier.


188 byte Transport Streams are allowed in ATSC 3.0. but it's a legacy mode. All ATSC 3.0 stations on the air use UDP over IP packets.


My intuition is that if it can be encrypted, it can definitely be signed. Is that wrong?


Fine. Let's agree to that -- encrypt everything and publish all of the decryption keys. Make a huge fine to encrypt anything with a non-published decryption key.


That sounds like something you could lawyer out of or wait until the enforcement authority focuses on something else. Encryption here only benefits the content owner and comes at the cost of the user. There's no value here in adding encryption.


What does that accomplish?


It reveals how silly the argument of parent commenter is.


When was the last signal intrusion? LMAO


35 years ago: https://en.wikipedia.org/wiki/Max_Headroom_signal_hijacking

So yeah, it is not much of a pressing issue.


Hasn't happened since digital TV. It's more likely that a broadcasting station is hacked and the stream is hijacked there rather than hijacked using a rogue transmitter.


This is going to kill archivists. There are so many fascinating YouTube videos of things like the 1989 sf earthquake during the World Series [1] or tornados [2] that just so happened to be on someone’s VHS or TiVo. That James Taylor music in the first clip would require encryption (as would the fact that it’s the World Series), and the second clip would be encrypted because there’s no sense in complicating things by ever turning it off.

Huge loss if this happens. Looks like it probably will, though.

[1]: https://youtu.be/Z8ExMR0c0aM

[2]: https://youtu.be/FagzNHuI5JI


I'd be more ok with it, honestly, if public interest (news, local-origination programming, etc) content was illegal to encrypt, and it was only entertainment programming that they were allowed to encrypt. From what I'm understanding, though, the stations that have switched on encryption have done it wholesale, 24/7. To me, that is unacceptable.

I hope this is quickly cracked and spread far and wide. Fuck these grifter station groups and networks.


To clear up some confusion in this thread: According to the ATSC 3.0 Security Authority [1], the ATSC 3.0 standard already allows for signal signing without the Widevine DRM encryption. Signing is already required, but encryption is optional [2].

Encryption is not necessary for authentication.

[1]: https://a3sa.com/

[2]: https://a3sa.com/wp-content/uploads/2022/03/Security-Systems...


For anyone using an HDHomeRun or any other OTA capture card, this effectively kills the ability to watch and record content using Plex/Jellyfin/Emby/etc.

Only "certified" devices are allowed access to the encryption keys. Only closed, fully locked down black box recording systems will ever be "certified". Don't have a Windows machine with a fully verified HDCP chain? Sorry, you can no longer watch OTA TV.


It’s funny how this is actually worse than cable. I still have and use the old HDHomeRun Prime (no longer made), which has a cablecard inserted into it (which your cable company is legally required to provide, or at least it used to be?) and it emits unencrypted video on every channel, except for I believe “premium” channels which is basically only HBO.


My local cable company gets around this by strategically pricing everyone towards using their new cable boxes which are essentially digital TV over DOCSIS internet. The prices for the IP TV plans (which they still call "cable") are less than $100 per month, but I was quoted over $300 per month for a traditional cable plan that could use a CableCard.


Yeah these sorts of practices seem to be everywhere. I have Comcast Business (for internet) at home, and even for that, they want you to use their provided cable modem + "security gateway". I told them I wanted to use my own modem and router, and they told me that would cost more! I can only assume they gather data about your home network and sell it to third parties, and don't want to lose that revenue stream. And I assume that device also broadcasts that "xfinity" public WiFi network as well.

I of course think the practice is disgusting regardless, but it surprised me that they'd do it on their business-class product too. Would be really nice to see some regulation aimed at prohibiting this sort of thing.

(To be fair, I recently called Optimum for cable internet setup at another address, and told them I wanted to use my own equipment, and they still gave me the same price. At least some companies aren't engaging in this bullshit. They did try to upsell me to a much faster package than I wanted, and tried to get me to add their cellular product, but I guess that sort of thing is a normal practice anywhere, and at least the sales rep wasn't pushy and it was easy to say no.)


We had this situation in Germany as well. The providers argued that their routers/etc. are part of their network and the user network starts behind that. If the user wants to use their own router etc they can connect it behind the provided one yadayadayada. In the end their lost the argument. The providers need to accept any router and have to hand out the connection credentials (the provided boxes came with backed in credentials) so users can connect with their own hardware. But most providers will now refuse to give support in case you run your own router. That’s all for internet though. Don‘t know how cable is handled nowadays.

But this reminds me of the day a nice telecom call center person wanted me to get their router. The argument he gave me was: „with our router we have access and can automatically fix update and optimize the router for you“. My answer was down the line of: „that’s precisely what I don‘t want“. A few years later a huge Telekom blackout happened across west Germany or so. Apparently the error was a faulty update which misconfigured the user credentials. All boxes went offline for the users (I guess the service ports where still available) Classic Murphy.


Comcast also has deployed this other trick where you call them for support, they'll just say they can't do anything if you use your own modem. It's malicious incompetence.


Oh for business users they'll offer to send someone with the threat that if it's anything on the premises or it is an intermittent issue resolved by the time they get there then they'll tack a $100 charge on.

EDIT: I've written before about an issue caused by a miswritten provisioning file on their end that involved eventually writing their executives to get it resolved: https://news.ycombinator.com/item?id=35595663


With Comcast, you can disable the public Wi-Fi on your end (just log in) and you can also ask them to put your cable modem into "bridge mode", to use with your own router, but to get static IPs you need your router in router mode and it will get a dynamic IP and the static IPs.

I was sick of the way that Comcast prices creep up so I switched away anyway.


The modem they currently use actually reenables the Xfinity hotspot when I turn bridge mode on. It’s infuriating.


Yikes. I wonder if you can get it replaced with the business gateway without wifi.


Open case, remove wifi chipset or at least the antennas?


Maybe easier to wrap it in foil/put it inside a metal box/trash can? Warranty/service terms: intact.


> I can only assume they gather data about your home network and sell it to third parties, and don't want to lose that revenue stream

Nah. You are just paying for the privilege of breaking their unified management platform.

As an ISP "power users" break the uniformity that leads to economies of scale in management, and often over-estimate their own abilities leading to increased support costs.


DOCSIS in practice does not guarantee interoperability. Each ISP has its own supported modems list. Deviating from their blessed hardware means they will not send the special ISP specific firmware that’s bug compatible with their setup. Or they might refuse to activate it. Of course any issues are immediately blamed on customer owned CPE.

Because of this the real point of demarcation is the approved modem/gateway’s Ethernet port not the coaxial junction box.


So I work mostly with fiber, which is a bit different than DOCSIS in terms of demarcation and interoperability, but at least with fiber, these economies of scale in management can also be realized without having this unified management platform, although it can indeed impact the revenue stream. I work at an ISP where LAN management is an add-on option (that most users take), and so we maintain this uniformity :

- unmanaged clients ("power users") get an ONT that is very easy to monitor remotely, and we never had a situation where they were unable to setup a DHCP client

- managed clients pay a bit more and get an AP/router that they cannot directly configure, except for things like the wifi password and some NAT mappings.

It would not make sense to price it this way if we were selling data about their home network, and I suppose that's part of the reason other big ISPs here prohibit their users from connecting to the ONT directly.


How much does it cost to say "sorry, we cannot help you because you're using your own router" like Comcast support does? I can't imagine how that would cost more than them supporting their own router.


100% this.


Comcast and Optimum both offer low-cost cell phone networks. They resell service from the big three, but largely rely on WiFi calling. Phones automatically connect to the default modem/router combos.


> Comcast and Optimum both offer low-cost cell phone networks.

Plans that run on other networks (in Comcast's case it's Verizon).


Of course, the big strategy here is to try and get to a point where they can free up a whole lot more spectrum on the cables for internet and not have to densify CMTS a whole bunch.

(Of course, having spyware cable boxes helps with other revenue streams, too)


I thought I read somewhere that the provision that required cablecard specifically access is no longer in effect. They still must provide access, but what that is seems murkier than ever: https://www.nexttv.com/news/fcc-abandons-cablecard-navigatio...


That’s probably true. But I guess if you already have a cablecard, it’s not going to suddenly stop working. Mine is still working just fine.


Comcast "forced" me off of mine by upping my rate to $180/mo for the cheapest cable-only package when there were contract deals available with internet and more channels for $110/mo.

No contract rates available without turning in the cablecard. Switched symmetric GB fiber provider for $65/mo and pay for streaming TV during the NHL season.


> Switched symmetric GB fiber provider for $65/mo and pay for streaming TV during the NHL season.

Good, everyone who is able to switch away from cable should switch away from cable.

Signed, a time warner spectrum hostage


Cable television (and, to some extent "television" in general) has the stink of a dying industry all over it. Of course, "cable TV" during my lifetime has often been a type of business run, in many areas, as a sort of personal piggy-bank / for "rents" extraction, and not in any kind of public or consumer oriented manner at all [1]. But, really, at this point, cable is just milking as much as it can out of the generations that still are very dependent on it as it sinks into oblivion.

Cable wasn't exactly great, well, ever ... but, even through perhaps about 2015, it was at least somewhat watchable. In the past few years, I've had the ... (mis)fortune of being in a household with cable (after years of only even being able to watch when I went to someone else's home). Commercials were bad enough 10 years ago. Now, they hardly show any scenes in shows / movies before there is a commercial. Movies with runtimes of 1.5 hours, will run for 2.75 hours on TV. This can be on "broadcast" stations as well as cable-only. The barrage of ads only drops off after about 10pm.

Even worse, they now have very "dynamic" time slot ads, 5s ads interspersed with 15s ads etc... Plus, the ads themselves often enough feel made for the "TikTok" generation.

Just an absolute mess.

I'll never look back at TV with any deep nostalgia, though there is a bit of nostalgia for some aspects. It was never a highlight of life - like Seinfeld quips in one of his stand-ups: "... everyone on TV is doing something better than what you are doing ... you never see someone on TV sliding off the couch with potato chip crumbs all over their face ..." (something to that effect). But, it's really "jumped the shark", these days.

[1] https://www.nytimes.com/2021/09/30/obituaries/john-j-rigas-d... (I can't quickly find some of the material I was looking for - practices of companies in the 90s, fighting any kind of innovation while fees exploded etc. ... There were noteworthy laws enacted, incl. 1992 cable-related act and the notorious 1996 telco act ... lots of bad anti tech anti consumer crap mixed in all of it, and lots of private corralling of money, in any case)


Cable has definitely gone downhill. I remember we got our first cable box (a fairly large black metal box with a channel selector dial on it) in 1985 or so, and it was actually pretty good. Not that many channels, but as I remember it (I was very young, so it's a bit fuzzy), most channels had no commercials at all, even between programs.

I haven't had cable since 2005 or so, when I canceled it. I think I got cable TV just because I assumed that was just what I was supposed to do, since I'd had it for nearly all my life. But after a year or so of living on my own, I realized I rarely watched it, and got rid of it. Haven't looked back, and I aggressively avoid being exposed advertising as much as possible. When I'm visiting family the TV is usually on in the background (with some cable channel on), and it's astonishing to me how little actual programming is there these days. Feels like mostly ads, and, as you point out, normal-length movies have their time slots expanded by at least 50% to account for ads. Gross.


I wish I could switch. It's ridiculous that in San Francisco my only realistic choice is Comcast. No fiber (despite being one block from the 3rd Street fiber trunk), and MonkeyBrains won't guarantee the speeds I want.

Either way, kudos to you for voting with your wallet here. I wish we could all do that in every situation.

I'm a little bit surprised they didn't offer you a better rate when you called to cancel. A friend of mine has been riding a 1-year signup promotion for a good 5+ years now; every year when they're about to switch him to regular pricing, he calls them and tells them he's unhappy with the new rate and will cancel. But in your case, I guess Comcast's profits are solid enough (and they know most people don't have an alternative) that they can be choosy about their customers.


You can thank your local corrupt politicians for maintaining Comcast's monopoly in your area. Comcast pays good money to have those votes, money it takes from you and your neighbors.


The capital expenditure to build fiber is also quite large, Sonic.net, Astound and others have spent money to build fiber in parts of California, but maintaining and using existing infrastructure is just cheaper than building new, especially if trenching is involved.


Up until 2 years ago, I used to use an HDHomeRun Prime with a cablecard for just basic cable (only a dozen or so channels) because I had terrible antenna reception in my apartment (I was only about 2 or 3 miles from the transmitter, but with a hill in-between). It cost me something like $60/month for just the basic cable (from RCN). Fortunately I've now moved and have great OTA reception on ATSC 1.0 so I was able to ditch the expensive cable service.

I really think the basic broadcast channels should be free to watch on whatever medium you choose. These should be free on clear QAM cable without needing a cable card.


When I looked into this, it seemed the "premium" channel restriction (formally called "Copy Control Information") was something that was done client-side in software, because Windows Media Center was one of the only software able to play copy-once content. Have people tried cracking the drm scheme used?


Unfortunately not always the case in NYC at least. Verizon (FIOS) had basically every channel unencrypted. When I had to switch to Spectrum I discovered they encrypt basically every channel save for ones available over OTA.


> Only "certified" devices are allowed access to the encryption keys. Only closed, fully locked down black box recording systems will ever be "certified".

I really really hope this doesn't go through, but if it does, I can't wait for the day when these keys are inevitably leaked.


These modern systems tend to have a seperate key for every consumer. Ie. every single device ever produced has a seperate key.

If any device is cracked/leaked, they find out which one is cracked and send out new keys for every other device except the one that was cracked.

Through clever use of key hierarchies, you only need to send out a small number of new keys over the air to make sure every legit user gets a new one, but your leaked key doesn't get replaced so anyone using that gets locked out.

There is no master key to leak - if you leak one key, you only lock out one device. All other keys are ephemeral.


Is that what they do with satellite TV? Not knowing anything, I'd think they'd need a unique connection for every user, like Internet streaming, to have unique keys.


Encrypt video broadcast with a master key pair. Then just continually broadcast the decryption key, encrypted for every customer individually, alongside. If there's a mysterious "activation" period after turning on the device initially, it's probably something like that. Rotate the master every so often to kick off users.


> Then just continually broadcast the decryption key, encrypted for every customer individually, alongside.

Wouldn't broadcasting a unique stream for each client increase bandwidth?


You can do neat things with key hierarchies to avoid this.

Group all your customers into leaves of a binary tree. 100 million customers is a tree ~27 levels deep.

Issue every customer a private key on a smartcard. Also generate keys for each node in the tree, and have the smartcard also preloaded with the keys from that customer to the root. (ie. 26 extra keys on the card - easy to store).

Now, whenever a customer leaks their key, you cut that customer out of the tree and regenerate all nodes up to the root. You transmit over the air, every few minutes, all the modified keys. Each new key is transmitted multiple times encrypted with the children of that node.

Now every legit keyholder either has the master key, or some set of keys that can decrypt the master key (as a combination of the keys on the card and the keys transmitted over the air). Any banned cardholders do not.

Using this method, even banning hundreds of keys, there won't be more than tens of thousands of keys that need to be transmitted over the air, even though you might have 100 million cardholders. That's very transmittable every few minutes, meaning that honest cardholders won't have to wait more than a few minutes for service, even if their tree-neighbour is a hax0r.


It would, but if you are only transmitting keys, and only every couple hours, it needn't be much bandwidth.


This has already happened unfortunately. In my area (Boston) nearly all of the ATSC 3.0 channels were encrypted the day they went on the air (CBS, ABC, NBC). As a result, they are unwatchable. We need to petition the FCC to force broadcasters to remove the encryption.


The problem with cable card companies is spectrum is now sun setting all cable cards due to the FCC no longer mandating their existence for consumers.


> Sorry, you can no longer watch OTA TV.

And nothing of value was lost.


>> Sorry, you can no longer watch OTA TV. > And nothing of value was lost.

Except radio spectrum was lost


"Lost" how?


During severe weather, when the internet goes out, I can receive video updates on the weather situation with OTA TV. Even if cell service is available, it may be spotty or overloaded, and getting this info over a broadcast instead of through a network is simply using the right tool for the job.


Maybe you need to get a more reliable internet provider, or switch to 4G.


Tell me you’ve never experienced a widespread natural disaster without saying it.

And your privilege of multiple ISPs and the ability to afford switching to one that may not be included with your rent.


I live in a part of the world with sustained 140mph winds for about four weeks a year.

We manage to keep power and comms running.


It's not so surprising that regular weather patterns can be prepared for.


I'm not talking about an individual problem, sometimes events cause issues that are regional in scope, not limited by ISP, and also result in degraded cell service. If you like, replace "severe" with "extreme".


The failure was letting encryption into the standard in the first place. This will be a never ending game, with big broadcasters continuously lobbying the FCC and congress for the ability to monetize the broadcast bands. If we allow broadcast television to become a subscription service, then just kill TV broadcasting and repurpose this spectrum for mobile (cellular) use. I'm not endorsing this idea, I'm only saying that by going down the path of encrypted transmissions, broadcasters are no different than any other ISP - except they'll own the pipe AND control the content.

You want to stop this in its tracks? Convince Amazon to start buying some TV stations. Congress would be livid.


It's not about turning OTA into a subscription service. It's about taking control of which devices are allowed to view OTA channels. It's about taking control away from the end-user in terms of what they can do with the signal that they record with their equipment. Privately sending that video to wherever I am physically located? Not if they don't say you can.

It's disgusting, and the FCC should be ashamed for not flatly rejecting encryption on OTA channels in all its forms.


> then just kill TV broadcasting and repurpose this spectrum for mobile (cellular) use

I would much rather prefer it become an unlicensed spectrum. I absolutely abhor the idea that spectrum goes to the highest bidder in our current regulatory environment that greatly favors incumbents.


That's not feasible unless there's some regulatory body requiring spectrum sharing (CDMA or GSM or something else?)


By "unlicensed" they presumably mean a loose framework for short-range transmissions, like the rules used for ISM bands.

The ISM bands at 900 MHz, 2.4 GHz and 5.0 GHz used for WiFi, Bluetooth, etc. are the best-known examples.


Would the TV bands actually be useful for that? Wi-Fi has actually been going up the frequency bands looking for spectrum, from 2.4GHz to 5GHz and now 6GHz. Each one adds significantly more bandwidth (but worse propagation for a given transmitter power). If we were to make a "Wi-Fi 7R"[0] with 900MHz support, which is right next to some of the upper UHF TV stations in the US, wouldn't that be terribly slow and have lots of interference from overlapping base stations? I mean, 2.4GHz is already crowded to the point of unusability in a lot of dense areas.

[0] The R stands for "range"


> Each one adds significantly more bandwidth (but worse propagation for a given transmitter power).

As far as I know, that's mostly due to these bands simply having more spectrum available, in addition to actual physical propagation characteristics (lower frequencies indeed propagate a bit better across obstacles like walls or floors, and slightly better through air, but not at all through free space).

In addition to that, unlicensed bands arguably work precisely because they are (by regulation) limited mostly to short-range applications, using maximum transmission power as a proxy for range. One person's signal is another person's noise, after all.

There's other unlicensed bands available that are more suitable for long-range communication, but these usually come with duty cycle restrictions for the same reason.


I think this is one of those things where we should open it up (with limits, I’m not saying we should allow 10kW base stations or something obscene like that) and see what innovation we usher in?

I’m guessing it will be good enough out in the middle of nowhere or something that needs just reliable low speeds?


If someone is already in the middle of no where, 2.4 GHz congestion isn’t a problem for them.

I’m always for more unlicensed spectrum.

But I strongly disagree with your distaste for the FCC’s reverse auctions of spectrum. Wireless Spectrum is a limited public resource and an auction is a much better way to allocate it than to have those same companies instead hire lobbyists to try to convince the FCC to allocate that spectrum to them.


> But I strongly disagree with your distaste for the FCC’s reverse auctions of spectrum. Wireless Spectrum is a limited public resource and an auction is a much better way to allocate it than to have those same companies instead hire lobbyists to try to convince the FCC to allocate that spectrum to them.

There has to be a better way than to allocate spectrum to any one company and give them the rights to buy and sell this spectrum for ninety nine years. If the government needs money, raise taxes!

I am not saying big telco should get wireless spectrum allocation for free. I am saying nobody should get wireless spectrum allocation at all. At least not in the way we currently do things.

If we really need money so much, why not put billboards left, right, and center all over our interstate highways? Why not let companies sponsor the Washington Monument, the White House, and the US Capitol? Lets have an auction and let the highest bidder paint these buildings with whatever they see fit.

Why not give all our federal land to Monsanto for a ninety nine years lease?

/s

Sorry for yelling. I feel very strongly about this. I don't have a solution to how we can allocate spectrum better than an auction. The best I can think of is reduce the number and amount of licensed spectrum.

I want there to be something left in the wireless spectrum when in maybe a few decades hopefully future humans will have a little bit more brains than us come up with a better way to allocate spectrum.

Just to be clear, I am not arguing for repealing Highway Beautification.


802.11af and 802.11at are already a "thing", so I guess they would be useful.


> Convince Amazon to start buying some TV stations.

Heh. Along those lines... When I was an Amazon Product Manager back in 2020, I was tasked to work on a plan for ATSC 3.0 support in Fire TV. I actually suggested that one of the opportunities was to buy/invest in digital broadcast towers as a way of multicasting large amounts of data wirelessly. Some people in AWS were interested in the idea as well. Note - I'm talking about using the towers for one-way digital data transfer, not owning stations.

Everything about my proposal - even the basic support stuff for Fire TV - was rejected wholesale and I left soon after. (In case you're wondering why Sony, Samsung, HiSense, LG and other TVs you can buy today have ATSC 3.0 support and Fire TVs don't.) The lack of forward thinking at Amazon has become endemic.

BTW, it's surreal to spend nearly 6 months deep diving into a technology from hardware to software, tower to TV, then hearing absolutely nothing about it for 3 years, then suddenly seeing two front page links about it in a span of days. Truly surreal.


> If we allow broadcast television to become a subscription service, then just kill TV broadcasting and repurpose this spectrum for mobile (cellular) use.

We should definitely do this, at least. Maybe keep educational stuff like PBS going, but no need to waste bandwidth on soap operas or sports.


In the US, this has happened three times already: in the 80s, channels 70-83 were reallocated to cell phones; in 2008, channels 52-69 were reallocated to cell phones; in 2016, channels 38-51 were reallocated to cell phones. So cell phones have already taken half the spectrum originally allocated to OTA tv.


We should take half that remaining spectrum and reallocate it to wifi.


Seems like it's in the wrong part of the spectrum to be very useful for wifi. IMHO, it would propagate too easily for dense residential (or dense office), which is where congestion is most apparent.


yes, instead we can waste the bandwidth on reddit, twitter, instagram, and netflix.


How about re-purposing some of it for unlicensed short-range consumer devices (a la WiFi, Bluetooth). We desperately need more spectrum for that.


For short-range communications such as Wi-Fi or Bluetooth, the existing higher frequencies will do just fine.

But getting more low-frequency spectrum would be great for longer-range mesh based use cases. For example, I find it quite absurd that I can't message friends a few hundred meters away (e.g. on an airplane sitting in a different row, a few aisles over in a supermarket in a basement etc.) without the both of us having an internet connection via Wi-Fi or cell signal.


I hope you submitted that as a comment, as I think it is well said, and should be heard.


Is there any example in history where the FCC was trying to push through one of their anti-consumer rules that would benefit the usual corporate donors, where the "public comment period" actually convinced them not to do it? I've always thought of a public comment period as a "suggestion box positioned on top of a shredder." They don't care what we think--aren't they just collecting comments because they have to?


In 2016 the FCC enforced Net Neutrality regulations on ISPs after a period of public input that showed overwhelming support for the rules.

This was undone a year later. This time, there was another period of public input, but the public consensus was ignored in favor of giving Ajit Pai's corporate BFFs what they wanted.

Right now the FCC is in a 2-2 partisan deadlock, but that will likely change shortly with the nomination of a 5th comissioner making it to the senate.


I would like to see this as well. I recall during the net neutrality wars [1] that well over 1 million comments left on the FCC website were fake. I wonder whether these comments are monitored at all.

[1] https://techcrunch.com/2021/05/06/80-of-the-22-million-comme....


I hope you succeed. Although I am in Canada, we tend to follow along with what happens in the US in terms of Standards.

I'm still a user of OTA tv, and use HDHomeRun with TVHeadEnd on a NAS to record any shows I like. This definitely would affect me down the road.

I still hold a grudge against Rogers (back when I had cable), when I recorded a bunch of sports from the Beijing Olympics in 2008 and liked watching them on the go. The Rogers PVR, I think it was the Scientific Atlanta Explorer 8300 HD PVR, had a firewire port, and my old macbook had a firewire port. With that, you could play your content from the PVR, and recorded it directly onto your computer as a .ts (transport stream) and then convert it to a smaller file.

Then of course, without my permission, they pushed a firmware upgrade and wiped all my recordings before I could get them off. Jerks.


What's even the point of this? It's a solution in search of a problem that doesn't exist. Who is even pirating OTA content anyway? And if you have the tuner if it doesn't have HDCP then can't the content be captured anyways? Even if it has HDCP, HDCP is broken already.


> Who is even pirating OTA content anyway?

It's sports. Local games are often shown on broadcast TV while packages to view them in other regions are expensive. There's a huge network of sports streamers with ATSC tuners, most of whom who charge (a lot less than the package).

It'll maybe shut down the sports streamers for a year or two, at the cost of social good. Doesn't seem worth it to me!


It would only stop pirates for a whopping 24 hours at best. If there is a will, there is a way to bypass video DRM. It has to be decrypted at some point to appear on a display, and that's the place where it's possible to bypass any DRM without much issue. HDCP is useless [1][2][3], and unless Roku is failing to implement it right, my basic HDMI splitter from Micro Center is more than enough to strip it and feed info HDMI signal into a raspberry pi for ambient light effects. And in order for people to actually use ATSC 3.0 encrypted streams with an overwhelming majority of TVs on the market in use, folks will have to have some form of HDMI box that does the decryption anyway...

[1]: https://en.wikipedia.org/wiki/High-bandwidth_Digital_Content...

[2}: https://en.wikipedia.org/wiki/High-bandwidth_Digital_Content...

[3]: https://en.wikipedia.org/wiki/High-bandwidth_Digital_Content...


Cheap HDMI splitters often have the HDCP circuit only on the incoming side and send decrypted signal out of the receiving end.

You can easily bypass any HDCP signal with $25 worth of stuff off Amazon and record it to your local PC with FOSS like OBS or even the built-in camera softwares.

All this does is make people have to spend more money to get less service. It disproportionately negatively affects the poor for no social good.


It won't shut down the sports streamers at all.

These people, and their customers, have a very different use case and this won't block them at all.

They can just use an HDCP stripper and an HDMI capture card and then re-encode it.

Failing that, they can just point a camera at a TV.

Sports viewers care a lot less about quality.

I'm not saying you're wrong that they are doing this because of sports, but, it won't do anything to curtail that.


I fail to see how encrypting the stream helps them stop this. If a sports re-streamer is just capturing OTA and distributing it verbatim, can't any random TV that could have received the OTA also receive said stream?


I believe that none of the consumer TVs have decryption for ATSC 3.0. It's another box to be connected, and possibly connected to the internet to get updated keys.


This is the real WTF. How many times are they going to break compatibility with OTA TV? A TV purchased in 1955 could receive broadcasts for 50+ years until the digital cutover. Now I’m hearing that tvs purchased just a year or two ago can’t receive a signal without an upgrade box? It’s absurd.


You're both not wrong but that doesn't stop the lawyers wanting these measures. The practicalities of them are irrelevant to the legal team.


Don't the sports streamers just rebroadcast the mlb.tv (or equivalent) transmission? I highly doubt it will stop them at all.

Like any other drm, this will get worked around quickly at the cost of a worse experience for those following the rules.


>> > Who is even pirating OTA content anyway?

>> It's sports.

That's silly. Sports are way more valuable to the consumer when watched in real time. There is very very little value in saving a copy.


They aren't saving copies. They are doing real time streaming.


Right... so all they have to do is plug in one of these boxes into an HDCP stripper and they can keep on streaming.


You can pay for NFL sunday ticket at $200/m, or you can pay $0-$1 to a dodgy streamer who's rebroadcasting the OTA feed from in-region.


Along with commercials. I don't understand why the industry is against things like that, or having a TV showing a game in a public place.


Or pay for an antenna once?


Right, but if you're out of region, someone has to retransmit the OTA.


You're silly:

> There's a huge network of sports streamers with ATSC tuners, most of whom who charge (a lot less than the package).


> HDCP is broken already.

IMO this encryption can be interpretated as "you are supposed pay to view this channel". They could have foregone encryption with just a flag except that it would be trivial for any Aliexpress atsc hdmi dongle to simply forget that about that flag.

That being said yeah they probably require hdcp which.. Well you can find HDMI splitter (that goes from 4k to 4k on hdmi1 and 1080p on hdmi2) that "simply forget" about hdcp 1&2. (no idea whether that's on purpose but that's not the reason I bought it in the first place)


> IMO this encryption can be interpretated as "you are supposed pay to view this channel"

Growing up, I didn't have cable and only had OTA networks. This was before FOX was a network at all, so VHF was only the Big 3. During the day, they only aired soaps, so it was the UHF bands that offered anything different. One of those was TBN, and I would tune in for laughs. One day, Paul Crouch said that if you were watching his program "right now" and did not send him money, you were stealing from him. So your "you are supposed to pay for this channel" is not too far off from the beliefs of some of the broadcasters.


The point is to build a cable-like company without spending money to build the cable infrastructure, by using public spectrum.


Not sure about who is pirating, but OTA signals are typically higher bitrate than a cable subscription. So the image is typically better as long has you have good reception.


ATSC 3 uses HVEC (instead of MPEG2 like ATSC 1) so the quality will shoot way up assuming encryption doesn't spoil it for everyone.


I don't see how encryption would affect the image quality. Obviously not being able to decode the stream makes things difficult, but that has nothing to do with the codec used to compress the video.


Most video streams degrade gracefully when data is corrupted. Losing a byte or two is (generally) not that big of a deal.

Encryption turns every dataloss into something catastrophic. Now, instead of 1 byte lost, you are talking about 1 mb lost (or whatever the size of the encryption chunks are).

That becomes especially bad as codecs get more bandwidth friendly. That 1mb can represent a lot of data, which ultimately gets corrupted until the next keyframe flows through.

You can sort of think of it in terms of a bitmap vs jpeg. If you corrupt 40 bytes in a 1mb bitmap, no problem, it will still mostly look like the original image. However, if you turn that bitmap into a 30kb jpeg and corrupt 40 bytes, now that's a much more significant amount of the information changed.


The block cipher used on broadcast doesn't have a big impact. People have been doing encryption on pay TV broadcasting for decades. There's also plenty of error correction, often 25% of the broadcast feed data is ECC.


Like I said, it expands the amount of data lost when corruption does happen. You can't have 1 bit off. And, due to the nature of interference, it's generally a block of bytes that end up corrupted.

Encrypted pay tv exists (in the form of satellite transmissions) but there, interference is minimized by having a geosynchronous satellite high in the air directly beaming a signal. Only bad weather interferes. Further, because it's being beamed from a single source (rather than multiple towers around an area). you can point your dish directly at the satellite to get a relatively perfect directional connection. Other signals, the sun, power lines, etc don't generally interfere because you are concentrating a focused signal.

That math all changes when talking about receiving multiple terrestrial signals with a non-directional antenna.

If you've watched satellite tv, you know that whenever a storm rolls through it becomes unwatchable. There's not really any sort of graceful degradation, it's either a perfect signal or a blank screen with "no signal". SOMETIMES you might see giant swaths of green blocks or whatever if the corruption is just right, but generally speaking it's all or nothing.

Meanwhile, I get relatively weak signals from a couple of weak OTA stations. For the most part, the images are perfectly passable.


To gain more control over the customer. To block recording so they can monetize live viewing and DVR/on demand/DVD sales viewing separately. To prevent pirate streams. To ensure commercials can’t be skipped. To enable paywalls. They want to get this rolled out and to set the expectation of DRM before ATSC 3.0 is popularly adopted.

Broadcasters have given some bogeyman reason of deepfake edits of broadcasts being possible. But I’m sure that will still be possible after encryption.

The last time this came up it this anti-feature was called the “broadcast flag” bit that would instruct hardware to refuse the viewer’s command to record.

Some cable TV operators let you DVR most channels except for premium channels or PPV events. Others block recording on every single channel just because they can. In either case any recordings are lost when the box breaks or is otherwise swapped.


>Who is even pirating OTA content anyway?

Literally everyone even remotely interested in TV content?




Done!

Proceeding(s):16-142

Confirmation #:202307140526319305

Submitted: Jul 14, 2023 11:20:36 AM

Status: RECEIVED

I am writing in opposition to DRM Encryption being part of the ATSC 3.0 standard. I am a household, like many others, that still use an over-the-air antenna to receive local channels.

I depend on free TV signals for general news and entertainment and I am concerned about costs/accessibility if DRM encryption is included. My concern is that broadcasters will force/coerce encryption on their signals, since it is part of the ATSC 3.0 standard, which will result in an restriction on which antennas can be used. I will have to purchase a new antenna to view the channels that I can currently see with current antenna.

Thank you for you attention


Encrypting public TV transmission.... I didn't know that was a thing. Truly speechless.


Funnily enough, I just got my HAM radio General license - precisely because I can't stand s*t like this. Now I'm just waiting for someone to clamp down on HAM frequencies......


And of course we peasants aren’t allowed to encrypt our signals.


Get an itinerant license. $300 bucks or so, and then you can encrypt if you use the itinerant frequency, and you don't even need frequency coordination for it.

It also comes with some of the other benefits of commercial space.

One of the amateur radio clubs I've joined pooled up and basically offers it as a service to its members.


Thanks for this, I’d never considered this approach.


ty, had no idea about this.


> The broadcasters have said encryption is important for copy protection or other nonsense about protection from hackers and “deep fakes.” But the reality is they are trying to protect broadcast retransmission fees that now make up a significant portion of their revenue.

> Lawyers for the broadcasters have effectively stopped every large scale retransmission effort making encryption unnecessary to protect their broadcast exclusivity rights. What this is really about is making it more difficult for everyday consumers to watch free over the air TV in an effort to push us back onto paid subscription services.

This is a pretty muddled message, as written. It’s odd to say “the reality is…”, and then to say that that is a cover for something else. Based on what’s being said here, it seems like the entire retransmission tangent should be left out entirely.


I'm sorry this sounds non-constructive. I only have an internet plan at home, and I switched to PlutoTV on my Fire Sticks/Google TV sticks. I used to really love HDHomeRun because of how I could stream it around the house, and I did love seeing local broadcast channels. I think the only forward-looking option here is to stream via the internet. I submitted a response to the filing. I keep thinking of how public music radio stations have suffered a slow death and been taken over by countless religious groups.


It is unfair for TV broadcasters to use the public spectrum by shutting out the public through encryption. It must be stopped.


Anecdata: France has a few encrypted channels, and except that there is a monopoly on those channels [1] I think it's quite fair. They take like a sixth of the available bandwidth.

That being said I understand the uproar is about channels switching from FTA to subscription, which isn't legal for channels here

[1] all those channels belong to the same company, but realistically they are the only long-term subscription based channels in France


We should do something like the UK does. We should have the American version of the BBC. I hate the networks totally and completely.



We should do something like the UK does. We should have the American version of the BBC. I hate the networks totally and completely.

Are you under the impression that the BBC is the only television in the UK and it doesn't have other networks?


The American version of the BBC: PBS


PBS is a private company that receives very little funding from the public, and is mostly funded by local stations which in turn are funded through donations.

BBC is funded through an annual Television license fee, and supplemented through international distribution.

While US Public Television (largely PBS affiliates) and BBC have similar goals, fill a similar role. They're very different. Though maybe what you meant was that this is as close to BBC as the US has...


Thank you for posting this here, I was unaware of this going on as it hasn't reached my state.


what public even means is getting redefined completely.

but this must have something to do with the deep understanding rePUBLIC (continuous re-negotiation of this public/private boundary ? but i'm guessing having been unable to finish reading that old Plato book)

why this is scary is because of deep connections between privacy and identity (sense of self even) but I'm already rambling


Public like oil drilling on public lands. Private companies exploit public resources such as finite spectrum, petroleum, or unpolluted water.


and people, people are a resource up for exploitation by this point


American digital TV is unencrypted? That's a surprise, here in Europe nearly all digital TV channels have been DRM:ed right from the start.


My first thought was that broadcasts should never be encrypted; everyone has a license to decrypt the signal and that was a condition of giving them a chunk of the RF spectrum free from interference.

I thought about it some more, and think you need encryption to authenticate the broadcaster to the viewer. For example, without encryption I can drive by the old folks home and broadcast my video of "the world is ending, kill yourself before it's too late" and do a lot of mental damage to people. With encryption, this attack is blocked; I don't have ABC news' key, so I can't pretend to be them.

All in all, I'm not sure what the right public policy decision is here. I guess analog TV worked pretty well. Broadcast intrusions are fun to read about anyway: https://en.wikipedia.org/wiki/Max_Headroom_signal_hijacking


> For example, without encryption I can drive by the old folks home and broadcast my video of "the world is ending, kill yourself before it's too late" and do a lot of mental damage to people.

I mean, yes, you can take a homebrew transmitter and do that, just like you could have done for decades. But you're still operating an unlicensed transmitter and are performing broadcast signal intrusion.

https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A... already defines specific limits which prevent pirate broadcasting.

Why is DRM necessary? And why is it only necessary now?


Because the OTA broadcasters want two things from the viewers.

First, they want to be paid. Second, they want to know who you are so they can provide “targeted” advertising to their clients.

DRM forces both.


The “unlicensed” aspect was never preventing this. Do you deny the basic benefits of end-to-end encryption?


Is end to end encryption even beneficial in a public broadcast medium? I mean, you’d need to send the encryption key as part of the broadcast. There isn’t an out of band channel to transmit a key, so how could this even work in a secure way? Or will they require an internet connect for key distribution? That seems antithetical to the purpose of broadcast TV.

Signing the signal is all you need to be able to validate that the signal came from the broadcaster. But even this assumes that the public key will be transmitted often and the rogue pirate broadcast a bad key.


It actually explicitly prevents this, legally speaking. That was my whole point. This was already explicitly illegal.


> Do you deny the basic benefits of end-to-end encryption?

Yes.

Encryption is for keeping communication private. There's no benefit when communication is meant to be public.

If you want signal integrity, you can sign the signal. But even that is overkill. The threat and harm of intrusion is extremely low.


Authentication, proving validity, doesn't require encryption. Authentication uses cryptography, but the signal doesn't need to be encrypted since can add a signature to prove who came from and that hasn't been tampered with.


You can sign a message without encrypting it, thus ensuring everyone realizes it’s from you while allowing everyone to see it.


Only the rich and powerful should have the key to broadcasting. We mustn't let those poors tell lies. It's to protect granny! The rich and powerful have never lied to us, so they're the obvious party to hold the only key.


I don't think this invalidates your point, just I would say reduces it significance in the choice to allow encryption.

Additionally, I haven't seen an old folks home that doesn't have cable in many years. OTA signal is more common for the under privileged and rural communities. where a local transmitter wouldn't reach many anyway.


You could have done that for almost the last 100 years. It has not been an issue.




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