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OTI, along with Public Knowledge, Consumer Reports, and other public interest groups, the National Association of Broadcaster’s (NABO) proposal to mandate a nationwide transition to a new digital over-the-air TV standard (ATSC 3.0)—thereby requiring all TV sets to have a new tuner. NAB’s plan is deeply flawed and prioritizes broadcaster profits and control at the expense of the public interest. The Commission must not authorize this under the guise of modernization.

The public interest cannot be served by creating technological barriers to reception of free broadcast signals. Historically, the Federal Communications Commission's (FCC) broadcast priorities have included the universality, affordability, and openness of access to over-the-air content. Any mandatory transition to a new standard must preserve these values. It must ensure universal and equitable access to service; strong and enforceable public interest obligations; affordable and interoperable reception equipment; non-discriminatory access to devices and content; robust privacy protections; and the safeguarding of fair use rights, innovation, and competition. Unless these concerns are addressed, we urge the Commission to reject the NAB petition.

The proposal by NAB to mandate a nationwide transition to ATSC 3.0 by 2030 imposes significant and unjustifiable burdens on American consumers. While broadcasters stand to benefit from expanded commercial opportunities—including targeted advertising, datacasting, and retransmission fees—consumers are asked to absorb the costs of new equipment, navigate technical complexities, and potentially lose access to free over-the-air television if they cannot afford or adapt to the new standard. This cost-shifting is neither equitable nor consistent with the Commission’s longstanding obligation to ensure universal, affordable access to essential communications services. It also marks a shift in policy from the previous analog-to-digital broadcast transition, where Congress, in the Digital Transition and Public Safety Act of 2005, made a subsidy available to every household to cover the cost of necessary converter boxes.

For millions of Americans—particularly those in low-income households, rural communities, tribal areas, or elder populations—broadcast television remains a primary or exclusive source of news, educational content, emergency alerts, and entertainment. These communities are least likely to upgrade their hardware frequently and are disproportionately affected by costs associated with new tuners, incompatible televisions, or internet-enabled features. These issues are compounded by the pervasive and inappropriate incorporation of Digital Rights Management (DRM) into the ATSC 3.0 standard, which fundamentally contradicts the Commission’s mandate to promote access, localism, and diversity.

To that end, while the NAB’s petition should be denied, the FCC should condition any eventual transition on the implementation of a robust consumer protection plan, including:

• a federally funded voucher or rebate program for low-income households and institutions;
• requirements that ATSC 3.0 stations simulcast substantially similar content in ATSC 1.0 until a defined penetration threshold is met;
• clear labeling requirements on devices regarding ATSC 3.0 compatibility and internet dependencies;
• rules prohibiting broadcasters from requiring internet connectivity as a condition for accessing unencrypted content;
• and periodic public reporting on consumer impact, device adoption rates, and service accessibility.

Absent such safeguards, the transition will not serve the public interest—it will impose new costs on the public for the benefit of industry incumbents.