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Re: Service Rules for the 746-764 and 776-794 MHz Bands, and Revisions of Part 27 of the Commission's Rules, Order on Reconsideration of the Third Report and Order, WT Docket No. 99-168

I concur in today's result. I am writing separately, however, because I am troubled by the potential disenfranchisement of American television viewers that could occur if we accelerate the mandatory conversion from analog to digital.

On balance, today's order is a positive development for consumers. But this is true only because our Third Report and Order otherwise would have resulted in a requirement that "single channel" licensees broadcast in a digital format on their remaining channel by 2002, leaving analog consumers without access to these channels. I don't believe that stranding these viewers next year was ever the intent of the Commission. Under today's Order, the single channel stations will now be able to broadcast in analog beyond the 2002 date. Strict adherence to this date would have been worse than our alteration of their final conversion responsibilities. Were it not for this unique circumstance, I would have been troubled by potentially accelerating the mandatory conversion from analog to digital.

While I strongly support the conversion to digital television, here we meet what I think is an unintended consequence - potentially leaving more analog consumers behind. I am troubled by a conversion schedule that could leave Americans without access to broadcast services.

In the future, I hope that the Commission will assign high priority to protecting consumers of free over-the-air television service and will act so as to minimize the number of consumers left without access to broadcast television when the conversion is complete.