CONCURRING STATEMENT OF COMMISSIONER COPPS
  
      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.