How do the V-Chip Requirements affect DTV Products?

Ó July 6, 1999 By David Broberg

Background:

The FCC issued a Report and Order (FCC 98-36) on March 13, 1998 mandating the inclusion of content based blocking functions in Televisions beginning July 1, 1999. The requirements of this order mandate the so called "V-Chip" function in TVs.

The problem is the language of the order says that DTV receivers will be expected to react to V-chip data in a similar manner as analog sets. But the definition of the signaling characteristics are only defined for the analog transmissions. This leaves some questions open:

• Are new DTV receivers required to support the V-Chip blocking functions?
• Does the requirement apply to the receiver set-top-box or to the HDTV monitor?
• How will broadcasters encode the V-Chip information for DTV signals?

What we know:

1. The current FCC requirement that mandates the blocking circuits on one half of all TV models now and all remaining models by the end of this year does not address DTV receivers to the same level of detail as analog sets.
2. The current FCC requirements only apply to DTV "receivers" with an integral display and a viewable screen size of at least 13" diagonally. They also apply to DTV receivers sold as a set-top-box that can be purchased "as a system" at retail. This provision includes "systems" consisting of PC-Tuner cards and PC-Monitors that are sold together and ATSC receivers that might be sold with DTV ready monitors in a single transaction.
3. The FCC rule for receivers, defines a mandate only for the line-21 VBI technology for program advisory data. This is the NTSC (analog) method to carry coded program content advisories.
4. For DTV receivers, the FCC rule only says they should "react in a similar manner as analog receivers." It does not define the required content advisory packet format although at least two different schemes are possible.
5. The EIA-744 standard defines how the TV Parental Guideline information is multiplexed with the closed captioning data in the NTSC signal. The FCC rule insures that this signal is "protected" against disruption, distortion or deletion by downstream cable operators.
6. The ATSC standard (A/65 "PSIP") has been passed with the inclusion of Rating Region Tables including the provision to code program content advisories. EIA-766 is the US Rating Region Table standard that duplicates the US TV Parental Guideline labels.
7. Although the ATSC standard A/65 is noted in the discussion portion of the new rule, the FCC rule does not require the use of A/65 (PSIP), however most DTV stations will find at least some of it necessary.
8. There currently is no FCC protection of the A/65 PSIP on downstream (cable) systems.
9. The ATSC system for DTV also includes a new standard for closed captioning (EIA-708) data in the video user bits. The EIA-708 standard includes the provision to carry a backward compatible EIA-608 data stream which can be used to reconstruct a line 21 VBI signal in a DTV receiver/decoder. Of course a VBI signal is only useful for the 480-Interlace image formats. This EIA-608 data can include the EIA-744 content advisory packets.
10. There is no requirement for broadcasters to generate content advisory data (V-Chip) data in either the line-21 (EIA-608) method for NTSC, nor in the A/65 method for ATSC. Participation is voluntary on the transmission side. The only requirement is, that if content advisory packets are sent in analog signals, they must conform to the EIA-744 format.

What we can assume:

1. When transcoding programs to DTV that were originally produced for NTSC, it is possible (and desirable) to transcode the line-21 (EIA-608) data into the video user bits. (That way, a DTV receiver/decoder with a downconverter and an NTSC output, can reconstruct the line-21 caption and "V-chip" data.)
2. It is possible (but not required) to build a DTV receiver that can look at the A/65 PSIP signal for EIA-766 content advisory data.
3. It is possible (but probably not required) to build a DTV receiver that can look at the video user bits for the EIA-608 content advisory data.
4. It might be possible (and probably compliant) to build a DTV receiver that reacts to some other content advisory packet structure besides EIA-744 or EIA-766.
5. It is possible that two or more content advisory signals in the same DTV program stream may disagree on a given rating.
6. It is possible for DTV stations to generate ATSC signals today, with either or both recognized forms of content advisory data, or an entirely new data structure for the advisory.
7. It is possible that some DTV receivers will respond only to A/65 (EIA-766) content advisory signals.
8. It is likely that some DTV receivers will respond to only to EIA-608 content advisory signals carried in the video user bits, since decoder IC's are already available to process this signal format.
9. Since it is likely that some DTV receiver systems will also support analog NTSC, then it is also possible that some of these systems will only respond to analog content advisories when in the apparatus is in the NTSC mode and will not respond to either form of DTV content advisory data. It is not completely clear if this would be a rule violation since one could argue that this set does indeed "react in a similar manner as analog receivers."
10. Since Cable STB's are not yet sold at retail, (and not bundled with a display) they are likely to be considered exempt from the requirement to process the broadcast V-chip signals, for the moment. However, local franchise requirements have often required separate parental locking functions on cable boxes for some time. When (and if) retail cable boxes ever appear, they could find themselves suddenly bundled with a display and bound by the FCC V-chip (and captioning) rules for TVs.

What we should be asking:

1. Will cable TV systems carry the broadcasters' A/65 data? Does the station's (or network's) contract with the cable operator guarantee it?
2. Will your new DTV receiver respond to content advisory information in A/65 or transcoded EIA-608 or both or neither?
3. If your new DTV receiver is supposed to support V-chip blocking, and this product (system) also works for NTSC, does the V-chip function only work for NTSC?
4. What happens when the A/65 content advisory doesn't match the EIA-608 rating for the same program?
5. Will future FCC rules for cable compatibility require carriage and protection of the A65 signal on the cable plant?
6. Will retail cable STB's include FCC mandated V-chip processing? For NTSC? For ATSC? For cable signals?
7. What happens when both the STB and the monitor (display) include redundant controls (and passwords) for V-chip blocking functions?
8. Does the FCC expect to issue new rules for V-chip requirements in DTV receivers?
9. Do the current FCC rules imply a requirement for new DTV receivers to support transcoded EIA-608 data for parental blocking? Just what is a violation?
10. Will any consumer ever actually use the v-chip parental locking functions successfully?
11. How long before sets include V-chip "searching and sorting" functions? "Seek the naughty bit"
12. If the V-chip "experiment" is considered successful, how long before our government requires password protected refrigerator locks to block minor's access to beer or wine that might be stored within?

For more information:

• EIA / CEMA V-Chip Information Center
• V-Chip Education Project
• FCC V-Chip Homepage
• NAB's TV Parental Guidelines Page for Broadcasters
• MPAA's Page on TV Parental Guidelines

This article may not be duplicated, reprinted or published in whole or part without express written permission from the author. broberg@ieee.org

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