In a speech at the Open Technology Institute, Rosenworcel made her case against the framework, which the Republican majority is expected to vote to approve at the Nov. 16 open meeting.
Rosenworcel said she is excited by the standard's prospects of Ultra High Definition, immersive audio and advanced emergency alerts. But she is less enthused about what she sees as a rush to market that might leave many consumers behind.
Related: Pai Pans ATSC 3.0 Framework Critics
In the minus column are that the new standard is not backward-compatible, and while it is voluntary, it may not be for consumers since the FCC is proposing to allow broadcasters to bundle ATSC 3.0 and current 1.0 signals in retrans negotiations, she told her audience.
"That means consumers could find their bills going up because they will be stuck paying for two signals—even though their current television equipment can only receive one," she said. "That sounds a lot like paying more and getting less."
MVPDs had asked the FCC to carve out 3.0 from retrans negotiations, making the same argument as Rosenworcel.
Rosenworcel said the main problems with the plan are in how it differs from the plan for the DTV transition drawn up more than a decade ago.
First, there is no congressional mandate for the move, she said, adding that "instead it's a few unelected FCC officials making decisions about when you need to buy new televisions, acquire new equipment, and locate the HDMI port on the back of your set."
Second, there is no subsidy for new equipment consumers will need--either a new TV set or a converter--to receive the ATSC 3.0 signal. There was a multi-billion converter box subsidy in the DTV transition.
Third, there is no test market as there was for DTV--in that case, Wilmington, N.C.
Rosenworcel said the FCC should hold off on approving the rollout and instead work with Congress to legislate it.
As to the need for a test market, she said what needs testing includes the risk to consumers of being left behind, as well as the impact of targeted advertising and the implications for privacy, the use of encryption, the collection of audience data and the risk for hacking.
The IP-based ATSC 3.0 standard will bring a bounty of online interactivity but also the same privacy and security issues broadband operators have been wrestling with.
Rosenworcel also echoed some of the concerns of the critics of the Sinclair-Tribune deal given that Sinclair has a handful of ATSC 3.0 patents.
"When the agency adopted the ATSC 1.0 standard, it made clear that reasonable and nondiscriminatory terms were part of the package," Rosenworcel said. "In the current proposal, this issue is addressed in no more than a footnote. Moreover, we know that Sinclair Broadcasting—which holds essential patents for ATSC 3.0—has been one of the biggest champions of this new standard. We also know that they have pending before the agency the biggest broadcasting transaction in our nation’s history. Before we authorize billions for patent holders and saddle consumers with the bills, we better understand how these rights holders will not take advantage of the special status conferred upon them by the FCC."