Yes, in fact, I am surprised that broadcasters haven't done more to push FTA as a solution to "go digital" for those OTA users that will lose analog. FTA can provide better reception, over a wider area, with a wider variety of programming. OTA would only beat FTA for those who live in "Grade A" OTA reception areas, in large markets with lots of channels and subchannels on the air.
The one broadcaster that has, to some extent, is TBN. They probably promote FTA as a solution to receive their entire digital suite of networks just as much as OTA digital. (Although now that the Digital Transition is upon us, OTA is certainly getting top billing.)