The American Cable Association urged the Federal Communications Commission to move cautiously in seeking a successor to the CableCARD to ensure that independent cable operators and other small business entities are not burdened by disproportionate regulatory mandates.
"With the FCC shifting away from strict reliance on the CableCARD regime -- a costly experiment that almost all acknowledge has been a failure -- ACA recommends that the FCC carefully move forward in crafting new ways to promote the retail sale of affordable navigation devices as ACA members want to avoid retrofitting their systems with expensive new software and capital equipment," ACA President and CEO Matthew M. Polka said.
For several years, ACA has urged the FCC to relax CableCARD rules to allow ACA members to deploy less expensive set-top boxes, advancing the migration from analog-to-digital networks while freeing up bandwidth needed to increase broadband download speeds for millions of consumers in rural America.
In July 13 comments, ACA raised no objection to the FCC Notice of Inquiry's (NOI) effort to finding a solution that would promote competition in both the wholesale and retail markets for navigation devices, as envisioned by the 1996 Telecommunications Act, or that would lower costs for multichannel video programming distributions. In the NOI, the FCC has specifically proposed to replace the CableCARD with the "AllVid" concept.
The "AllVid" concept involves an adapter that communicates with a cable, phone or satellite multichannel video service, which would perform only the tuning and security decryption functions specific to a particular provider. A "smart video device" would then connect to the adapter through an open standard, and would perform navigation functions, including the presentation of programming guides and search functionality.
ACA has no view on the specifics of the "AllVid" concept at this time, but the trade group expressed concern that the "AllVid" concept could require ACA members to make substantive - and costly - changes to their equipment and operations, including, but not limited to, new physical connections, communication protocols and authentication requirements, and content encoding.
"The FCC must recognize that any new requirements under the ‘AllVid' approach could come with large per-headend or per-customer costs, which will be disproportionately higher for smaller operators," Polka said. "This is problematic because the typical ACA member with thousands rather than millions of subscribers simply does not have the luxury of a large customer base that can readily absorb escalating fixed costs imposed by regulation."
ACA is hopeful that the FCC will not repeat the mistakes of the CableCARD era and will instead consider new rules that won't force ACA members to divert valuable capital resources away from the deployment of advanced services, including broadband, in rural and smaller markets.
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