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ACA To FCC: No Proven Need For Dedicated Customer Support Related To Video Description, Emergency Info

Cable Trade Group Also Claims Action Lacks Congressional Direction

PITTSBURGH, July 25, 2013 - The American Cable Association urged the Federal Communications Commission to refrain from adopting rules that would require multichannel video programming distributors (MVPDs) to provide support services specifically designed to assist customers in accessing video description or emergency information content on a secondary audio stream.

"ACA maintains that the Twenty-First Century Communications and Video Accessibility Act (CVAA) provided no direction for the FCC to impose such a requirement; there is no evidence such a requirement is necessary; and it would be exceedingly burdensome for small operators to commit the necessary resources for such dedicated customer support," ACA President and CEO Matthew M. Polka said.

ACA submitted comments (attached) to the FCC on July 23 in response to the FCC's Further Notice of Proposed Rulemaking (FNPRM) related to discrete additional implementation issues arising out of the CVAA's emergency information and video description rules. The FCC sought comment on whether to require MVPDs to provide support services specifically designed to assist customers in accessing video description or emergency information content on a secondary audio stream on operator-supplied navigation devices.

Rather than adopt these additional requirements, the FCC should acknowledge that its current position of encouraging covered entities to provide customer service support remains an appropriately flexible and sufficient manner in which to address this issue, ACA said.

ACA stressed that the FCC did not offer any evidence of an existing problem that its proposed requirements would address.  One reason for the sparse record may be that customers of MVPDs have not needed support from MVPDs to access these features; another reason may be that MVPDs are already satisfying the needs of their customers who request support accessing these services.

Another point ACA raised was that smaller MVPDs would likely find any prescriptive customer support mandates burdensome. ACA's membership, for one, primarily consists of smaller and midsize operators of varying sizes and capabilities; it would likely be very challenging for these operators to meet the same obligations as the country's largest cable operators.  The thin margins that many smaller operators operate within mean that many do not have extra resources to specifically devote for this type of support.  Absent any indication of need for such dedicated support, there is little justification for imposing such burdens on smaller providers.

"The FCC's current approach of encouraging MVPDs to remain generally capable of answering questions regarding access to the secondary audio stream with respect to the navigation devices each supports, and to provide contact information regarding accessibility questions, is entirely sufficient and appropriate," Polka said.

About the American Cable Association

Based in Pittsburgh, the American Cable Association is a trade organization representing nearly 850 smaller and medium-sized, independent cable companies who provide broadband services for more than 7 million cable subscribers primarily located in rural and smaller suburban markets across America.  Through active participation in the regulatory and legislative process in Washington, D.C., ACA's members work together to advance the interests of their customers and ensure the future competitiveness and viability of their business.  For more information, visit http://www.americancable.org/

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