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Improving the CableCARD Regime

Improving the CableCARD Regime

CableCARDs will again be a topic of discussion in D.C. this week as the FCC on Thursday is expected to approve some revisions to the CableCARD rules, smart-card like devices which facilitate the ability of retail  cable-ready “video navigation devices” to access cable services. We largely agreed with the proposals the Commission made in its CableCARD Further Notice and want to ensure that customers who utilize these devices have a satisfying experience.  We also support the Commission’s efforts in the “AllVid” Notice of Inquiry to examine fresh approaches to implementing Section 629 that involve all video providers – not just cable – and we have proposed a set of principles that can serve as a foundation for these efforts.  But since the AllVid item is still in early stages, we are committed to working with the Commission on targeted revisions to the CableCARD rules. You can review this previous post on the history of CableCARDs for a refresher on how we got to our current point. Quite simply, the CableCARD approach failed largely due to rational consumer choices. The original one-way retail devices worked only with one-way cable services, cost more than other devices, and made consumers assume the risk of obsolescence.  Instead, consumers chose to lease devices at government-mandated rates which offered Video on Demand and other valuable interactive services and which also provided them the flexibility to swap boxes when the next model was released or return boxes if they terminated service. We agree that consumers should have a self-installation option, if their cable operator allows self-installation of leased set-top boxes and the device's manufacturer provides adequate installation support, as Moxi and TiVo do today. We also think it's a good idea for professional installers to arrive at the home with no fewer than the number of CableCARDs (specifically, M-Cards) that have been requested by the customer. And we agree that operators can provide more transparency regarding CableCARD pricing by including relevant information on an operator’s website, in rate cards and in other notices. On a broader level, we don’t think that onerous new CableCARD requirements should be imposed on cable operators; instead, the focus should shift towards new solutions that cover all multichannel video programming distributors.   As we said in an earlier post, “the only way a retail video device marketplace can fully work for consumers is if all MVPDs participate.” To that end, we’re happy to work with manufacturers like TiVo, but as we noted previously, we feel that TiVo’s proposal for mandating a standardized IP backchannel approach – in lieu of tuning adapters, so that one-way devices can access two-way switched digital video channels – would be costly, time-consuming and unnecessary. Instead, all parties should work together to make the viewing experience better for consumers. We hope that tomorrow’s FCC meeting will help move us in that direction.