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ACA Tells FCC Not To Act On Downloadable Security Report

DSTAC 'Device Proposal' A Costly Option Not Intended By Congress

PITTSBURGH, October 13, 2015 - The American Cable Association urged the Federal Communications Commission to take no further action related to the recommendations contained in the Downloadable Security Technical Advisory Committee's (DSTAC) Report.

The Report includes Working Group 4's (WG4) proposal for a "Competitive Navigation" System (Device Proposal) that would be incredibly disruptive and costly for multichannel video programming distributors (MVPD) to implement, with the heaviest burden falling on smaller operators. 

In comments filed with the FCC, ACA criticized the make-up of the Committee - a working group of technical experts that was supposed to broadly represent all stakeholders - whose charge was to report and recommend solutions for uniform, and technology- and platform-neutral downloadable security.

The Committee selected was not broadly representative and the DSTAC Report included WG4's proposals concerning non-security elements of MVPD service.  WG4's work exceeds the scope of the Congress' directive and was not necessary for the Committee to fulfill its mandate, ACA wrote.  Further, the Device Proposal itself is a costly and impractical solution that runs directly counter to the intent of Congress in abolishing the cable TV set-top box integration ban in the STELA Reauthorization Act of 2014 (STELAR).

"To ensure the continued availability of MVPD service and to avoid the significant costs that MVPDs would incur to comply with unnecessary technical mandates, the FCC must ignore the Device Proposal and permit MVPDs to continue with the flexible, pro-competitive approach that has been developed in the market and is embodied in the App Proposal," ACA President and CEO Matthew M. Polka said.

The "Application-Based System" proposal (App Proposal) refers to a concept that would impose no technical mandates on MVPDs, following an organic approach that relies instead on competitive market forces that already have led to the development of new technologies that have been embraced by consumers.

As a threshold matter, ACA underscored its disappointment that the working group did not include representatives from the independent cable community.  Had smaller cable operators, of which ACA nominated several, had seats at the table, they would have pointed out that the burdens the Device Proposal would impose on all MVPDs would be significantly amplified for smaller MVPDs.  They would also have made clear the Device Proposal incorrectly assumed that all MVPDs were currently operating at a level of sophistication that few beyond the very largest operators have thus far reached.

In its comments, ACA stressed that the Device Proposal runs counter to good regulatory policy, which favors flexibility and free market principles over technical mandates.  The market for video programming is more competitive than ever and consumers have real choice in both video service providers and consumer electronics that can be used to access video programming.

The demand for retail navigation devices has moved away from the traditional set-top box model, and has grown in ways that could not have been anticipated just a few years ago. There is simply no need for further regulation to encourage competition in an already flourishing marketplace.

ACA said the FCC ban on integrated set-top boxes, requiring cable operators to deploy CableCARD-enabled boxes, added $1 billion in costs to consumers and failed to achieve the stated goal of a competitive retail market for STBs.  With that history, ACA said the FCC should be very careful about believing that new technological mandates will work out any better.

"In contrast, the Device Proposal would require MVPDs to evolve a high level of sophistication almost immediately, requiring millions of dollars of network upgrades in a short span of time. Although advocates of the Device Proposal emphasize that MVPDs will retain flexibility to innovate and experiment with new functionalities, they ignore the significant burdens associated with its implementation, burdens that would be borne entirely by the MVPDs," 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 nearly 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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