CableCARD no longer required legislature

[richard1980]

Hasn't the FCC already been giving out some limited waivers on the integration ban?

Yes, but only for boxes that don't have any fancy capabilities (no HD, no DVR, etc.). Basically the waivers are for DTAs or similar boxes.

As many of you know, the integration ban was put in place to force cable companies to support CableCards, and it was reasonably effective at that.

As was already discussed in this thread, the integration ban was written in 1998...several years before CableCARD even existed. It was the integration ban that caused CableCARDs to be invented in the first place.

Getting rid of the integration ban wouldn't, by itself, remove the requirement to support CableCard.

Without the integration ban, there would be no law requiring the cable companies to even use CableCARDs or any other similar technology, much less offer support for the technology. The cable companies would be free to switch to integrated security modules and completely abandon the concept of separable security.

And keep in mind there's a very large installed base of cable company provided STBs that rely on CableCard, so there's only so much damage that could be done.

Integrated security could be deployed to the current installed base via a firmware update. Even if that were not possible, the future deployment of new STBs is inevitable anyway, and those boxes could be built with integrated security.

Cable companies *probably* wouldn't do anything too bad...

How do you know?

To do so would risk future FCC or Congressional involvement (e.g., AllVid), which the cable companies really don't want.

Congress does not repeal laws that they wish to continue to enforce. If Congress repeals the integration ban, then the clear intent of Congress is to allow integration.

From the cable company perspective, CableCard is already 1) deployed and 2) no real threat, so I imagine if they need to be able to argue that they support third-party boxes, they'd rather go with CableCard than any other technically-feasible option.

From the cable company perspective, CableCARD unnecessarily increases costs. The cost of the physical boxes that are currently deployed is irrelevant. It's the future boxes that will be deployed that the cable companies will consider. Additionally, the larger cable companies all have facilities and employees dedicated specifically to CableCARD, which could be shut down if CableCARD were phased out. And let's not forget about opportunity cost. A customer that leases a CableCARD instead of a cable box is costing the cable company money. While that opportunity cost is relatively small, it's still an opportunity cost nonetheless.

Of course, this doesn't just apply to CableCARD. Substitute any separable security technology, and the same cable company perspective still applies.

[barnabas1969]

Yep the real danger here is not that Cablecard will go away, but whether there will be an open IP access standard to replace it. Right now that is very much in doubt given the FCC's insane decision to allow Charter to go their own way for a new downloadable security standard.

http://www.multichannel.com/technology/ ... ver/142813

It's interesting that Charter's request stated that software-based security would make it easier for Consumer Electronics manufacturers to build retail devices, but the Consumer Electronics Association is opposed to Charter's waiver.

This condition is scary:

Charter must also support the CableCARD indefinitely, including self-installation, and in switched digital video deployments, among other requirements. As an incentive, Charter will no longer be required to provision new CableCARDs to customers when a third-party device compatible with the MSO’s downloadable security system is available for purchase at retail.

So, when "a" third party device is available (no matter how much it sucks, and no matter if it doesn't work with a PC), Charter will no longer be required to provision new CableCARDs. So... that means that nobody will be able to add a new CableCARD device to their account. What happens if a CableCARD dies in an existing device? Will Charter be required to replace it?

[reggie14]

As was already discussed in this thread, the integration ban was written in 1998...several years before CableCARD even existed. It was the integration ban that caused CableCARDs to be invented in the first place.
[...]
Without the integration ban, there would be no law requiring the cable companies to even use CableCARDs or any other similar technology, much less offer support for the technology. The cable companies would be free to switch to integrated security modules and completely abandon the concept of separable security.

I think one of us is misinterpreting the regulations and the proposed bill here. I can't find the specific text that has been proposed, so I'm only working off the statement that they're looking to remove the integration ban. The integration ban, while related, is distinct from the requirement for separable security. When the FCC was developing the regulation, they considered putting forth the separable security requirement without the integration ban, but there was concern that cable companies wouldn't support the technology faithfully. So the regulation included both the separable security requirement and the integration ban, although cable companies were given different deadlines for each (both were pushed back significantly).

It sounds like they only want to remove the integration ban, so I assume the requirement for separable security would remain. I believe other FCC regulations specifically call out support for CardCard, so unless cable companies get other waivers from the FCC, they'd be on the hook to support CableCard as the separable security mechanism.

[richard1980]

I can't find the specific text that has been proposed, so I'm only working off the statement that they're looking to remove the integration ban.

"(5) Should Congress repeal the set-top box integration ban? If Congress repeals the integration ban, should Congress take other steps to ensure competition in the set-top box marketplace both today and in the future?"

The integration ban, while related, is distinct from the requirement for separable security. When the FCC was developing the regulation, they considered putting forth the separable security requirement without the integration ban, but there was concern that cable companies wouldn't support the technology faithfully. So the regulation included both the separable security requirement and the integration ban, although cable companies were given different deadlines for each (both were pushed back significantly).

I believe you are confusing the separable security requirement (the requirement that security functions should be separated from the non-security functions...the opposite of integrated security) with the requirement to make separate security modules available that work with retail navigation devices. The issue is not whether the separate security module should still be required to be available, but whether security functions in cable boxes should remain separate from the non-security functions. By lifting the ban on integrated security, Congress would be allowing integrated (i.e., non-separable) security in the cable boxes.

It sounds like they only want to remove the integration ban, so I assume the requirement for separable security would remain.

Well, I guess if Schrödinger's cat can be both alive and dead at the same time, security can be both integrated and separable at the same time...until you observe it, in which case it becomes either integrated or separable, but not both.

[reggie14]

"(5) Should Congress repeal the set-top box integration ban? If Congress repeals the integration ban, should Congress take other steps to ensure competition in the set-top box marketplace both today and in the future?"

Ahhhh, thanks. On my first pass I didn't fully grasp that they don't seem to have draft statutory language, just a question in a letter to stakeholders.

For the purposes of this discussion, I'm going to continue to assume that the choice of language in the letter was deliberative- that is, that they're proposing removal ONLY the integration ban.

I believe you are confusing the separable security requirement (the requirement that security functions should be separated from the non-security functions...the opposite of integrated security) with the requirement to make separate security modules available that work with retail navigation devices. The issue is not whether the separate security module should still be required to be available, but whether security functions in cable boxes should remain separate from the non-security functions. By lifting the ban on integrated security, Congress would be allowing integrated (i.e., non-separable) security in the cable boxes.

We're (mostly) on the same page there. I didn't mean to say anything that contradicted what you said about, other than to make a distinction between "separable" and "separated." The FCC's initial regulations that led to CableCard had two major distinct, but closely related, requirements: 1) separable security, and a requirement to use those same separable security mechanisms in their own boxes (i.e., the integration ban).

Well, I guess if Schrödinger's cat can be both alive and dead at the same time, security can be both integrated and separable at the same time...until you observe it, in which case it becomes either integrated or separable, but not both.

I think this is the primary source of the confusion in our discussion.

I don't see any intrinsic problems with allowing separable security and integration at the same time. That is, make cable companies support CableCard without requiring that they put CableCards in their own STBs. There's nothing particularly special about CableCards, other than they have some crypto hardware and keys to enforce access control by only decrypting authorized streams (basically). There's no reason you couldn't embed that same functionality in the hardware and firmware that make up an STB.

Michael Powell made the same observation as an FCC commissioner when they came up with the initial rules (see this). As I understand, the integration ban was created in addition to the separable security requirement as a way to basically force cable companies to "eat their own dog food." If they had to rely on those separable security mechanisms for their own boxes, they'd presumably make sure the system works. If they didn't have to rely on them, what strong incentive did they have to keep the system functioning properly? I understand the logic. It probably was the right decision at the time, too.

The situation is a bit different now, though. The cable companies seem to have CableCard support working pretty well now, and we have stronger regulations from the FCC about the level of support that is required from cable companies for CardCards (see this).

Assuming the separable security requirement stays, along with all other CableCard rules besides the integration ban, I really think the damage would be minimal.

The kinds of waivers that slowbiscuit referred to in this post have to potential to do far more damage, particularly to the PC DVR ecosystem (my strong expectation is that any downloadable security approach would at least need to work with [new] TiVo boxes to be viewed as credible, but the same can't be said for PC DVRs, which are a dying breed anyway).

[IownFIVEechos]

Why is it that after the first year the cable card price does not drop? If the rule is 1/12th the price of it, I understand support stays the same but clearly on the hardware end money has been recouped; no? Also in the FCC rule it sounded like the customer has the right to either own or rent the equipment, meaning why can we not buy the device on ebay etc... and have them work? Or can we and I missed that?

[barnabas1969]

Reggie, you may be correct. But you should contact your Senators and Representative to voice your concern and desire that CableCARD continues to be supported.

[IownFIVEechos]

After reading Reggie's post which made this topic much more clearer (to me at least). It almost sounds like by trying to stop this we are hurting innovation. What if someone stopped cablecards from ever being used in the STB's? Sounds like a new method of accessing this content will be born if the cable companies have the option to expand on what already exists; just make it better (innovation?).

[reggie14]

Why is it that after the first year the cable card price does not drop? If the rule is 1/12th the price of it, I understand support stays the same but clearly on the hardware end money has been recouped; no?

That sort of pricing model would be highly unusual in the cable industry, or the telecom industry in general. The bigger question is why have CableCard rental rates increased in some instances? It could be due to the lost revenue and higher support costs associated with the newer FCC regulations. Though, the truth of the matter is, customers who rent STBs by the cable company are probably still effectively subsidizing the CableCard system for TiVo and WMC users.

Also in the FCC rule it sounded like the customer has the right to either own or rent the equipment, meaning why can we not buy the device on ebay etc... and have them work? Or can we and I missed that?

That refers to the "navigation" box (e.g., your TiVo or WMC+tuner), not the CableCard.

[reggie14]

Reggie, you may be correct. But you should contact your Senators and Representative to voice your concern and desire that CableCARD continues to be supported.

To be perfectly honest, I'm not sure I think that.

I'm a CableCard user myself (SageTV with an HDHR Prime), so I certainly have a personal stake in this, particularly in the short-term. But thinking more broadly, I'm not sure there are enough CableCard users to justify regulations. I think the market has (largely) spoken, and there's very little interest in retail STBs. Cable companies will likely continue to work with particular vendors with decent-sized customer bases (e.g., TiVo, and maybe Samsung down the line), but home-brewed DVRs are such a niche area that it likely doesn't make sense for government or industry to pay much attention to them, support-wise or regulation-wise.

I tend to think it just makes sense for cable companies to support CableCard as long as their back-end infrastructure is consistent with it, but I'm not sure we should be imposing regulations that make it more difficult to companies to change their systems. Generally speaking, I'd probably slightly prefer an approach where the integration ban goes away (which I think the FCC can do themselves), and the FCC is open to waivers for CableCard entirely in situations where it broadly makes sense (even if it does screw over WMC users), with proper notice to customers, etc.

CableCard isn't a great solution and hasn't been effective at creating a thriving retail STB market. Maybe something like AllVid would have been more effective, but at this point I don't think it makes a lot of sense to regulate that into the market. By the time it would get standardized, developed and deployed I strongly suspect it would be an obsolete technology.

[barnabas1969]

A thriving retail STB market doesn't exist because the cable companies actively discourage customers from using CableCARD (that was my experience on the phone with them, and I've read many similar stories from others), and they were providing terrible support for CableCARD until about 2 years ago. Support is finally decent in most cases, if you know the right phone number to call or the right department to ask for when you call your cable company.

I'm all for a new solution like Charter is proposing, as long as CableCARD continues to be supported until real alternatives exist in the retail market. My cable company's whole-home solution is very expensive (it would cost me an extra $86/month) and it is very clunky to use. TiVo has FINALLY come out with a solution that I would find acceptable in the Roamio/Mini. I think that the possibility of a thriving retail market is just now becoming a reality. Killing CableCARD is the wrong thing to do.

[reggie14]

Sure, I agree that retail STBs were never really given a fair shot. Though, I'd probably say the reasons were more complicated than simply some cable providers providing poor customer support. Timing, high up-front costs for early DVRs, financial incentives to stick with provided STBs, and general apathy also played factors.

In any event, that doesn't change where we are now. CableCard support has been much better, but TiVo's retail subscriber base decreased for 6 years. It increased by 6,000 in the last quarter, which can be viewed as a success only because of the long-term downward trend. TiVo's recent profitability is due almost entirely to their agreements with cable providers (Virgin, notably). ReplayTV is long gone, and Moxi failed too (despite fairly impressive capabilities).

The Roamio looks pretty good, but I would be incredibly surprised if TiVo could turn around the downward trend, much less turn the retail side into a thriving business.

I just don't see the demand. Many of my younger, more technically-savvy friends have cut the cord, largely with the help of Netflix, Hulu, Amazon and Apple (sometimes augmented by less-than-legal sources, though not as often as you might think). My friends that are slightly older often have young kids, almost none of whom watch TV shows and movies on TVs (mainly iPads, some laptops). The parents still usually watch things on TV, but they seem rather disinterested in paying for a TiVo.

Could the Roamio let TiVo rebound a bit? Perhaps. But I think the providers DVRs, in some cases, have improved, too. Growth would almost certainly be slow, and I think that by the time they theoretically could grow to "real" numbers streaming will be a much more viable option.

[barnabas1969]

I don't think that streaming will ever become a viable option. The cable companies provide the Internet service. They want your money. Don't think for a second that they will let you continue to download unlimited content without paying the piper. Monthly download caps are coming your way soon.

[slowbiscuit]

Yep, already happening on Comcast - they are reintroducing a 300GB cap (with every extra 50GB costing you $10 more) with a slow rollout to avoid widespread criticism. Just showed up in the ATL in December, been in other cities and areas before that.

They are going to make sure that they get their money one way or the other and the FCC/Congress really don't give a crap that we don't have viable alternatives. Very understandable when you realize how the revolving door and campaign payoffs work of course.

[IownFIVEechos]

Hopefully you can monitor your usage and put a stop on it if you hit a limit like a cell phone?

[barnabas1969]

Google Fiber would be nice, but there are no plans to roll it out in my area. There used to be a wireless Internet service in my area, but I can't remember what it was called. It required line of sight to their transmitter, which was somewhere northwest of my location. They had a diamond shaped flat antenna that you had to mount so that it was pointed at their transmitter. Anyone have an idea if this type of thing still exists?

[IownFIVEechos]

Very understandable when you realize how the revolving door and campaign payoffs work of course.

"Comcast ranks among the top-ten corporate influencers in Washington, having spent $18.8 million on lobbying last year, according to the nonpartisan Center for Responsive Politics."

http://tv.yahoo.com/news/comcast-lobbyi ... ector.html

[STC]

Lobbying is really a form of bribery. A very corrupt mechanism IMO.

We give you money, you do what we say, capiche?

[IownFIVEechos]

This describes Time Warners Cap methods and plans.

http://finance.yahoo.com/news/time-warn ... 08612.html

[Dragonfly]

Hopefully you can monitor your usage and put a stop on it if you hit a limit like a cell phone?

Yep. Thanks to the handy-dandy Comcast Usage Meter:http://usagemeterapp.comcast.net/faq.html