I noticed something odd today, three nearly identical comments filed on FCC proceeding 97-80 (1,2,3). I knew someone must be coordinating the comments, so I searched, and sure enough, it if an effort organized by the EFF.
The body of their suggested letter reads:
As a consumer interested in protecting competition, innovation, and legitimate use of cable TV content, I urge you to refuse requests for waivers of 47 CFR 76.1204(a)(1) by NCTA, Charter, Verizon, and all other cable providers. The FCC’s integration ban, which in effect requires cable companies to integrate CableCARDs into their own set-top boxes, remains good policy today.
Now ten years after the Telecommunications Act of 1996, cable companies have dragged their feet long enough on competitive alternatives to proprietary set-top boxes, thus hampering innovation and harming consumers. The integration ban will also help market competition prevent further restrictions on cable subscribers’ ability to make legitimate use of recorded content.
By adopting content protection limits (encoding rules) in docket no. 97-80, the Commission recognized the importance of allowing consumers to make certain uses of TV content, regardless of a particular cable provider’s or copyright holder’s wishes. With competition spurred on by the integration ban, consumers would have the freedom to choose the least restrictive cable-compatible device available. The CableCARD standard already prescribes restrictions that harm consumers by limiting non-infringing uses, and such restrictions will get even worse if cable providers’ set-top boxes are unchecked by competition.
Please refuse requests for waivers of 47 CFR 76.1204(a)(1).
I decided to toss my support behind this effort as well, and I inserted some text of my own:
As a tech blogger I’ve followed the evolution of CableCARD closely, and it has been a string of disappointments. Between the delays, the limitations on what UDCPs may support, the unpalatable requirements of OCAP/tru2way which discouraged CE vendors, the broken promise to fully deploy tru2way by July 2009 (July 2010 for Charter – it is now August 2011), SDV and Tuning Adapters, MVPDs having to be forced to allow self-installs and to use fair pricing, etc., etc., they have an extremely poor track record.
As an IT professional I know the value in “eating your own dog food”. When cable MSOs were required to begin using CableCARD in their own devices, overall support improved. Of course, they took shortcuts by pre-pairing the cards and permanently installing them in their STBs, so they didn’t need to use the same installation and activation process, but it still exercised the infrastructure. They should be forced to continue using CableCARD until such time as a new system, such as AllVid, is available to *all* devices.
I believe that cable MSOs should be required to use the same systems available to consumer electronics companies. This helps to force them to improve the systems for their own sake, and not neglect them unfairly. I think it would also put pressure on them to work toward a better solution, like AllVid, which would benefit all parties – especially consumers. If they’re allowed to roll their own solutions, independent of what is available to CE vendors, they have little to no incentive to adopted unified, open standards and robust systems for CE products.