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The Latest CableCARD Updates from the FCC

The FCC met today to discuss several items – among them, the fate of CableCARD technology. Here are the provisions adopted by the Commission specific to CableCARD devices. From today’s press release on “unleash(ing) video innovation and consumer choice,” the FCC is putting forth rules to:

  1. Ensure that retail devices have access to all video programming that is prescheduled by the programming provider
  2. Make CableCARD pricing and billing more transparent
  3. Streamline CableCARD installations
  4. Streamline requirements for manufacturers who build CableCARD devices

The history of the CableCARD has been a long, and somewhat sordid affair. You can find context with a Motorola perspective under the CableCARD category of posts on this site – from a review of the original Seven-Oh-Seven mandate to more recent Motorola thoughts on how the FCC should handle CableCARD going forward.

CableCARD, FireWire, and FCC Mandates

Regulatory oversight is a very important check in our government system of checks and balances. However, that doesn’t mean it always works. Two cable industry milestones in the last week illustrate this point vividly.

First, the NCTA reported that the largest US cablecos have now deployed more than 21 million set-tops with embedded CableCARDs. (via Light Reading Cable) Despite that fact, the FCC’s CableCARD mandate is widely considered a failure, and the agency is actively looking for potential alternatives. There is plenty of debate over why the CableCARD hasn’t been successful, but the biggest reason may be that it was just too hard to deploy the technology quickly enough to keep up with other advances in the market.

Example #2: Last week the FCC withdrew another mandate requiring cable operators to include a FireWire connector, or 1394 port, on all set-tops. The reason? Nobody uses FireWire. Industry veteran Leslie Ellis explains it very succinctly in a post over at Multichannel News. After pouring $400 million into 1394 deployments, cable operators have clear evidence that HDMI is the connector people really want.

Ask any cable engineer how many subscribers requested 1394, since the mandate. I did, back in March, of the CTO of a cable company with about 5 million subscribers. His answer? Five. (Five. Out of 5 million. In five years.)

There is a natural conclusion to be reached from these examples. Any further FCC mandates in the cable industry – think home gateway device – should be handed down with caution. The best intentions don’t always produce the best results.

FCC Proposals: The Devil is In the Details

The Federal Communications Commission held an open meeting today to discuss many of the proposals the agency put forth in the recently released National Broadband Plan. Although the video stream of the proceedings was choppy, I did manage to catch bits and pieces of the event. For each agenda item, spokespeople came forward to provide background information, and a request that the FCC continue with plans for a Notice of Inquiry, and/or a Notice of Proposed Rule Making. On all six agenda items (see list below), the FCC voted to continue with an NOI and/or an NPRM.

Continued investigation is a good thing, especially because, as is often the case with regulatory proposals, the devil is in the details. For example, the FCC has launched an inquiry on a proposed all-MVPD gateway device as a means to spur more competition in the retail video device market. But how “smart” or “dumb” should that gateway be? How much will it cost? (The cable industry incurred huge costs with the CableCARD mandate.) How will it affect innovation in the MVPD network? Given the dynamic nature of the market, will today’s regulations still be relevant and meaningful by the time the industry has had a chance to implement them?

It’s also important to note that there’s a huge amount of innovation going on right now – much of it a direct result of competition – that shouldn’t be ignored. This includes advances in 3D TV, TV Everywhere, and interactive television. That’s not to say it’s been a smooth ride, or that it couldn’t be smoother, but progress in the industry shouldn’t be understated.

FCC Agenda items:

  1. Universal Service Fund reform
  2. Wireless data roaming
  3. Commercial availability of video devices
  4. CableCARDs
  5. Ability of broadband infrastructure to withstand natural disasters
  6. Cybersecurity

CableCARD Rules Set to Change

It was only three years ago when the Seven-Oh-Seven deadline hit, and here we are examining the CableCARD mandate once again. The FCC is opening up a notice of proposed rule making in order to create new CableCARD policy. It didn’t go so swimmingly last time, so I thought it worth taking a look back at CableCARD implementation three years ago.

Here’s a Q&A I ran with Motorola’s Rob Folk back in 2007. It’s a good review of how much went into getting cable equipment CableCARD-compliant. The process is worth remembering in both technical and policy discussions going forward.

2007 Interview with Motorola executive Rob Folk

Q: First off, when Motorola introduced CableCARD-compliant set-tops at CES last January, there wasn’t one new box, but a whole new product line. Couldn’t you have simplified matters by sticking with one new set-top model?

Rob: Unfortunately not. That’s one part of why this transition was such a big job. As cable operators moved over to the separable security model, they certainly weren’t willing to sacrifice the range of options they had come to expect with embedded-security set-tops. When we launched the DCH line, we needed standard-definition and high-def products, DVRs and non-DVRs, analog-digital set-tops and all-digital set-tops. While we were at it, we also created a new external set-top design. It was a massive undertaking.

Q: The point of introducing CableCARD-compliant or host set-tops was to separate out the sophisticated security component of the hardware. What were some of the technical challenges in accomplishing that?

Rob: It sounds simple, the idea that you’re just removing a feature, but it was incredibly complicated. The security chips have been an integral part of set-tops since their inception. In ripping that component off the board, we had to create a new interface through which operators could literally insert encryption technology via an external card. Not only that, but the interface had to be capable of taking a standardized package, meeting CableLabs’ specifications, i.e. a CableCARD. All of that added a lot of complexity, and there was pressure too in moving away from technology that had worked so well for so long.

Q: There are retail devices on the market that take CableCARDS, so other folks have mastered this type of challenge before. How are Motorola’s Host set-tops different from what’s available at retail?

Rob: The key difference is Motorola’s Host set-tops had to be validated against all of the applications that the service providers already had deployed in the field on the embedded security set-tops. Retail set-tops don’t have all of the same functionality as cable set-tops at this point. Ensuring that the Host set-tops supported transparently the same interactive applications as the embedded-security products took a great deal of effort.

Q: I know not all of the engineering for the CableCARD transition happened in the set-tops. What else had to be done?

Rob: There was a lot of on-site preparation work done with our customers. We did system upgrades at the headend, including working on support for interactive applications. Operators needed the latest application versions and platform software to implement the switchover. Then there were the more mundane aspects of the transition like making changes to the subscriber billing systems. It was a very detailed process.

From an overall education perspective, Motorola did a number of programs to support the operators with this transition including: seminars, a webinar, a whitepaper and an in-depth training program.

Q: I know that Motorola’s embedded-security set-tops have not gone away completely. How does that impact the current situation?

Rob: Our earlier line of set-tops has not gone away at all. Those products are still being used by operators outside the US and by operators in the US who received FCC waivers. And you’re right; the fact that so many different set-tops are deployed does have an impact on our work. We maintain technical support teams for all of our products in the field.

Q: Last question, how have operators and consumers responded since the transition took place?

Rob: Deployments have gone well. We’ve gotten a lot of positive feedback and comments from the operators. I think the key indicator is that operators are now looking at these Host set-tops just like any other set-tops. The specialness has gone away, which is a good thing when you’re trying to make a transition as seamless as possible.

As far as consumers go, there is a fair amount of confusion about what actually happened when the CableCARD deadline passed. I know we get questions through the Motorola website about purchasing Motorola set-tops at retail. In reality, the Seven-Oh-Seven deadline was a change for operators, but there was no change for consumers. Motorola makes set-tops for service providers, but other retail devices have been supported for several years now. And the Motorola host products are designed to provide the same functionality as earlier embedded-security set-tops.

The National Broadband Plan

The FCC released its national broadband plan today, and the Web is buzzing with commentary and analysis. Motorola hasn’t put out any public comment on the plan yet, but I thought it would be worthwhile to publish a couple of excerpts from an earlier Motorola filing during the FCC information-gathering period. See below for two of Motorola’s recommendations made in a filing last December.


…The Public Notice states that the “Commission’s CableCARD rules have resulted in limited success in developing a retail market for navigation devices.” We agree and support recent calls for an NOI to examine fresh approaches to addressing the future of navigation devices in the MVPD marketplace. Cable operators and their customers have incurred substantial costs as a result of CableCARD requirements. Beyond the costs associated with developing the CableCARD solution and redesigning headends and equipment to support CableCARDs, cable operators have now deployed over 17.7 million CableCARD-equipped set-top boxes from a wide and growing number of suppliers, including Motorola, Pace, Samsung, Panasonic, Cisco, Evolution Broadband, and TiVo. In contrast, on the retail side of the ledger, only 456,000 CableCARDs have been deployed in retail navigation devices. This disparity makes crystal clear that the costs of the current regulatory regime — which may now be approaching $1 billion — far outweigh any public interest benefits…


…IP enables operators and suppliers to reduce costs through the elimination of unnecessary functionalities (such as redundant set-top box tuners) and accelerate the development and deployment of interactive applications (such as widgets and other interactive features). Motorola strongly supports the deployment of IP networks. We provide IP and hybrid QAM/IP set-top boxes to MVPDs, as well as the network equipment that supports IP video distribution. Motorola also is developing cutting-edge products that will deliver the next generation of IP video service. For example, Motorola is working on solutions with its IPTV and other set-top boxes that will enable the delivery of 3-D television service.

So Many Different Kinds of Security

When people think about security and IP traffic, they typically think about digital rights management (DRM), and all the attendant connotations that come with it. However, there are really two different types of security to consider: DRM that secures the content itself, and network security, which secures the transport of IP packets.

In the second category, Motorola announced today that the company has achieved “Manufacturer Certificate Authority” status from CableLabs for DOCSIS 3.0 products. What that means is Motorola is certified to provide security keys and certificates for all DOCSIS equipment, from DOCSIS 1.0 through DOCSIS 3.0.

Aside from the fact that security in DOCSIS systems is important, the news is interesting in the context of Motorola’s history as a provider of conditional access (CA) technology. On the broadband side of the business, most folks think of Motorola for its set-tops. What is talked about less frequently in mainstream discussions is the conditional access security technology that makes those set-tops viable in an industry obsessed with protecting its content. The CA technology used to be embedded in set-tops, but is now effectively separated through the deployment of CableCARDs. In any case, it is a huge piece of what made Motorola successful in the cable world.

On the DOCSIS front (mainly modems today) security is certainly as important it is in set-tops. For the entertainment industry it is becoming even more so as more content is delivered over IP. How should content providers deliver that security? It certainly starts with the network.

The NCTA on Switched Digital Video and CableCARDs

The NCTA conducted an interesting form of outreach last week. After apparently reading a number of unflattering and possibly inaccurate reports on switched digital video’s impact on CableCARD retail devices, the association put out the word that it would conduct a conference call briefing for any bloggers and journalists interested in discussing the topic. The call happened on Friday and it was truly a party of industry trade folk. Among the people I know were on the call: EngadgetHD, Cable Digital News, Multichannel News, IP and Democracy, TV Technology, Envisioneering, HD Guru, Gizmo Lovers, and Zatz Not Funny. And other than someone who treated us all to loud hold music (participants’ phones were not muted), everyone behaved pretty well.

Digression aside, there wasn’t much in the way of news on the call, but I still applaud the NCTA for holding an open forum. More interesting to me than the NCTA’s presentation were the questions that came after it. Here’s a sample (paraphrased) with the NCTA’s answers (also paraphrased). The entire recorded conference call is also available. Call 1-800-475-6701 and enter access code 920821.

Sampling of Q&As from the 4/25 NCTA conference call:

Q: Given the issue of having no 2-way communications in today’s retail CableCARD devices, why doesn’t the cable industry support DCR+?
A: The same problem exists with DCR+ as with one-way CableCARD devices in that consumers don’t get access to all the cable services they expect. DCR+, for example, won’t receive certain existing services like Time Warner’s StartOver and LookBack, not to mention future applications.

Q: What assurance can you give that Tru2way won’t be superseded by something else in three or four years, making consumer hardware obsolete?
A: Cable operators are putting Tru2way in their own devices so they’re not likely render Tru2way obsolete when they have so many set-tops with it in the field.

Q: Given the issues with switched digital video, why doesn’t the cable industry just move to all-digital like Verizon to reclaim bandwidth?
A: The cable is industry is much bigger than Verizon with a lot more existing analog customers. The transition is going to be much more difficult.

Q: PC companies and portable media player companies have difficulty with the CableLabs certification process, particularly when their headquarters are in places like Shanghai, rather than Boulder, Colorado. How do companies figure out how to work with CableLabs?
A: The CableLabs licensing and certification process is open to anyone who wants to participate, and CableLabs wants more companies to get involved. With all the innovation and energy from some of these CE companies, it seems it would be possible for them to make contact with CableLabs without getting 150 people in a room for a CableLabs event in Shanghai. Several cable industry CEOs have even gone to Japan and Korea to reach out to the Asian CE market. It could be a two-way street.

Q: Will there be any kind of requirement for operators to tell subscribers which channels will be on a switched network?
A: Yes, generally operators have to give thirty-day notice when there’s any kind of programming change.