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In Comcast’s turn to blast the FCC’s proposal to create new rules aimed at spurring a retail market for set-top boxes, the MSO said that, if enacted, such rules threaten to “stifle TV innovation.”

The proposal, led by FCC chairman Tom Wheeler, “would require satellite and cable TV providers to disaggregate or separate their services so that a few companies could repackage them as their own without negotiation for content rights like everybody else in the market does today,” Mark Hess Comcast’s SVP, office of the CTO, wrote Thursday in this blog post.

Hess had a front seat on FCC-appointed technical advisory committee formed a year ago to pursue potential downloadable successors to the CableCARD, and came up with multiple paths – an apps-based model favored by the cable industry, and another AllVid-style approach that discusses the idea of a "virtual headend." 

Earlier today, Wheeler said assertions that the proposal is akin to an earlier proposed AllVid regime are incorrect, and that it would not create the need for a second box and did not affect MVPD programming deals or how operators tier, bundle or price video services.

Hess argued that Wheeler’s “proposal, like prior federal government technology mandates, would impose costs on consumers, adversely impact the creation of high-quality content, and chill innovation.  It also flies in the face of the rapid changes that are occurring in the marketplace and benefitting consumers.”

Hess also echoed the arguments already laid out by the cable industry, holding that the market for competitive video devices is proliferating without government meddling, citing the rise of OTT services from Netflix and Amazon, multichannel alternatives such as Sony’s PlayStation Vue and Dish Network’s Sling TV.

As proof of the impact of the current state of competition, Hess pointed to X1, Comcast’s next-gen, IP-capable video platform, noting that it supports apps for retail mobile devices.

“Given these exciting, pro-consumer marketplace developments, it is perplexing that the FCC is now considering a proposal that would impose new government technology mandates on satellite and cable TV providers with the purported goal of promoting device options for consumers,” he wrote.

Hess also argued that the FCC’s track record on tech mandates is “has been less than stellar,” citing examples such as the CableCARD, which failed to create a vibrant retail market for set-tops and cable-ready TVs, and a mandate for 1394 outputs in set-tops “even after it was clear that other outputs had won out in the marketplace.” The FCC scuttled 1394 "FireWire" interface requirements in cable HD set-tops in 2010, as long as the boxes provided alternative access to content over IP home networks.

The nine largest incumbent U.S. cable operators have deployed 54 million CableCARDs in MSO-supplied set-tops versus just 618,000 of the removable security modules in TiVo boxes, TVs and other retail products that sport a CableCARD slot, per the National Cable & Telecommunications Association’s latest report to the FCC.

That’s an increase of 1 million versus the 53 million CableCARDs that those same operators had deployed when the NCTA filed its previous report in August, and a mere 1,000 more CableCARDs in retail devices.

The NCTA has been issuing these reports since the FCC’s ban on integrated security set-tops took effect in July 2007. Thepassing of the STELAR Act, which became law on Dec. 4, 2014, activated a provision that will sunset the FCC’s current ban on integrated security set-tops after a year.

The FCC has since been focusing on a potential successor to the CableCARD based on downloadable security systems that could be applied to cable operators as well as other MVPDs, including telcos and satellite TV providers.

As part of that pursuit, the FCC-appointed the Downloadable Security Technology Advisory Committee (DSTAC), which in August presented multiple non-CableCARD options, I ncluding an apps-based approach favored by cable operators and an AllVid-style approach favored by others, including Google, that discuss the implementation of a “virtual headend” and a government-specified gateway devices that can unite video from various MVPDs. http://www.multichannel.com/news/next-tv/fcc-group-presents-multiple-non-cablecard-paths/393305

Interested parties filed comments on the final DSTAC report in early October. A summary of those comments are available here. Reply comments are due Nov. 9, 2015. 

The FCC-appointed Downloadable Security Technical Advisory Committee (DSTAC)  provided multiple, possible paths to a post-CableCARD world, and, like its report, the responses that poured into the Commission docket on the matter were similarly divisive.

The DSTAC report included an apps-based proposal approach favored by cable operators and another AllVid-style approach, favored by companies such as Google, that discuss the implementation of a “virtual headend” and a government-specified gateway device capable of uniting video from various sources. It also covers an apps-based approach that would support competitive UIs.

The formation of the DSTAC in January followed the passing of the STELAR Act, legislation that will sunset the current set-top security integration ban in December 2015 and called on the FCC to take a look at a successor approach to the CableCARD that could spur the retail market for video navigation devices for not just cable operators, but other MVPDs.

The FCC Media Bureau  recently sought comments on the final DSTAC report, which came rolling in under the October 8 deadline. Reply comments are due Nov. 9, 2015. 

The FCC has not announced if it would follow with a larger Notice of Inquiry or a full Notice of Proposed Rulemaking on the matter. However, it does have plenty of arguments to weigh on each side – whether to stay its hand, or pursue a new mandate that would establish a successor to the original, cable-focused integrated set-top security ban that took effect in July 2007…and failed, quite miserably, to create a vibrant retail market for set-tops (at last count, the top nine incumbent U.S. cable operators had deployed about 53 million CableCARDs in MSO-supplied set-tops, compared to a comparatively paltry 617,000 in retail devices).

As reported yesterday, NCTA reiterated its view that the FCC reject calls to create new technology mandate, noting that the “apps revolution” has brought pay TV services to twice as many consumer video devices as there are set-top boxes currently in use. It also labeled the AllVid concept as “pure vaporware,” and warned against the pitfalls of allowing a system that disaggregates pay TV services.

Here’s a summary of several (but not all) comments submitted this round:

Google

Google is squarely in the AllVid/virtual headend camp.

In its comments, Google noted that it had to develop its own set-top equipment for video services provided by Google Fiber, and that “[u]nlike most set-top equipment, the Google Fiber devices and interfaces allow subscribers easily to switch between Google Fiber’s linear programming channels and online video options like VUDU, YouTube, and a Netflix account…The Commission should commence a rulemaking to ensure that all consumers enjoy these sorts of options.”

The app-based approach with operator-provided UI, Google said, would not assure a competitive retail market for navigation devices and that it would “lock consumers into having their video consumption experience framed and controlled entirely by the MVPD,” leaving little to no room for customization or innovation by third parties.

Comcast

Like the NCTA and its other cable industry constituents, Comcast favors the apps-based proposal, calling AllVid a “warmed over” and “flawed and unnecessary technology mandate” that “exceeds the Commission’s authority” and would go beyond Congress’s mandate in STELAR.

Comcast argued that AllVid would increase security risks, extend unnecessary costs to consumers, eat more power. Additionally, the MSO argued, it would require MVPDs to redesign their networks and break apart their services in a way that would let CE manufacturers “repackage with their own user interfaces, effectively turning MVPDs into wholesale content suppliers to these manufacturers (but without contractual privity or protections) and develop an undefined, new piece of on-premises equipment that customers would have to rent to enable access to MVPD service on an AllVid-compatible CE device.”

As for apps, Comcast said its Xfinity TV Go App, which today provides about 80 live channels and more than 22,000 VOD choices, has been downloaded more than 17.9 million times, an increase of 60% over the past seven months. Comcast also said Xfinity apps also provide Title VI protections (such as Emergency Alert Systems, closed captioning and consumer privacy protections).

Comcast also brought up its support of the Digital Living Network Alliance’s VidiPath initiative (subscription required), which lets MVPDs stream their services securely over the home network to other VidiPath-compatible, customer-owned devices through a downloaded MVPD app.

Update: Comcast also noted that it is developing an HTML5-based app with Encrypted Media Extensions (EME), which, it said, “would enable access to Xfinity service on compatible device platforms without the need for building customized native apps for every device platform.”

That approach, Comcast said, would help Comcast deliver services to smart TVs, retail set-tops and other TV-connected devices, which today “currently operate in much more fragmented markets using different operating systems.”  Comcast added that it’s also working towards supporting HTML5 with EME on its X1 platform, which will allow X1-capable set-top boxes will be able to support a wider range of third-party apps.

TiVo

TiVo reiterated that it’s a “longtime advocate for a replacement of the CableCARD standard with solutions that better reflect today’s marketplace and technology” and argued the FCC to build on the committees report and initiate a rulemaking.

TiVo noted that its new Bolt product, which supports pay TV, OTA and OTT video services, demonstrates the kind of innovation that the retail device market has brought to bear with the CableCARD, despite its “often cumbersome” installation process and historic issues with MVPD support for it.

“The availability of non-proprietary nationwide security solutions free cable operators to purchase set-top boxes from a variety of suppliers, rather than being locked in to purchasing set-top boxes from a single conditional access vendor,” TiVo argued.

And without a successor system, “smaller operators will again be locked into a single supplier of conditional access solutions on a system-by-system basis as they were prior to CableCARD,” TiVo said.

The company also argued that the apps-based approach, while “are no doubt welcome to consumers…do not measure up to the type of retail competition mandated by Section 629.”

EchoStar

EchoStar, the set-top and technology unit with corporate ties to Dish Network, said it “generally supports the conclusions set forth in the DSTAC Summary Report,” but warned that if the FCC decides to move forward it “must not oversimplify this complex technological and service delivery ecosystem, as doing so would likely lead to a regime that does not adequately reflect and protect the legitimate interests of all affected parties.”

EchoStar also highlighted that the pay TV industry is made up of one-way systems (like satellite TV) and two-way systems, and that the technical diversity of the industry will make it difficult to come up with a “one size fits all” approach.

Verimatrix

The maker of IPTV security for various types of providers said it has “solved the security aspects” that are similar to the problem presented to the DSTAC, noting that its platform supports multiple DRMs using downloadable software, but that it “does not favor forced standardization by government mandate at this level.”

“However, certain discrete elements and interfaces within an MVPDs security system can be standardized on a go-forward basis that would be helpful to competition and innovation without undue harm to security,” the company said. “We have these interfaces clearly identified in our solutions and are working on voluntary standardization of them in various fora. We will highlight these possible areas of standardization herein, but we do not propose that the FCC mandate them.”

Hauppauge Computer Works

Hauppauge advocates the pursuit of competitive interfaces and the virtual headend proposal and urged the FCC to move ahead on new rules.

“Apps are good, but you need to read the fine print,” it said, noting that there needs to be an API open to developers. Operator-provided UIs, the company added, are proprietary and can only be developed by select individuals and run on select TV systems.”

Public Knowledge

The group is in favor of the virtual headend proposal, and wants the FCC to take action and pursue a new rulemaking.

“After years of inaction, the Commission now has the chance to finally fulfil its statutory duty of promoting a competitive market for video navigation devices,” PK said. “The Commission should take that opportunity, and building on the DSTAC report’s ‘virtual head-end’ proposal, move quickly to a rulemaking proceeding that formalizes a new standard allowing differentiated devices to access and display MVPD content.”

PK held that the app proposal “would be a step back from the existing CableCARD system.”

Further, it isn’t buying cable’s disaggregation argument, holding that Congress envisioned that navigation could be separated by a different entity than the MVPD’s linear video offering.

“What the MVPDs characterize as ‘disaggregation’ is in fact the approach most consistent with  Congressional intent and the statutory scheme, which is why it is the approach already taken by the CableCARD system, which cable operators claim to support.”

American Cable Association

The group, which represents independent cable operators, urged the FCC to proceed with “great caution” before putting forth any new technology mandates. And the ACA argued against the AllVid approach and in favor of the apps-based proposal.

“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 Commission must eschew 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.”

“For traditional cable operators who have many navigation devices in the field capable only of receiving QAM signals, the transition to IP delivery necessarily will occur over a period of years,” the ACA said. “Market forces will determine the precise pace of the transition so that small cable operators can afford to make the transition in an orderly, non-disruptive, and non-economically burdensome manner.”

The device-based approach would require “millions of dollars of network upgrades in a short span of time.”

Sony Electronics

Any government-mandated solution “should be made available to third-party device manufacturers on reasonable and non-discriminatory terms” and enable consumers to  access “the full array of MVPD services for which they have subscribed,” Sony Electronics said in its comments. “It should not enable MVPDs to choose winners and losers among device manufacturers, and it should not enable device manufacturers to pick winners and losers among MVPDs.”

Amazon

Amazon said the DSTAC report agreed that downloadable content security is achievable, but that control over navigation devices’ user interfaces ““is a question of policy, not content security.”

“Although important to competition and improved user experiences, the question of which party controls a device’s UI falls outside of the scope of content security, as the DSTAC members agree,” Amazon noted.

Arris

Arris, a top maker of set-tops that’s trying to acquire U.K.-based Pace plc, said it supports the apps-based proposal.

“As detailed in the DSTAC Report, the apps-based approach is built on a track record of marketplace success in enabling consumer access to a widening array of connected devices,” Arris said. “In contrast, an AllVid-type approach would be unduly burdensome on MVPDs and their customers and should be avoided.”

Consumers Union

The Consumers Union argued that consumers “have no practical alternatives to renting set-top boxes that can access MVPD content…The time is ripe for the Commission to develop a universally relied upon standard that ensures that design and licensing of technology is not controlled only by a few special interests.”

Nagra

Nagra told the FCC that the focus should be on security and, more precisely, on “downloadable security technology,” rather than “higher-layer and other functions which are ancillary to security.”

“We believe that solving the navigation, guide and meta-data problems will largely be solved as part of a well-reasoned security solution,” Nagra said. “We caution the Commission that attempting to comingle navigation issues with security issues yields a much more complicated discussion, and unnecessarily complicates the underlying (and significant) security challenges.”

Comptel

Comptel, which represents wireline and wireless providers in the broadband marketplace, said the development of online video distributor options “is good for consumers, for video competition, and for broadband deployment and adoption.”

But as long as incumbent cable operators control the development and distribution of set-top boxes, “they can deter consumers from accessing independent content over their set-top boxes and televisions,” it said, concluding that the FCC should move ahead with a rulemaking that will promote more retail competition for video navigation devices.

The Motion Picture Association of America

The Motion Picture Association of America (members include Walt Disney Studios Motion Pictures, Paramount Pictures Corp., Sony Pictures Entertainment Inc., Twentieth Century Fox Film Corp., Universal City Studios LLC, and Warner Bros. Entertainment Inc.) said its committed to providing content “through a wide variety of platforms and distributors.”

But when push comes to shove, the app-based proposal “will meet those goals.”

“By leveraging the strength of downloadable applications, this approach will offer device manufacturers a variety of ways to access video, as well as enable them to innovate and differentiate their equipment, without interfering with licensing agreements,” the MPAA said.

As for the competitive navigation proposal, it “makes no commitment to abide by content providers’ licensing terms,” the group said. “Third-parties could potentially seek to disassemble the programming, features, and functions offered over distribution services and selectively reassemble some of them for their own commercial exploitation. This could interfere with contracts, upset copyright law, and run afoul of the First and Fifth Amendments to the U.S. Constitution.”

That approach would likewise “impose significant costs, require the restructuring of networks, and necessitate standards yet to be developed. Thus, it fails the DSTAC’s charge to avoid solutions that are unduly burdensome.”

AT&T/DirecTV

Like other MVPDs, AT&T/DirecTV favors the apps-based proposal, holding that the alternative “would take the Commission beyond its statutory authority by exceeding the ‘device’ competition addressed by Section 629 of the Act and venturing into ‘service’ competition, which is not so addressed.”

They also feared that AllVid would deprive customers of the features and functionalities that customers expect from their MVPD service and pay for and “[blur] the lines of responsibility for addressing service problems and questions.”

DirecTV, the filing noted, uses RVU technology (which is similar in some ways to VidiPath) to provide a remote user interface to multiple televisions or other RVU-compliant retail devices, eliminating the need for additional set-top boxes in each room.

“Dumbing down MVPD services and stripping out their features – which the Device Proposal or other similar governmental technology mandate would do — is exactly the wrong approach in a marketplace where consumers already ubiquitously access MVPD and OVD content on a wide and growing array of retail devices,” they said.

DLNA

DLNA  put forth its own VidiPath approach as an alternative.

“The Commission should not (and need not) create a new system from scratch,” it said. “VidiPath is an existing solution that is proven and being deployed to market by a number of MVPDs.”

Reiterating its view, the NCTA urged the FCC to reject calls to create new technology mandate aimed at bringing pay TV programming to retail devices, noting that the “apps revolution” has brought pay TV services to twice as many consumer video devices as there are set-top boxes currently in use.

The FCC Media Bureau is seeking comments on the final report that the Commission-appointed Downloadable Security Technical Advisory Committee (DSTAC) submitted August 28. Reply comments are due Nov. 9, 2015. The FCC has not announced plans to follow with a larger Notice of Inquiry or a full Notice of Proposed Rulemaking on the matter.

The formation of the DSTAC in January followed the passing of the STELAR Act, legislation that will sunset the current set-top security integration ban in December 2015 and called on the FCC to take a look at a successor approach to the CableCARD that could spur the retail market for video navigation devices for not just cable operators, but other MVPDs.

The DSTAC report was far from unified, and included an apps-based approach favored by cable operators and another AllVid-style approach, favored by companies such as Google, that originally envisioned a government-specified gateway device uniting video from various sources.

The NCTA has labelled the latter concept as “pure vaporware,” while also complaining that it would “strip the programming out of the pay TV service a consumer purchases, mash up that service in any way the manufacturers wish, and brand it as their own service – with no responsibility to programmers or distributors to deliver the content as required by contract and programming licenses. “

“The “DSTAC’s Report underscores that there is no need for FCC technology mandates in a marketplace where consumers can access MVPD and OVD content on a wide and growing array of retail devices,” the NCTA said, noting that apps from pay TV providers have been downloaded over 56 million times for the iOS and Android platforms and are now available to more than 460 million video devices in the U.S., more than twice the number of set-top boxes currently in use.

CableLabs CTO Ralph Brown recently posted a blog that presents that tally in more detail.

Multichannel News will shed more light on the other filings and positions on the matter shortly. 

In a decision that calls into question the long-term future of Dish Network’s virtual client software for certain smart TVs and gaming consoles, the pay TV operator confirmed that the Virtual Joey is currently unavailable for purchase to new customers.

Existing customers can continue to use Virtual Joey, a spokesperson said. Dish declined to comment when asked if the company intends to phase out the Virtual Joey. Dish also has not announced if intends to launch a next-gen version of the client, which Dish had been offering for $7 per month.

The Virtual Joey enables the secure navigation of both linear TV and DVR recordings using HTML5. As a component of a whole-home solution, the Virtual Joey app is authenticated during connection to the associated Hopper HD-DVR device, and behaves like a traditional hardware-based Joey client device.

The Virtual Joey was one of several currently MVPD retail-focused features presented in a report (PDF) issued to the FCC on August 28 by the Downloadable Security Technology Advisory Committee (DSTAC), which advised the Commission on possible alternatives to the CableCARD that could be applied to a range of MVPDs and spark a more robust retail market for set-tops and other video devices. The DSTAC failed to come up with a unified recommendation, instead offering the FCC a variety of possible options.

Other MVPDs are using, or plan to use, different technologies to deliver their UIs and services securely to retail devices.

DirecTV has been focused on an approach based on RVU for “DirecTV Ready” TVs made by Samsung, Sony, Toshiba and LG that connect via the home network to a Genie HD-DVR.

Some major U.S. cable operators, including Comcast, Time Warner Cable and Cox Communications, have been getting behind VidiPath, a set of guidelines developed the Digital Living Network Alliance (DLNA) that identifies devices, including set-tops, consoles and tablets sold at retail, that support subscription TV content from cable operators and other types of MVPDs. At the INTX show in Chicago, a proof-of-concept demo (subscription required) showed Comcast’s X1 platform running on several retail devices, including TVs from Samsung and LG, without the need for a separate set-top box.

When Apple CEO Tim Cook declared that “We believe the future of television is apps” as he introduced the new Apple TV yesterday, it was music to the ears of the National Cable & Telecommunications Association.

“Must say that I agree with Tim Cook. #AppleEvent,” NCTA chairman Michael Powell tweeted during the event, pairing it with a pic of Cook on stage with the words “The future of TV is apps” behind him.

John  Solit, NCTA’s senior director of digital strategy, took that endorsement a step further today in a blog post about the state of the retail market for video devices and, of course, the new Apple TV and its new new operating system and Apple’s decision to go with an open approach that will likely bring a flood of apps to the platform.

“It has been for some time and the way we see it, the new Apple TV, while a great conduit to cable programming via iTunes download and specialized programmer and operator apps, is direct competition,” Solit wrote. “But this kind of competitive innovation is opening up a world of possibilities – especially for app makers. The TV experience is constantly changing and innovation in the app space is where it’s changing the fastest and to the greatest effect.  Apple CEO Tim Cook said it most succinctly when he proclaimed, ‘The future of TV is apps.’  We couldn’t agree more.”

He then listed examples such as HBO Go, Watch ESPN and apps from Comcast and TWC. “These apps have been downloaded millions of times and are available on 460 million connected video devices – twice the number of leased set-top boxes.”

That the NCTA likes what Apple’s saying with respect to apps also isn’t a huge surprise, as it fits with the cable industry’s position with respect to the specter of possible new removable video security rules that could succeed the CableCARD, focus on downloadable options and apply to different types of MVPDs, not just cable operators.

The FCC-appointed Downloadable Security Technical Advisory Committee (DSTAC) submitted proposals late last month that were anything but unified. Among the proposals was an app-based approach that’s favored by the cable industry, which has argued that natural market forces, not more mandates, should pave the path forward with respect to retail set-tops and video devices.  You can read the whole thing here. 

The  FCC Media Bureau is currently seeking public comment on the DSTAC report.

The FCC Media Bureau announced Monday that it is seeking public comments on the final report that the Commission-appointed Downloadable Security Technical Advisory Committee (DSTAC) submitted last Friday (August 28).

The FCC, which also posted the six-page report here, said comments are due Oct. 8, 2015, with reply comments due Nov. 9, 2015. Docket 15-64 has been setup for the process. The FCC has not announced plans to follow with a larger Notice of Inquiry or a full Notice of Proposed Rulemaking on the matter.

“By this Public Notice, the Media Bureau seeks comment on the DSTAC’s report, including the four Working Group reports attached to the final report, and how it should inform the Commission’s obligations under Section 629 of the Communications Act,” the FCC Media Bureau noted.

The formation of the DSTAC in January followed the passing of the STELAR Act, legislation that will sunset the current set-top security integration ban in December 2015 and called on the FCC to take a look at a successor approach to the CableCARD that could spur the retail market for video navigation devices for not just cable operators, but other MVPDs.

The DSTAC report presents two security proposals -- one that relies on HTML-5 security APIs and associated encrypted media extensions  for distribution in the home and via the cloud, and a “virtual headend” approach whereby the network security and condition access is handled in the cloud with interfaces between the operator and the device using protection such as DTCP-IP.

The scope of DSTAC’s work also was not unified, as it spanned multiple  non-security and control plane components. A proposed app-based approach would retain the MVPD’s user interface as services are made available on IP-connected retail devices such as gaming consoles, tablets and PCs.  Another approach factors in competitive navigation/UIs that empower CE companies, such as TiVo, to create and implement their own guides.

The Consumer Video Choice Coalition -- a group whose membership includes CCIA, COMPTEL,  Public Knowledge;  Ceton, Google, Hauppauge, SiliconDust, TiVo and Vizio – applauded the DSTAC’s work and the  FCC’s decision to put out its call for public comment. The CVCC also wants the FCC to follow with policies that would lead to a vibrant market for set-tops and other video devices.

"The DSTAC process was productive, in that it showed that the disagreement between cable companies and others about the set-top box market is not about what technologies are possible, but what outcome the FCC should work for,” the group said, in a statement. “ The Consumer Video Choice Coalition believes that the FCC should adopt policies that are most likely to lead to a competitive set-top box marketplace, where consumers can choose from a variety of devices at different price points and with different feature sets, and no longer have to rent outdated devices from their TV provider.”

The National Cable & Telecommunications Association also was generally pleased with the DSTAC report, but was not wild about the potential return of an AllVid proposal that originally envisioned a government-specified gateway device uniting video from various sources.

"Regrettably, the report veers off course by including a controversial proposal to place a burdensome technology mandate on MVPDs known as AllVid," NCTA said in a statement released late last week. "This approach could jeopardize consumer protections including privacy, emergency alerts, parental controls, and inhibit innovation by allowing the government to dictate the way video content is delivered to consumers." 

As expected, an FCC-appointed committee on Friday presented the Commission with multiple paths toward a post-CableCARD world for retail video devices, including downloadable video security options that would allow for competitive user interfaces.

Formed in January, the Downloadable Security Technology Advisory Committee (DSTAC) provided its recommendations to the FCC a week ahead of a September 4 deadline. The DSTAC came together following the passing of the STELAR Act, legislation that will sunset the current set-top security integration ban in December 2015 and called on the FCC to take a look at a successor approach that could spur the retail market for video navigation devices for not just cable operators, but other MVPDs.

The CableCARD regime has failed miserably with respect to sparking a robust market for cable-ready retail devices. The NCTA, in its last report to the FCC on the matter, said the top nine incumbent U.S. cable operators had deployed about 53 million CableCARDs in MSO-supplied set-tops since ban on integrated security took effect in July 2007, versus 617,000 CableCARD modules that were deployed in TiVo boxes, TVs and other retail products with CableCARD slots.

For the DSTAC, the big trick is to provide recommendations that could achieve a downloadable, platform-neutral system without being “unduly burdensome” while also applying to MVPDs that use a wide range of access technologies and proprietary video security and conditional access systems.

The DSTAC report, at six pages, has yet to be released (the FCC did not announce when it would make them public), but two members of the committee – Jay Rolls, SVP and CTO of Charter Communications; and Milo Medin, VP of access services at Google, provided a summarized view of the group's findings.

While the final recommendations offer multiple paths that could be mixed and matched to achieve the goals of the initiative, Rolls said the DSTAC did find agreement on several points. For example, the group recognized that MVPD networks are diverse and varied. “We all agree that you don’t want to overhaul those networks just to accommodate a brand new security system.”

He also said the proposals also did not recommend a solution based on “common reliance,” which is a concept whereby operator-supplied equipment uses the same security system as retail devices to receive MVPD services.  “That was deemed not to be necessary,” Rolls said.

The DSTAC also agreed that its recommendations should center around IP protocol, whether delivered from the MVPD or by a product in the home, and that the MVPD must retain control of the downloadable element. “Security is a very sensitive topic and needs to be very tightly controlled,” he said.

On the security end, there were two proposals – one that relies on HTML-5 security APIs and associated encrypted media extensions  for distribution in the home and via the cloud, and a “virtual headend” approach whereby the network security and condition access is handled in the cloud with interfaces between the operator and the device using protection such as DTCP-IP.

The scope of DSTAC’s work also was not unified, as it spanned multiple  non-security and control plane components.

A proposed app-based approach would retain the MVPD’s user interface as services are made available on IP-connected retail devices such as gaming consoles, tablets and PCs. MVPDs use or plan to use various methods for that, including DLNA’s VidiPath approach that is resonating with cable operators, RVU (in use by DirecTV), and the technology Dish Network is using for its Virtual Joey app.

Another approach factors in competitive navigation/UIs that empower CE companies, such as TiVo, to create and implement their own guides. That work focused on three primary interfaces – service discovery, entitlement information (content a consumer has rights to access); and content delivery (whether it allows for live TV, on demand or cloud DVR streams, or a mix of them). The approach also factors in different DRM approaches and the transfer of metadata to deliver navigation/interfaces that consumers can digest, Medin explained.

The DSTAC suggests that the different proposals could be combined in different ways to achieve the goals of creating a vibrant market for retail video devices that can support MVPD services. 

Rolls called the DSTAC exercise “truly a team effort,” while acknowledging that the recommendations were not finalized without some lively discussion. “We weren’t clawing each other’s eyes out. It was a very civil debate,” he said.

“Engineers are very good at solving problems but the definition of the problem matters a whole lot,” Medin said.

Next steps will include the publishing of the report itself. The FCC has not said how it might act on the DSTAC proposals, and if the Commission might follow with a Notice of Inquiry or a full Notice of Proposed Rulemaking.

If the FCC moves ahead on a rulemaking, Evolution Digital, a supplier of set-tops and video software mostly to tier 2/3 MVPDs, suggested in a letter to the FCC on August 21 that the Commission should exempt small operators as such rules could be “unduly burdensome” from a financial and engineering perspective partly because it would force them to embark on IP video transitions prematurely.

The FCC has yet to decide if it will pursue new separable video security rules that would succeed the CableCARD and apply to all MVPDs, but a vendor that works with many tier 2/3 MSOs has urged the Commission to give special consideration to smaller operators if it ultimately decides to pull the trigger on such an initiative.  

Evolution Digital, a maker of set-tops and video software aimed at helping cable operators transition to IP-based platforms, argued that smaller operators would have difficulty carrying the financial burden required to implement IP-based solutions prematurely, and that if the FCC does go for a rulemaking, it should be applied to larger MVPDs that have access to more financial and engineering resources.

Evolution Digital presented its argument in a letter to the FCC dated August 21 that was co-authored by Brent Smith, CTO of Evolution Digital, and Eric Hybertson, Evolution’s senior director of product engineering. Smith is a member of the Downloadable Security Technology Advisory Committee (DSTAC), the FCC-appointed group that will present its recommendations to the Commission tomorrow (August 28).  Hybertson is Smith’s designated alternate to the DSTAC.

While Evolution is helping small- and mid-sized operators transition their networks and CPE devices to IP, “the economics of rural cable require them to take a more cautious and financially conservative approach," Smith and Hybertson wrote. 

They recommended that the FCC exclude them from any rulemaking that would “unduly burden them to implement IP-based video solutions before they are capable of doing so.”

As a precedent in this area, they cited the FCC 12-126 rulemaking that exempted smaller operators from having to support IP-enabled devices to ensure compatibility between cable service and CE equipment, but did require commitments from the six largest incumbent cable operators.

Evolution suggested, in light of recent MVPD consolidation (i.e. Charter’s proposed acquisitions of Time Warner Cable and Bright House Networks), that the FCC limit any future rulemaking to the top four incumbent U.S. MVPDs (post-deal, that would be: Comcast, Charter, Cox Communications and Cablevision). Post-deal, those MSOs would represent 86% of all U.S. cable subs.

The DSTAC, formed in January after the passing of the STELAR Act, legislation that will sunset the current set-top security integration ban in December 2015, has been chewing on potential downloadable video security approaches that could succeed the CableCARD and apply to not just cable operators, but also to telcos and satellite TV providers.

The DSTAC is tasked to file its recommendations to the FCC by Sept. 4; it will present them tomorrow.

Heading into that meeting, the group has been challenged to come together on a unified proposal (subscription required) as two different angles have surfaced. 

The first proposal, “WG3 HTML5 Security APIs,” abstracts security for applications to run on consumer devices, which Evolution argues, “is not viable for any MVPD, regardless of size” and that it would force small cable operators to implement a second scenario – IP simulcast.

IP simulcast, Evolution said, is unduly burdensome to smaller operators because it would require additional spectrum and that it would require them to support a format (and additional equipment and processes) that is in addition to the original three formats – analog NTSC transport, digital QAM transport protected by legacy security, and TV Everywhere apps that rely on security that is proprietary to each app.

Adding spectrum to accommodate another format (IP simulcast) is cost prohibitive for small operators, Evolution said, noting that the costs could run into the tens or hundreds of millions of dollars and “put many of the smaller operators out of business.”

If the FCC ends up going with rules that apply the WG3 HTML5 Security APIs Proposal,  Evolution said, smaller operators should be given a waiver.

The other DSTAC proposal – the “Virtual Headend System” – requires services to be streamed in IP – either via the operator’s access network (the cloud) or a “local cloud” that makes that conversion using an in-home device.  

The cloud delivery option, Evolution said, requires IP simulcast, which, as it already argued, is a non-starter for smaller ops. As for the local cloud option, that’s similar to an AllVid proposal that the cable industry has rejected. But if the FCC ultimately goes with a rulemaking centered on the Virtual Headend System, Evolution said, the Commission should also provide small ops with a “complete waiver.”

The fireworks start tomorrow at 10 a.m. ET. 

Though consensus has been fleeting, an FCC-appointed committee is slated this week to present its recommendations for a downloadable video security system that could ultimately succeed the CableCARD.

That group – the Downloadable Security Technology Advisory Committee (DSTAC) – is scheduled to present its final summary report to the Commission on Friday (August 28). The 90-minute rendezvous will be get underway at 10 a.m. ET, and will be streamed live here.

The DSTAC was formed in January after the passing of the STELAR Act, legislation that will sunset the current set-top security integration ban in December 2015, and calls on the FCC to pursue a downloadable alternative to the CableCARD. The DSTAC is to file its recommendations to the FCC by Sept. 4.

It’s unknown what the FCC will do next, including whether it will follow with a Notice of Inquiry, a Notice of Proposed Rulemaking, or simply sit idle.

The DSTAC last met on August 4 (subscription required), and it was clearly apparent that the group would be challenged to come together on a unified proposal. 

The meeting focused on multiple technology proposals that attempt to establish platform-neutral video security approaches to support third-party retail devices and work with various multichannel video programming distributors, including cable operators, telcos and satellite-TV providers. The group has had trouble agreeing on a common system that can apply to all MVPDs while taking into account a multitude of legacy platforms, as well as newer IP-based delivery systems.

On the IP side two proposals have been pushed forward. One, presented by Public Knowledge, centers on the concept of a cloud-based “virtual headend,” where the heavy lifting would be done before encrypted content is delivered to a third-party set-top or other type of video device.

To address the legacy issue presented by services that still rely on QAM/MPEG-based video transport, the proposal also discusses the use of a discrete device that would essentially convert the legacy signal into a secure IP-based transport stream that could be viewed by retail devices. That approach appears to be a revival of an “AllVid” proposal that the cable industry has previously argued against over claims that it forces the disaggregation of MVPD services.

A second proposal, which appears to be the one endorsed by more traditional MVPDs, is app-based, centered on Web-based platforms and standards where content can be delivered over HTML-5 with Encrypted Media Extensions (EME).  Many such apps have been written and deployed, supporting a range of retail devices.

Some DSTAC members, including Dr. Joseph Weber of TiVo, countered that the app-centric approach merely maintains the MVPDs’ interfaces and does not provide a path for competitive UIs.

Charter Communications has begun to deploy its new “Worldbox” to paying customers, the MSO revealed in a recent FCC filing that updated the Commission on the MSO’s rollout of a new downloadable security platform for set-tops and other types of video devices.

While the Worldbox is a device that is being leased by the operator, industry sources also confirm that Charter and TiVo are in talks about a retail solution that would employ the new downloadable security platform.

Charter, the MSO told the FCC, “deployed its first new Worldboxes to paying customers using downloadable security in April, 2015, and continues to ramp up the deployment of the downloadable security system throughout Charter’s systems. Enabling the Worldbox in any given footprint requires changes and additions to many pieces of the video delivery system, and those deployments are underway.”

Charter declined to comment further on its rollout of the Worldbox, a hybrid IP/QAM device that has at least two approved suppliers – Humax and Cisco Systems (which is in the process of selling its set-top and CPE business to Technicolor).

The Worldbox runs Charter’s new cloud-based Spectrum Guide, developed with ActiveVideo (Charter and Arris now own ActiveVideo via a joint venture). Charter has been testing the UI in Fort Worth, Texas, and has expressed plans to test it in markets such as Reno, Nev., and St. Louis.

Charter mentioned the Worldbox deployment update in a semi-annual report that it must file with the FCC per a condition for a waiver the MSO obtained in 2013 that allowed Charter to use dual-mode boxes equipped with integrated security and the operator’s new downloadable platform. Per the filing, Charter has deployed more than 2.67 million STBs with integrated security covered by the waiver as of June 30.

A condition of that waiver also requires Charter to engage in “good faith negotiations” with a CE manufacturer that intends to develop a set-top box to be sold at retail in the U.S. that uses Charter’s downloadable security system.

Regarding that status, Charter said talks with a CE manufacturer commenced in 2013 and that those talks are ongoing. Charter noted that it is “now awaiting further progress on technical details,” adding that talks with additional CE manufacturers commenced in the second quarter of 2015.

It appears that TiVo is one of the CE companies involved in those discussions.

TiVo, in a separate FCC filing about the company's interest in seeking clarity on cable’s ongoing support of CableCARDs, offered this nugget: “The TiVo representatives also responded to questions about discussions with Charter Communications concerning the use of Charter’s downloadable security solution in TiVo’s retail products as envisioned in the 2013 Order granting Charter a waiver of Section 76.1204(a)(1) of the Commission’s rules.”

Charter and TiVo declined to comment on any specific discussions pertaining to downloadable security, but industry sources confirmed that the two sides are talking about a retail-facing approach.

A retail agreement could tie up some loose ends. Charter stopped leasing TiVo boxes about two years ago (that tied into an agreement between them that was announced in January 2011), but how those two companies might continue to work together has been a lingering question ever since.

Charter’s development and deployment of a downloadable security system for set-tops and other video devices comes amid a backdrop in which an FCC-appointed committee mulls a potential successor to the CableCARD. That group, called the Downloadable Security Technology Advisory Committee (DSTAC), is tasked with filing its recommendations to the FCC by September 4, though consensus on a unified approach has proved elusive thus far (subscription required). 

Charter plans to expand the deployment of the new UI and  Worldbox to systems that are coming way of its proposed acquisition of Time Warner Cable and Bright House Networks. 

Charter confirmed earlier this year (subscription required) that it has licensed the Reference Design Kit and has established two parallel development tracks: one that factors in its current technical approach and one that also includes the RDK, a preintegrated software stack for video and broadband devices that’s being managed by Comcast, TWC and Liberty Global.

The top nine incumbent U.S. cable operators have deployed about 53 million CableCARDs in MSO-supplied set-tops and a mere 617,000 of the removable security modules in TiVo boxes, TVs and other retail products with CableCARD slots, according to the National Cable & Telecommunications Association’s latest report to the FCC.

That’s about 400,000 more than the 52.61 million CableCARDs deployed in MSO-supplied boxes when compared to the NCTA’s report to the FCC in May, which represented an increase of about 1.1 million versus the NCTA’s report in February. The latest report also showed that 3,000 fewer security modules are present in retail devices versus the NCTA’s most recent report in May.

The NCTA has been issuing these reports since the FCC’s ban on integrated security set-tops took effect in July 2007. The passing of the STELAR Act, which became law late last year, activated a provision that will sunset the FCC’s current ban on integrated security set-tops after a year.

The FCC is now tasked with pursuing a successor to the CableCARD that will focus on downloadable security systems that could be applied to cable operators as well as other MVPDs, including telcos and satellite TV providers.

To help with that pursuit, the FCC in January appointed the Downloadable Security Technology Advisory Committee (DSTAC), which must file a report with the Commission detailing its findings by Sept. 4, 2015. The next DSTAC meeting is scheduled to take place tomorrow (Tuesday, Aug. 4), at 10 a.m. ET.

The scope and direction of the DSTAC has been a source of tension. Last month, a bipartisan pair of House members asked the Committee to keep to its statutory mandate and not stray into reviving an AllVid proposal that has historically gotten lots of push-back from the cable industry.

The FCC’s pursuit of a successor to the CableCARD continued to heat up this week as a group comprised of Google, Amazon, Public Knowledge, TiVo and others warned the Commission that putting too fine a focus on downloadable security without addressing the greater goal of furthering the competitive availability of set-tops and other navigation devices “would result in a walled-garden approach.”

Members of the group (see below for the full list) addressed their concerns in a letter to members of the FCC Media Bureau on May 11, ahead of the next scheduled meeting of the FCC-appointed Downloadable Security  Advisory Committee (DSTAC), set for this Wednesday (May 13).

The DSTAC, comprised of 18 individuals, was formed in January after the STELAR Act became law in December 2014, activating a provision that will sunset the FCC’s current ban on set-tops with integrated security after a year. The DSTAC is slated to file its recommendations to the FCC by September 4.

“The FCC Media Bureau staff’s efforts in coordinating and overseeing the DSTAC should continue to further the Congressional directives in Section 629,” the group wrote in the May 11 letter.  “In particular, any solution recommended by DSTAC should ensure that device manufacturers can differentiate retail products from MVPDs’ leased products."

On that point, they said manufacturers should be able to provide innovative and distinctive features, including unique user interfaces, enhanced search functionality, and improved means for recording and viewing content consistent with copyright law. They also said users of retail devices should be able to access the full complement of MVPD video service offerings, while also being able to pick between “premium devices with advanced functionality” as well as “simpler, lower cost devices according to their preference.”

“The DSTAC should achieve a recommendation that functionally supersedes the CableCARD, without a need for the CableCARD hardware,” they added.

A different group comprised of MVPDs, vendors and cable industry organizations, including several members of the DSTAC, issued a letter of their own last month that outlined concerns they have about the scope, direction and “policy detours” being made by a FCC-appointed committee.

That group also argued that the DSTAC was being steered into developing a method by which an MVPD’s retail offering would be “disassembled into individual piece parts” that a retail device maker could then selectively reassemble into a new configuration and service.  

They also claimed that FCC staff had proposed the DSTAC to define “non-security APIs,” to access these piece parts of the service, arguing that those proposals likewise “hark back to the ‘AllVid’ concept,” whereby pay-TV providers would need to deploy a separate adapter that would “enable a retail device to disassemble a provider’s retail subscription service for reassembly into a new service for commercial exploitation.”

The Free State Foundation echoed as much in this statement, also issued May 11, arguing that the FCC has charged the DSTAC with a task that “strays from Congress’s mandate for a report on downloadable security for next-generation devices… Requiring DSTAC to develop methods for disaggregating bundled video programming and menu contents are outside the scope of STELAR's mandate. Congress directed the FCC's Chairman to establish a working group focused on a ‘downloadable security system.’”

The group represented by Google, TiVo and Public Knowledge said the committee must dig deeper.

“Limiting the DSTAC’s scope to downloadable security alone, without reference to the committee’s broader mandate of furthering the competitive availability of navigation devices, would result in a walled-garden approach that does not promote the vigorous competition and innovation envisioned by Section 629,” they wrote.

The May 11 letter to the FCC Media Bureau’s William Lake, Brendan Murray and Nancy Murphy was signed by the following:

- Matthew Clark, Amazon (DSTAC member)

- Gary Hammer, Ceton Corp.

- Daniel O’Connor, Computer & Communications Industry

- Angela Kronenberg, Comptel

- Matt Wood , Free Press

- Milo Medin, Google (DSTAC member)

- Brad Love, Hauppauge (DTAC member)

- Abigail Slater, The Internet Association

- Joshua  Goldberg, Open Technology Institute at New America

- Adam Goldberg,  Public Knowledge (DSTAC member)

-Theodore Head, Silicondust USA

- Dr. Joseph Weber, TiVo (DSTAC member)

- Ellen Stuzman, Writers Guide of America, West  

The top nine incumbent U.S. cable operators have deployed more than 52.61 million CableCARD modules in MSO-supplied set-tops, according to the National Cable & Telecommunications Association’s latest report to the FCC.

That represents an increase of about 1.1 million from the NCTA's last report, issued in February.

By comparison, the number of CableCARDs currently deployed by those MSOs for use in retail-bought video devices such as TiVo DVRs and integrated HDTVs was just above 620,000 – roughly the same figure reported by the NCTA in February.

The NCTA has been issuing these reports since the FCC’s ban on integrated security set-tops took effect in July 2007. The passing of the STELAR Act, which became law late last year, activated a provision that will sunset the FCC’s current ban on integrated security set-tops after a year.

The FCC is now tasked with pursuing a successor to the CableCARD that will focus on downloadable security systems that could be applied to cable operators as well as other MVPDs, including telcos and satellite TV providers.

To help with that pursuit, the FCC in January appointed the Downloadable Security Technology Advisory Committee (DSTAC), which must file a report with the Commission detailing its findings by Sept. 4, 2015. The next DSTAC meeting is scheduled to take place Wednesday, May 13, at 10 a.m. ET.

In April, a group that includes several MVPDs, the NCTA, American Cable Association, and CableLabs, have voiced concerns about the scope and direction of the FCC-appointed committee.

The FCC’s pursuit of a successor to the CableCARD (pictured) is morphing into a tension-filled affair as a group comprised of MVPDs, vendors and industry organizations issued a lengthy letter outlining concerns they have about the scope, direction and “policy detours” being made by a Commission-appointed committee that is tasked with providing recommendations that will aid the FCC’s pursuit of a new downloadable video security system that would apply to cable operators, telcos and satellite TV service providers and endeavor to spark a vibrant retail market for set-tops and other video devices.

Meanwhile, TiVo, which is on the committee and a company that has a big stake in the outcome, issued a statement of its own, calling the letter an “inappropriate attempt by incumbents to pre-judge the outcome of the technical working group and infect the process with non-technical policy arguments that have been addressed in prior FCC proceedings.”

The DSTAC, comprised of 18 individuals, was formed in Januaryafter the STELAR Act became law in December 2014, activating a provision that will sunset the FCC’s current ban on set-tops with integrated security after a year. The DSTAC is slated to file its recommendations to the FCC by September 4. The next DSTAC meeting is scheduled for Tuesday, April 21.

The letter -- dated April 10 and addressed to Cheryl Tritt of Wilkinson, Barker, Knauer, the chair of the Downloadable Security Advisory Committee (DSTAC) -- complained that the committee “is veering into areas that are well outside its statutorily-defined charter,” and being “diverted toward proposals that would hinder the ability of consumers to access MVPD and online video services on their growing number of devices.”

The letter argues that the DSTAC is being steered into developing a method by which an MVPD’s retail offering would be “disassembled into individual piece parts” that a retail device maker could then selectively reassemble into a new configuration and service.

“From the very first meeting, working group deliberations were nearly derailed by a staff directive that the DSTAC “committee shall develop” a means to disaggregate service even if participants believe that those features should not be mandatory,” the letter claimed.

They are also concerned about how the DSTAC discussions are emphasizing a new “box” that would conceivably disassemble MVPD service into outputs that a device maker could rearrange, combine and overlay with its own UI.

They also claim that FCC staff has proposed the DSTAC to define “non-security APIs,” to access these piece parts of the service, that, in the group’s estimation “is beyond the DSTAC’s well-defined ‘downloadable security’ mission” that could “raise significant contract and copyright issues.”

Those proposals, they argued, “hark back to the ‘AllVid’ concept,” whereby pay-TV providers would need to deploy a separate adapter that would “enable a retail device to disassemble a provider’s retail subscription service for reassembly into a new service for commercial exploitation.” Further, they believe a new AllVid-like approach would preclude many consumers from receiving MVPD and online video services directly via secure downloadable IP apps on devices such as smartphones, tablets, and gaming consoles. The FCC initially asked for feedback on the AllVid idea in 2010, but has not acted on the proposal. Amid growing concerns about the notion of a “black box,” the Commission directed the DSTAC at the March 30 meeting not to focus on implementations yet, but to instead sort out the technical requirements. 

“Resurrecting AllVid variants here is already needlessly bogging the DSTAC’s deliberations in controversy…” the group wrote, urging that the committee avoid such “policy detours” as the group builds its recommendations.

The group also railed against some interest in directing the DSTAC to use CableCARD as “starting point” for its work, despite the fact that distributors such as Dish Network, DirecTV and telcos that rely on IPTV, such as AT&T, never used the security module, and that the market is migrating to video apps that work independent of the CableCARD.

TiVo, meanwhile, said the letter “ignores the statutory reference to a ‘platform neutral’ solution and omits the statute’s reference to Section 629 as the underlying purpose of the working group which is to create a competitive retail navigation device market.”

TiVo added that the MVPDs involved in the letter (see below for more detail) are “trying to use the technical working group to try to turn back the clock and limit retail devices only to carrying MVPD apps,” holding that it would also extend their control over the interface, and prohibit retail devices from providing "fair use" competitive functionality such as DVR, side loading, and out of home streaming.

Matthew Zinn, TiVo’s SVP, general counsel and chief privacy officer, said the process has not yet reached the policy-making stage, so the group should instead focus on identifying possible technical solutions.

As for some of the issues addressed in the letter, he said TiVo has been able to apply its own UI while supporting the underlying copyright issues.

UPDATE: As for the disaggregation concerns addressed in the letter, TiVo also disagrees with assertions that elements such as weather apps and caller ID to the TV should be included in the definition of the cable service. Zinn said the FCC’s definition of cable service in this instance is all about programming, and shouldn’t be part of the DSTAC discussion, anyway.

“Those are issues that shouldn’t be debated in a technology advisory group,” he said. “They can be policy and regulatory issues that can be debated at a later time.  

The letter to Tritt (and copied to all DSTAC members) was signed by the following:

- American Cable Association, Patrick Murphy and Jason Hansen

- ARRIS Group,  Bruce McClelland (DSTAC member)

- AT&T, Dr. Ahmad Ansari (DSTAC member)

- Bright House Networks, Jeff Chen

- Cable Television Laboratories, Ralph Brown

- Cablevision Systems Corporation, Bob Clyne (DSTAC member)

- Charter Communications, Jay Rolls (DSTAC member)

- Cisco Systems, Edmond Shapiro

- Comcast, Mark Hess (DSTAC member)

- Cox Communications, Steve Watkins

- DirecTV, Steve Dulac

- Dish Network, John Card II (DSTAC member)

- Evolution Digital,Brent Smith (DSTAC member)

- Motion Picture Association of America, John McCoskey (DSTAC member)

- National Cable & Telecommunications Association, Andy Scott

- Time Warner Cable, Kevin Leddy

- Verimatrix, Petr Peterka

- Verizon Communications, David Young

Other members of the DSTAC include Brant Candelore of Sony; Matthew Clark of Amazon; Adam Goldberg, Public Knowledge;  Brad Love, Hauppauge; Kenneth Lowe, Vizio; Milo Medin, Google; Alan Messer, Samsung; Simha Sethumadhavan, Columbia University; Dr. Joseph Weber, TiVo; and Robin Wilson, Nagra.

For past coverage on the DSTAC, please see:

-CableCARD Successor Inches Ahead

-FCC Group Starts To Seek CableCARD's Successor

-‘Black Box’ Talk Dominates FCC’s First DSTAC Meeting

In a meeting last week that became testy at times, a committee tasked with helping the Federal Communications Commission create a successor to the CableCARD began to focus on commercial requirements for a new downloadable security platform for set-tops and other video devices that will work with multiple pay TV providers.

At a second meeting held last Tuesday (March 17), the FCC-appointed Downloadable Security Technology Advisory Committee (DSTAC) outlined some initial ways it will try to ensure that the resulting system complies with the same legal requirements that are placed on multichannel video programing distributors (MVPDs).

The DSTAC, comprised of 18 individuals, was formed in January after the STELAR Act became law in December 2014, activating a provision that will sunset the FCC’s current ban on set-tops with integrated security after a year. The FCC is now tasked with finding a successor aimed at driving a retail market for set-tops and other video devices. The DSTAC is slated to file its recommendations to the FCC by September 4.

Part of last week’s discussion centered on defining the “service” itself, and whether that is limited to linear and video-on-demand, or a panoply that extends to features such as caller ID to the TV, dynamic ad insertion, customer care portals and customer service tools, and metadata associated with video content.

“Things have come a long way” over the past decade in terms of the sophistication of features that are now rolled into MVPD video services, Jay Rolls, SVP and CTO of Charter Communications, said.

Adam Goldberg, principal, AGP/Public Knowledge, outlined some desired baseline consumer requirements, noting that, at a high level, the downloadable system should provide the ability for unaffiliated third parties to build navigation devices for sale at retail in a way that is portable –  meaning a customer can use it with different MVPDs in different parts of the country.  That should also cover an MVPD’s full set of video services, including VOD, pay-per-view and more complicated services that are delivered suing switched digital video technologies, he said.

The meeting was also marked by some debate on whether third parties can disaggregate pieces of an MVPD’s service, because content is typically licensed as a service and, per the contracts, must be packaged together.

Charter’s Jay Rolls, for example, pointed out that there should be restrictions on relocating channels in the lineup, but Goldberg said it’s possible that “channel numbers might not flow through to a retail environment.”

The discussion did eventually shift to the topic of security. Robin Wilson, vice president, business development at Nagra, said the DSTAC must be mindful of creating a system that is renewable, noting that the downloader itself plays a “critical role” and needs to be recognized as “the Achilles Heel of this system.”  

‘Black Box’ Concept Polarizing

As was the case at the first DSTAC meeting in February, the notion of a “black box” remains a polarizing issue. Is it a separate piece of hardware or a logical chip-level component that would go into a set-top or another video device? Does the term even belong in the discussion?

The commission directed the committee not to focus on implementations yet. “The idea is to speak in terms of requirements,” Alison Neplokh, chief engineer for the FCC’s Media Bureau, said.

“We want to define the ‘what’ before we start working on the ‘how’,” Rolls agreed “That’s at the root. We want to nail down requirements before we try to solve the development piece of the solution.”

Creating those requirements is a major challenge considering the disparate systems used by MVPDs. In a portion of the meeting focused on technology and preferred architectures, Bob Clyne, senior vice president of engineering and new technologies at Cablevision Systems, noted that U.S. cable system control systems, video encryption and deciphering systems are far from uniform, and certainly differ from those operated by satellite TV and telco TV providers.

Are Apps The Answer?

There is also disagreement as to whether the use of video streaming apps solves the problem at hand.  MVPDs and their programming partners have developed authenticated apps that run on a wide range of retail devices, including iPads, Roku boxes and gaming consoles, but Goldberg argued that the UI remains largely under the control of operators, making it fall short of creating a fully open and competitive retail market.

“Maybe it’s good for consumers…but it doesn’t make it a competitive navigation device,” he said.

“It’s not completion if the choice of apps is only one, from the cable provider,” Dr. Joe Weber, chief technical officer for TiVo’s service provider business unit, said.

Mark Hess, senior vice president, office of the chief technology officer, business and industry affairs, Comcast Cable, countered that video app development has opened to door to more completion as MVPDs continue to extend services to smartphones, tablets, smart TVs and gaming consoles.

“The app world has embraced those platforms,” Hess said. “To frame this as non-competitive is just not factually correct…To say there’s no choice is ludicrous.”

Update: The FCC announced that the third DSTAC meeting will take place Tuesday, April 21, 2015 from 9:30 a.m. to 12:30 p.m. ET.

The FCC has penciled in March 24 for the second meeting of the Downloadable Security Technology Advisory Committee (DSTAC), the group tasked with helping the agency pursue a successor to the CableCARD, the removable security module that failed to generate a robust retail market for cable-ready set-top boxes.

The first meeting, held in March, focused on the scope of the initiative, which aims to cover not just cable operators, but telco and satellite TV providers. Part of the discussion centered on the notion of a “black box,” that could end up being a new, discrete piece of hardware or merely a metaphor for a more virtualized component or chip that can be embedded in set-tops and other video devices.

The DSTAC is comprised of 18 individuals from companies such as Dish Network, Amazon, Comcast, Cablevision Systems, Charter Communications, TiVo and Google. They are charged with filing a report to the FCC by September 4 that identifies and recommends performance objectives and technical capabilities tied to a “platform-neutral software-based downloadable security system” that is “not unduly burdensome.” The committee was formed after the passing of the STELAR Act in December 2014, which will sunset the current integration ban this December and calls on the FCC to pursue a downloadable alternative. 

At the first meeting, the DSTAC also started to debate whether over-the-top services should be considered in the report, which is being researched as the FCC looks to create new rules that will would define some online video providers as MVPDs, at least with respect to access to cable and broadcast TV programming.

Is the notion of “black box” that can support video services from all forms of multichannel video programming distributors a discrete piece of new hardware or merely a metaphor for a more virtualized component or chip that can be embedded inside set-tops and other video devices?

That was one of many questions weighed last Monday (February 23), when the Federal Communications Commission-appointed Downloadable Security Technology Advisory Committee (DSTAC) held its first meeting.

The group, comprised of 18 individuals from companies such as Dish Network, Amazon, Comcast, Cablevision Systems, Charter Communications, TiVo and Google, is tasked with investigating the successor to the CableCARD, a removable security module that failed to create a vibrant retail market for cable-ready retail video devices, and file its recommendations by September 4.

The committee is tackling the idea of a uniform solution even as other MVPDs, including Charter and Cablevision, have already developed and deployed downloadable security systems. Comcast and TiVo, meanwhile, are also pursuing a non-CableCARD solution.

The initial meeting focused on the scope of the report, including which types of navigation devices and the types of content and services – including linear TV and on-demand video -- should fit inside it.

The notion of an all-MVPD black box outfitted with downloadable security dominated the early discussions, though what form it will take remains an item that still needs to be clearly defined.

Talks gravitated toward a virtual module or even a chip that can support the baseline input and output requirements of pay-TV operators. That could end up spanning elements such as service discovery, channel tuning/content requests, emergency alert system information, closed captioning data, copy control information, subscriber authentication, and the audio and video streams themselves.

There are already factions forming on what this black box shouldn’t be.

Joe Weber, the chief technology officer for TiVo’s Service Provider Business Unit, warned that it would not be feasible for a retail CE company to support a multitude of separate devices that sits between it and the retail device from a wide range of MVPDs  

Concerns were also raised that adding yet another power-sucking device to the mix runs counter to the desire to lessen the pay-TV industry’s already sizable carbon footprint.

Alan Messer, vice president of advanced technology for Samsung’s Advanced Technology Lab, expressed some uneasiness about a so-called black box taking the form of a new chip, noting that it could significantly raise the materials costs for makers of TVs, DVRs and other retail video devices. Such a chip "might not be the right mindset,” he argued. 

Also up for debate is whether over-the-top services should be considered in the committee’s upcoming report, which is being researched as the FCC shoots for new rules that will would define some online video providers as MVPDs, at least with respect to access to cable and broadcast TV programming.

Mark Hess, SVP, office of the CTO, business and industry affairs at Comcast Cable, suggested that it will be difficult to exclude OTT from the discussion in a meaningful way given the current state of the video marketplace.

“It is an error to ignore it,” agreed Kenneth Lowe, vice president and co-founder of TV maker Vizio.

The process will also prove to be a challenge for MVPDs, such as satellite TV operators, that were not required to adhere to the original separable security rules. Dish Network, for example, is inherently a one-way, downstream-only platform. While its boxes do use broadband connections for upstream communications, they are out of Dish’s control and, therefore, not something that is fully reliable or secure.

“DBS is going to be the problem child here and bring in some unusual challenges,” John Card II, director of standards and technology, at EchoStar Technologies/Dish Network, warned.

While some on the committee are pushing for a successor that’s based on IP-based transport, others warned that MVPDs are not migrating there in lock-step.

“Not all operators move at the same timeframes,” Milo Medin, vice president of access services at Google, said. The challenge, he added, is to focus on solution that succeeds the CableCARD “without a multi-year gap.”

Another concern is whether metadata will be included in the downloadable security platform. Hess pointed out that MSOs such as Comcast strike separate deals for metadata and the rights on how they can use them. “There are a lot of subtleties to this as we go deeper,” he said.

FCC Chairman Tom Wheeler paid the DSTAC meeting a visit, thanking the group while also acknowledging that the task ahead won’t be easy.

“Congress gave us a non-trivial task that you all know so well,” he said. “We are under no allusions about the challenge that that mandate represents.”  

The first meeting of an FCC-appointed committee that will explore a potential successor to the CableCARD got underway Monday (February 23), with much of the discussion centering on the notion of an all-MVPD “black box” and whether OTT video service providers should be included within the scope of the discussion.

That group, called the Downloadable Security Technology Advisory Committee (DSTAC), is comprised of 18 members and includes execs from Dish Network, Cablevision Systems, Charter Communications, Comcast, Amazon, Google, TiVo and Evolution Digital.  The committee was formed after the passing of the STELAR Act in December 2014, which will sunset the current integration ban this December and calls on the FCC to pursue a downloadable alternative. The DSTAC is tasked with filing a report of its findings and recommendations to the FCC by September 4.

Monday’s meeting has so far focused on the scope of the report, including which types of navigation devices and the types of content and services – including linear TV and on-demand video -- should fit inside it.

The notion of a “black box” outfitted with downloadable security dominated the early discussion, though what exactly that will entail is not yet clearly defined. But the general idea for it seems to be focused on a virtual module of sorts or a chip that can support the baseline input and output requirements of pay-TV operators. That could end up spanning elements such as service discovery, channel tuning/content requests, emergency alert system information, closed captioning data, copy control information, subscriber authentication/provisioning, and the audio and video streams themselves.

What technical shape that black box takes is an early part of the debate. Joe Weber, CTO for TiVo’s Service Provider Business Unit, for example, warned that it would not be feasible for there to be a separate box that sits between it and the retail device from a wide range of MVPDs. 

Alan Messer, VP, advanced technology for Samsung’s Advanced Technology Lab, also raised concerns about this black box taking the form of a new chip, noting that it could significantly raise the bill of material (BOM) costs for TVs, DVRs and other retail video devices. Such a chip "might not be the right mindset,” he argued. 

Also up for debate is whether OTT services should be considered in the coming report, even as the FCC moves ahead with a new rulemaking effort that will look define some online video providers (OVDs) as MVPDS, at least with respect to access to cable and broadcast TV programming.

Mark Hess, SVP, office of the CTO, business and industry affairs at Comcast Cable,  suggested that it will be difficult to exclude OTT from the discussion in a meaningful way given the current state of the video marketplace.

“It is an error to ignore it,” agreed Kenneth Lowe, VP and co-founder of Vizio.

The FCC announced Thursday that it has rescheduled the first-ever meeting of the Downloadable Security Technology Advisory Committee (DSTAC) for Monday, Feb. 23, starting at 10 a.m. ET.

The meeting was originally scheduled for Tuesday (Feb. 17), but was cancelled after a snowstorm caused a shutdown of all federal offices in the Washington, D.C., area.

An FCC-appointed group of 18 execs and specialists from companies and organizations that include Comcast, Public Knowledge, AT&T, TiVo, Amazon, Evolution Digital and the Motion Picture Association of America, make up the committee. The DSTAC was formed soon after the STELAR Act became law on Dec. 5, 2014, activating a provision that will sunset the FCC’s current ban on set-tops with integrated security after a year.

The DSTAC is tasked with filing a report with the Commission by September 4, 2015.

During next week’s meeting, the DSTAC will focus on the scope of that report, the ultimate goals of the effort with respect to navigation device and content security, and recommend working groups and the tasks they’ll be assigned. 

The first step toward the development of a successor to the much-maligned CableCARD will have to wait.

A winter storm that dropped about four inches of snow in the Washington, D.C., area has caused the U.S. government to close all federal offices in the area on Tuesday, a move that also cancelled what was to be the first meeting of an FCC-appointed committee tasked with exploring and making recommendations for a “platform-neutral, software-based” downloadable security system aimed at replacing the CableCARD and promoting the competitive availability of set-tops and other MVPD-compatible  video devices. 

That group, called the Downloadable Security Technology Advisory Committee (DSTAC), was scheduled to hold its first meeting today at 10 a.m. ET.

An FCC official confirmed that the meeting was indeed cancelled and that a new date for that meeting has not yet been decided. When the FCC announced it was seeking nominations for the DSTAC in December, it anticipated that the group would meet in Washington, D.C., for full-day meetings once per month, at least through September.  The committee must file a report with the Commission by September 4, 2015.

The FCC recently appointed a group of 18 execs and specialists from companies and organizations that include Comcast, Public Knowledge, AT&T, TiVo, Amazon, Evolution Digital and the Motion Picture Association of America.  The DSTAC was formed soon after the STELAR Act became law on Dec. 5, 2014, activating a provision that will sunset the FCC’s current ban on set-tops with integrated security after a year.

Last week, Beyond Broadband Technology (BBT), which is not on the committee, offered to give the DSTAC a “full technical briefing” on a downloadable security platform that has been developed by a cable-backed group that has historically been focused on smaller, independent MVPDs. 

Beyond Broadband Technology (BBT), the cable consortium that has developed a downloadable security platform for set-tops and other video devices, wasn’t asked to participate on an FCC-appointed committee that will start the pursuit of a successor the CableCARD, but it still wants its voice to be heard.

In a letter to that group – called the Downloadable Security Technology Advisory Committee – on Friday (February 13), BBT CEO and CTO Bill Bauer proposed to give the DSTAC or any relevant sub-committee a “full technical briefing” so they can weigh and explore “the unique aspects and challenges in the development of a true ‘technology and platform neutral’ security system such as BBT's…”

BBT, which works primarily with small cable operators, sought but failed to secure spot on the DSTAC, which will hold its first meeting next Tuesday (February 17). The FCC recently appointed a group of 18 execs and specialists from companies and organizations that include Comcast, Public Knowledge, AT&T, TiVo, Amazon, Evolution Digital and the Motion Picture Association of America.

The DSTAC was formed soon after the STELAR Act became law on Dec. 5, 2014, activating a provision that will sunset the FCC’s current ban on set-tops with integrated security after a year. The DSTAC will help the FCC to identify and recommend  a “platform-neutral software-based downloadable security system”  aimed at promoting competitive availability of navigation devices – something that the CableCARD failed to do. The DSTAC must file a report with the Commission by September 4, 2015.

The BBT and the American Cable Association, meanwhile, have argued that the makeup of the committee underrepresents the interests of smaller, independent MVPDs.

Holding that no members of the current DSTAC committee have been fully briefed on the technical and security details of BBT’s technology, Bauer said the organization would be willing to share those security details “under appropriate safeguards, which are consistent with the Federal Advisory Committee Act.”

Among the points made by Bauer in the letter, he stressed that any recommended technology should work with both one- and two-way transport platforms, since “at least a third or more” of the current MVPD universe delivers serves on unidirectional plant, and any selected approach should likewise be backwards compatible with legacy systems.

Update: To clarify that, BBT noted that the one-way issue involves not just the residual of older, smaller DBS systems, but also DBS and the possible addition of video platforms of digital broadcast channels. 

Bauer also identified what he sees as the “most difficult hurdle” for any cross-industry standard for software-downloadable security – the current prevalence of proprietary public/private key security schemes and the tricky aspects of indemnification – i.e. who’s on the hook if the system is cracked.

“An additional major stumbling block is the associated almost impossible expectation of indemnity,” Bauer wrote. “These intractable issues can be ameliorated by development of a system that does not require a ‘trusted authority’ and allows fully individualized, user controlled software data encryption and conditional access downloadability.”

Arguing that the notion of “unbreakable” security is pure fantasy, Bauer also suggested that the DSTAC should favor technologies that are “nimble and recoverable” and support a design that keeps the “threat targets” small, versus one that would face industry- or nationwide vulnerabilities.

Because we’re still keeping score as the CableCARD regime heads toward its end, the number of removable security modules deployed in MSO-supplied set-tops by the top nine incumbent cable operators has eclipsed 51.5 million, the National Cable & Telecommunications Association said in its latest report to the FCC.

By comparison, the number of CableCARDs currently deployed by those MSOs for use in  retail-bought video devices such as TiVo boxes and integrated HDTVs was just under 620,000.

The NCTA’s previous report, issued last October, found that those same operators had deployed about 50 million CableCARDs in MSO-supplied boxes, and 623,000 modules in retail devices.

The FCC ban on integrated security set-tops took effect on July 1, 2007, but the CableCARD regime as the industry it is in the processing of fading away amid the passing of the STELAR Act, which became law late last year, activating a provision that will sunset the FCC’s current ban on integrated security set-tops after a year.

In STELAR’s wake, the FCC is now tasked with pursuing a successor to the CableCARD that will focus on downloadable security and removable systems that would apply to a broader range of MVPDs, not just cable operators.

Toward that end, the FCC last week appointed 18 members, including execs from Comcast, Cablevision Systems, Charter Communications, TiVo, Amazon and Google, to a new group called the Downloadable Security Technology Advisory Committee (DSTAC) that will give the FCC a hand. The DSTAC’s first of several monthly meeting is slated for Feb. 17, 2015, at FCC headquarters. The committee must file a report with the Commission detailing its findings by Sept. 4, 2015.

The Federal Communications Commission on Wednesday announced the appointment of 18 members to a new committee that will help the agency pursue a successor the CableCARD.

That group, called the Downloadable Security Technology Advisory Committee (DSTAC), is comprised of 18 members (Multichannel News identified most of the companies and organizations last week as the FCC was finalizing its list):

-Dr. Ahmad Ansari, Director of New Product Development, AT&T Labs;

-Brant Candelore, Senior Staff Member, Sony Electronics;

-John Card II, Director of Standards and Technology, EchoStar Technologies, LLC (Dish Network);

-Matthew Clark, Principal, Business Development Digital Products, Amazon;

-Bob Clyne, Senior Vice President of Engineering and New Technologies, Cablevision Systems;

-Adam Goldberg, Principal, AGP, LLC/Public Knowledge;

-Mark Hess, Senior Vice President, Office of the Chief Technology Officer, Business and Industry Affairs, Comcast Cable;

-Brad Love, Chief Technologist, Hauppauge;

-Kenneth Lowe, VP and Co-Founder, Vizio;

-John McCoskey, EVP, Global Policy and External Affairs, Motion Picture Association of America;

-Bruce McClelland, President of Network and Cloud & Global Services, Arris;

-Milo Medin, Vice President of Access Services, Google;

-Alan Messer, Vice President, Advanced Technology, Samsung’s Advanced Technology Lab;

-Jay Rolls, Senior Vice President and Chief Technology Officer, Charter Communications;

-Simha Sethumadhavan, Associate Professor of Computer Science & Alfred P. Sloan Fellow, Columbia University;

-Brent Smith, President and CTO, Evolution Digital;

-Dr. Joseph Weber, Chief Technical Officer for the Service Provider Business Unit, TiVo; and

-Robin Wilson, Vice President, Business Development, Nagra.

Cheryl Tritt of Wilkinson, Barker, Knauer will serve as chair of the DSTAC. Brendan Murray and Nancy Murphy will serve as the Designated Federal Officer and Alternate Designated Federal Officer, respectively, of the DSTAC, according to the FCC. 

The DSTAC is forming following the STELAR Act, which became law late last year, thus activating a provision that will sunset the FCC’s current ban on set-tops with integrated security after a year. Separable security has largely been handled by the CableCARD, a security module for set-tops and TVs that failed to create a vibrant retail market for cable-ready video devices.

The Act directs the DSTAC “to identify, report, and recommend performance objectives, technical capabilities, and technical standards of a not unduly burdensome, uniform, and technology- and platform-neutral software-based downloadable security system” to promote the competitive availability of navigation devices (set-top boxes and television sets, etc.). The DSTAC must file a report with the Commission by September 4, 2015 to detail its findings and recommendations.   

DSTAC meetings will be open to the general public. The first meeting has been scheduled for Tuesday, Feb. 17, 2015, at FCC headquarters in Washington, D.C. 

Beyond Broadband Technology (BBT), a consortium founded by small cable operators that has developed a downloadable security system, wanted to be part of the committee but did not make the cut. It had urged the FCC to reconsider over concerns that smaller operators would not be represented properly and arguing that the technical expertise of BBT chief technology officer Bill Bauer would bring value to the group.