The American Cable Association has asked the FCC not to
graft analog-era proof-of-performance signal testing on a more robust and
reliable digital-delivery system, agreeing with the National Cable and Telecommunications
Association that self-certification rather than what ACA calls "needless
and ineffective" testing is the right route in the digital age.
But if the FCC does impose the rules on cable operators, ACA
wants it to allow self-certification for the smaller operators it represents.
"At the very least, if the Commission does adopt such testing requirements,
it should permit smaller cable operators serving 400,000 or fewer subscribers
to self-certify signal quality," ACA says.
In reply comments to the FCC's proposal to update its
proof-of-performance rules and signal leakage criteria, ACA pointed out that
when the FCC adopted the current regime back in 1992, it did not apply the
proof-of-performance standards to digital cable systems, though it said it
could if it appeared "necessary or desirable" in the future.
ACA says it is neither since the FCC has not identified a
signal quality problem in need of resolving.
"There is no reasoned basis for imposing potentially
burdensome digital proof-of-performance requirements on cable operators,"
ACA provides two other reasons for not moving the rule
regime to digital: 1) improvements in cable technology and 2) competitive
forces that provide marketplace incentive to deliver quality video.
In 1992, says ACA, analog systems relied on amplifiers that
could result in noise and distortions, while the error correction capability of
digital technology provides a more consistently good signal.
It also argues that with cable services now using
independent nodes serving a few hundred customers apiece, testing one node
would not provide much info, while having to test all of them would be an
unnecessary burden, particularly on smaller operators, with no offsetting
Verizon agreed with NCTA as well, saying in its reply
comments that the FCC's rules were outdated and "largely irrelevant,"
particularly for its FiOS, which as an all-fiber system had "limited
capacity" for leakage.