The FCC's compatibility rules: good news and bad
These rules were required to implement Section 17 of the 1992 Cable Act. Shortly after these rules were issued, numerous Petitions for Reconsideration were filed by both the consumer electronics and the cable sides. The FCC has issued its reconsideration in a Memorandum Opinion And Order released April 10, 1996 and has modified the rules. There's some good news, and some bad news.First, the good news:
- The IR code restrictions have been removed. The requirement to use the same IR codes when replacing a set- top box no longer exists. This is good news, because the rule imposed extreme expense and operational difficulties on cable operators while providing essentially no consumer benefit. See § 25.
- The requirement to provide set-top boxes (on request and in proportion to cost) which include "multiple" descramblers has been clarified as being satisfied by just two descramblers. See § 9.
- This requirement can also be satisfied with a "Master/Client" configuration involving two or more descramblers operating with just one remote control. An integrated unit is not required. See § 10 & 11.
- It was clarified that the Decoder Interface component descrambler is not restricted to just descrambling. A unit can be leased to subscribers including any features and functions. See § 38.
- Cable operators must provide (upon request) a component descrambler performing only signal security functions. See § 38.
- CVS' request that consumer electronics manufacturers be required to share the burden of consumer education was denied. See § 29.
- Several technical specifications for "cable ready" TVs and VCRs have been relaxed.
a) The upper tuner frequency was reduced a trivial amount, rather than extended to the likely upper limit of cable systems during the lifetime of these products as requested by CATA. See § 56 & 57.
b) Tuner overload specifications were relaxed per EIA's and Zenith's request. See § 61
c) Image channel interference was relaxed. See § 65.
- Most damaging, the "Fair Warning Label" was lost. The "Fair Warning Label" was intended to reduce confusion when consumers are making point-of-sale purchase decisions and are offered TVs and VCRs which tune cable channels and have an F-connector. Most rational consumers would assume that these devices are "cable ready." Furthermore, it is easy for a consumer electronics salesperson to be confused by these products and suggest to consumers that these products are "cable ready." Unscrupulous salespersons may use these features to deliberately mislead consumers and close a sale. The "Fair Warning Label" was intended to minimize these hazards and to at least offer some degree of protection to cable operators when subscribers complain that their "cable ready" receivers have problems.
The consumer electronics manufacturers and the retailers were able to take this situation and stand it on its head. They convinced the FCC that a "Fair Warning Label" would actually cause confusion!
§ 48 ". . .We agree with the EIA/CEG that a negative advisory requirement could cause consumers confusion about the capabilities of TV products. . . . we are eliminating the advisory labeling requirement for consumer TV equipment that incorporates features intended to be used with cable service, but does not fully comply with the 'cable ready' equipment standards."
Even more alarming, the FCC gave the consumer electronics industry approval to include highly misleading statements in its advertising:
§ 49. . . " . . . factual statement about the various features of a device that are intended for use with cable service or the quality of such features are acceptable so long as such statements do not imply that the device is fully compatible with cable service. We do not consider statements relating to individual features that provide 'partial' compatibility, such as those mentioned by EIA/CEG to be representations that a device is fully compatible. ... We disagree with NCTA that statements about individual features will convey the impression that a device is fully compatible with cable service."
A look at the acceptable examples practically invites suggesting to consumers that products are "cable ready," even when they are deficient in many respects.
§ 41 & 42 ". . . For example . . .'tunes cable channels with unsurpassed accuracy' or is 'capable of receiving 125 cable channels'. . . should not be considered a representation that a device is fully compatible."
To make matters worse, products which do not meet FCC requirements for "cable ready" can still carry a statement that they are "cable ready" according to the Canadian rules!
§ 43 ". . . Zenith also seeks clarification regarding the certification statement required under Canadian General Radio Regulations. . . requires the phrase 'Cable Compatible Television Apparatus Canada GRR Part II' appear on some equipment sold in Canada . . . Zenith submits that manufacturers should not be prohibited from labeling equipment sold in the U.S. with a phrase required by the government of Canada . . .".
Given the above, any salesperson can provide convincing reasons for consumers to expect proper performance when an ordinary TV or VCR is connected to cable. When the subscriber complains about difficulties, the FCC has given the salesperson an easy out in blaming the cable operator.
Contact Walt Ciciora at: firstname.lastname@example.org