9 FCC Red No. 10 Federal Communications Commission Record FCC 94-80
Before the
Federal Communications Commission 
Washington, D.C. 20554
ET Docket No. 93-7
In the Matter of
Implementation of Section 17 
of the Cable Television 
Consumer Protection and 
Competition Act of 1992
Compatibility Between 
Cable Systems and Consumer 
Electronics Equipment
FIRST REPORT AND ORDER
Adopted: April 4, 1994; Released: May 4, 1994
By the Commission:
Table of Contents
Paragraph
Introduction 1
Background 7
Section 17 Provisions 8
The Compatibility Report 13
Discussion 17
Basic Approach for Achieving Compatibility 18
Decoder Interface Connector 34
Rules for Existing Equipment 43
Supplemental Equipment 43
Scrambling of Signals on the Basic Ser 
vice Tier 49
Remote Controls 60 
Consumer Education 64
Implementation or Rules for Existing 
Equipment 75
Rules for New Equipment 78
Cable Ready Consumer Equipment Standards 78
Definition of Cable Ready Equipment 78
Channel Tuning 85
Receiver Performance Standards 91
A. Adjacent Channel Interference 92
B. Tuner Overload 95
C. DPU Interference 99
D. Image Channel Interference 104
E. Conducted Emissions 107
F. Radiated Emissions 114
G. Input Selector Switch Isolation 119
H. Bypass Switch Attenuation 122
Equipment Authorization 125
Implementation of Rules for New Consumer Equip 
ment 128 
Standards for Cable Systems 132
Channelization 132 
Future Technologies 136 
Procedural Matters 145 
APPENDIX A: Amendments to the Rules 
APPENDIX B: Parties Filing Comments and/or Reply 
Comments
INTRODUCTION
1. By this action, the Commission is taking the first steps 
towards ensuring enhanced compatibility between consum 
er electronics equipment and cable systems. These regula 
tions implement the statutory requirements set forth by 
Congress in Section 17 of the Cable Television Consumer 
Protection and Competition Act of 1992 (1992 Cable Act), 
enacted October 5, 1992.' The objective of this portion of 
the 1992 Cable Act is to ensure compatibility between 
cable systems and consumer TV receivers and video cas 
sette recorders (VCRs). consistent with the need to prevent 
theft of cable service.
2. The new cable-consumer equipment compatibility reg 
ulations include measures that will assure improved com 
patibility between existing cable system and consumer TV 
equipment. They also include provisions for achieving 
more effective compatibility through new cable and con 
sumer equipment. The specific provisions of these regula 
tions are essentially the same as those proposed in the 
Notice of Proposed Rule Making (Notice) in this proceeding, 
with a number of modifications that address issues raised 
in the record.2 The new rules for improving compatibility 
between existing cable system and consumer equipment 
require that cable operators:
1) refrain from scrambling program signals carried 
on the basic tier of service;
2) offer subscribers supplemental equipment to en 
able them to use the special features and functions of 
their TV equipment with cable service; this includes 
providing subscribers the option of having simulta 
neous access to all signals that do not need to be 
processed by a set-top device:
1 See Cable Television Consumer Protection and Competition 
Act of W2, Pub. L. No. 102-385, 106 Stat. 1460. (1W2), 17. 
This proceeding is limited to issues involved in implementation 
of Section 17 of the 1W2 Cable Act. We have addressed the
implementation of other portions of this new legislation in 
other proceedings.
2 Notice of Proposed Rule Making in ET Docket No. 93-7, 8 
FCC Red 8495 (1W3).
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FCC 94-80 Federal Communications Commission Record 9 FCC Red No. 10
3) provide a consumer education program to inform 
subscribers of potential compatibility problems and 
methods for resolving such problems; this includes 
notice that remote controls and supplemental equip 
ment compatible with the set-top devices used by the 
cable system are available from third-party vendors; 
and
4) allow set-top devices that incorporate remote con 
trol capability to be operated with subscriber-owned 
remote controls or otherwise take no action that 
would prevent the use of such remote controls, in 
cluding changing the infrared codes used to operate 
the remote control capabilities of the set-top devices 
they employ so as to adversely affect the operation of 
consumer-purchased remote controls.
The compatibility rules for new equipment provide tech 
nical standards for "cable ready" consumer TV equipment 
and require that both "cable ready" consumer TV equip 
ment and cable systems use a standard cable channel plan.
3. We also conclude that more effective compatibility 
between consumer TV equipment and cable systems that 
use scrambling can be achieved through use of a standard 
interface connector, or "Decoder Interface." in "cable 
ready" consumer TV equipment and associated component 
descrambler/decoder devices to be provided by cable sys 
tems. Used together, the Decoder Interface and component 
descrambler/decoder devices can eliminate the need for use 
of a set-top cable box. However, based on indications that 
the cable and consumer electronics industries are close to 
agreement on a new Decoder Interface standard that will 
serve both existing analog cable operations and also incor 
porate flexibility to support new technologies and services, 
including digital cable service, we find that it would be 
appropriate to allow an additional period of time for the 
industries to complete their work on the new standard. We 
therefore will not act on the Decoder Interface standard 
and related issues now. but rather will allow cable oper 
ators, consumer electronics manufacturers and other rel 
evant industry parties an additional 90 days to complete the 
new standard.3 After that period, we will develop rules 
establishing a standard for a Decoder Interface connector 
and requirements for its use.
4. As a policy matter, we also find that standards for 
cable digital transmissions are desirable. These standards 
will be needed to ensure that compatibility is maintained as 
new digital cable technologies and services are introduced. 
We are not. however, adopting technical standards or other 
rules in this area at this time, as developmental work on 
cable digital technologies and services has not reached a 
stage where it would be reasonable to attempt to specify 
such regulations. We will continue to monitor progress by 
the industries in this area and will initiate a separate action 
on these issues as is necessary to assure continuing com 
patibility in the future.
5. The actions we are taking today will allow consumers 
to utilize equipment offered by a variety of suppliers, in 
cluding the cable system operator, in a competitive market. 
Thus, a number of manufacturers and retailers will be able 
to increase their participation in markets to which they
previously had limited access. Opening these markets to 
competitive equipment providers will give product devel 
opers and manufacturers, as well as cable system operators, 
the ability and incentives to introduce new products and to 
respond to consumer demand. In return, consumers will 
have greater access to technology with new features and 
functions. Most importantly, consumers will be assured 
that the equipment they buy will work with their cable 
system.
6. Open entry for equipment provision ensures that the 
equipment market remains competitive. In addition to 
open markets and incentives for innovation, another key 
component of competition is information. The new regula 
tions ensure not only that the marketplace will be open 
and equipment options available to consumers, but that 
consumers will be informed about their choices. Competi 
tion could be stifled unless consumers are informed about 
their equipment options. By structuring the regulations to 
promote innovation and competition, we expect increased 
investment in new technology development and increased 
economic activity as consumers purchase the new, com 
petitively priced equipment.
BACKGROUND
7. In the 1992 Cable Act. Congress recognized that there 
are a number of compatibility problems between cable 
service and consumer electronics equipment. These prob 
lems tend to limit or preclude the operation of premium 
features of consumer equipment and/or to affect the ability 
of consumer equipment to receive cable programming. For 
example, the use of set-top cable converter/descrambler 
devices typically hinders the operation of VCR features 
such as timed recording of sequential programs on dif 
ferent channels and recording one program while watching 
another. Set-top boxes also preclude the operation of spe 
cial features of TV receivers, such as "Picture-in-Picture," 
that require simultaneous tuning of two channels.4 In addi 
tion, current cable system practices often disallow the use 
of customer-owned remote control devices, both those that 
are supplied with receivers and VCRs and universal remote 
control devices that can control both cable set-top devices 
and consumer equipment. There also appears to be confu 
sion on the part of consumers about whether, and the 
extent to which, equipment is "cable ready" or "cable 
compatible." For example, current TV receivers and VCRs 
vary in their ability to tune the full range of channels 
offered by cable systems.
8. Section 17 Provisions. Section 17 of the 1992 Cable 
Act adds a new Section 624A to the Communications Act 
of 1934, that addresses compatibility between consumer 
electronics equipment and cable systems.5 In Section 
624A(a). Congress makes the following findings with regard 
to this matter:
- new and recent models of TV receivers and VCRs 
often contain premium features and functions that 
are disabled or inhibited because of cable scrambling, 
encoding, or encryption and by the use of cable 
devices, such as converters and remote control units, 
needed to receive programming;
J If the industry parlies do not complete their work in the 
90-day period, we will establish a standard using our own 
resources.
4 A complete discussion of the various compatibility problems 
is provided in the "Compatibility Report," infra.
5 Section 17 of the 1W2 Cable Act, supra.
1982
9 FCC Red No. 10 Federal Communications Commission Record FCC 94-80
- Consumers will be less likely to purchase, and 
electronics manufacturers will be less likely to de 
velop, manufacture, or offer for sale, TV receivers 
and VCRs with new and innovative features and 
functions, if these problems are allowed to persist: 
and,
- Cable operators should use technologies that will 
prevent signal thefts while permitting consumers to 
benefit from the features and functions contained in 
such receivers and VCRs.6
9. Section 624A(b) specifies that, within one year of the 
enactment of the legislation, the Commission, in consulta 
tion with representatives of the cable and consumer elec 
tronics industries, must report to Congress on means of 
assuring compatibility between TV sets, VCRs and cable 
systems, consistent with the need to prevent theft of cable 
service.7 This section also provides that within 180 days of 
that report, the Commission shall issue such regulations as 
are necessary to assure compatibility between consumer 
electronics equipment and cable systems.8 Section 624A(b) 
states that in issuing these rules, the Commission shall 
consider whether and. if so, under what circumstances to 
permit cable systems to scramble or encrypt signals or to 
restrict cable systems in the manner in which they scram 
ble or encrypt signals. However. Section 624A(b) also pro 
vides that the Commission shall not limit the use of 
scrambling technology where it does not interfere with the 
functions of subscribers' TV receivers or VCRs.4
10. Section 624A(c) specifies that, in developing the rules 
required by Section 624A(b), the Commission is to con sider: 10
- The costs and benefits to consumers of imposing 
compatibility requirements on cable operators and 
TV manufacturers in a manner that, while providing 
effective protection against theft or unauthorized re 
ception of cable service, will minimize interference 
with, or nullification of, the special functions of sub 
scribers' TV receivers or VCRs. including functions 
that permit the subscriber to 
-- watch a program on one channel while 
simultaneously recording a program on 
another channel;
- record two consecutive programs that 
appear on different channels: and.
- use advanced television picture genera 
tion and display features, and:
- The need for cable operators to protect the integrity 
of the signals transmitted by the cable operator 
against theft or to protect such signals against 
unauthorized reception.
11. Section 624A(c) further specifies that the equipment 
compatibility regulations shall include, as are necessary:"
- Technical requirements with which a TV receiver 
or VCR must comply in order to be sold as "cable 
compatible" or "cable ready":
- Requirements that cable operators offering channels 
whose reception requires a converter unit 
-- notify subscribers that they may not be 
able to use the special features of their 
TV receivers and VCRs;
to the extent technically and 
economically feasible, offer subscribers 
the option of receiving all other channels 
directly, without passing through the 
converter unit;
- Rules to promote the commercial availability, from 
cable operators and retail vendors that are not affili 
ated with cable systems, of converter units and re 
mote control devices that are compatible with 
converter units;
- Requirements that cable operators who offer sub 
scribers the option of renting a remote control unit 
- Notify subscribers that they may pur 
chase a remote control from any source 
that sells such devices;
- Specify the types of remote control 
units that are compatible with the con 
verter unit supplied by the cable oper 
ator; and.
- A prohibition that cable operators may not take any 
action that prevents or in any way disables its con 
verter units from operating with commercially avail 
able remote controls.
12. Finally. Section 624A(d) requires the Commission to 
review periodically and, if necessary, modify the regula 
tions issued pursuant to this section in light of actions 
taken in response to the regulations and to changes in 
cable systems. TV receivers. VCRs and related technology. ll!
13. The Compatibility Report. On January 14. 1993. the 
Commission issued a Notice of Inquiry (NOD seeking in 
formation and comment on the various issues relating to 
compatibility. u The Commission indicated that the infor 
mation gathered under the A'O/ was to be used in prepar 
ing the report to Congress required under Section 17 and 
in formulating proposals for rules to implement the com- 
patibilitv regulations required under this portion of the 
1992 Cable Act.
6 Section 624A(a), Section 17 of the 1942 Cable Act. supra.
7 Section 624A(b)(l), Section 17 of the 1992 Cable Act. supra. 
s Under Part 76 of the Commission's current rules, cable 
systems are subject to technical standards that specify minimum 
performance with regard to the quality of NTSC (or similar 
format) video signals provided at subscriber terminals, 47 C.F.R. 
76.62 and .605; delivery of closed captioning information, 47 
C.F.R. 76.606: and signal leakage. 47 C.F.R. 76.601(e). .605. 
.6()9(h) and .610-.617. NTSC is the analog television system 
currently used in the United States. Portions of the above rules 
also specify requirements for monitoring and measuring tech 
nical performance and resolving any interference resulting from 
cable system operation. The Commission's rules currently do 
not address compatibility between cable systems and extended 
features of subscribers' TV sets. VCRs and related equipment. 
" Section 624A(b)(2), Section 17 of the 1992 Cable Act, supra. 
10 Section 624A(c)( 1), Section 17 of the 1992 Cable Act. supra. 
" Section 624A(c)(2), Section 17 of the 1992 Cable Act, supra. 
12 See Section 624A(d), Section 17 of the 1992 Cable Act, supra. 
' ' See Notice of Inquiry. ET Docket No. 93-7, 8 FCC Red 725 
(1993).
1983
FCC 94-80 Federal Communications Commission Record 9 FCC Red No. 10
14. Subsequent to the NOI, representatives of the cable 
television and consumer electronics industries established 
the "Cable-Consumer Electronics Compatibility Advisory 
Group" (CAG) to address the various topics in the matter 
of cable equipment compatibility. This group submitted a 
number of proposals to address both short term and long 
term compatibility problems. Under the CAG plan, com 
patibility problems between cable systems and existing con 
sumer equipment would be addressed through consumer 
education and supplemental equipment that provides si 
multaneous access to multiple channels of cable service. A 
key element of the CAG plan for more substantial long 
term improvement in compatibility is the implementation 
of a "Decoder Interface" connector, an updated version of 
the existing EIA/'ANSI "multiport" connector. 14 This fea 
ture would be incorporated in "cable ready" TV receivers 
and VCRs to enable use of component cable de- 
scrambler/decoders. The component descrambler/decoders 
would connect to consumer devices through the Decoder 
Interface connector and process signals after the consumer 
device's tuner. This would avoid the current problems 
caused by the use of set-top devices that disable features of 
consumer equipment related to tuning. The CAG plan 
further provided that cable systems that use scrambling 
would be required to provide component de- 
scrambler/decoders to subscribers that have Decoder Inter 
face equipped receivers and VCRs. The CAG plan also 
specified that a standard cable television channel plan be 
used by both cable systems and "cable ready" consumer TV 
equipment.
15. On October 5. 1993, the Commission submitted to 
Congress its "Report to Congress on Means for Assuring 
Compatibility Between Cable Systems and Consumer Elec 
tronics Equipment" ("Compatibility Report"). 15 In the 
Compatibility Report, the Commission concluded that the 
most appropriate course of action for addressing the cable 
system/consumer electronics compatibility matter would be 
a three phase plan. The first phase of this plan would 
provide immediate relief for the existing base of consumer 
equipment. The second would require more substantial 
measures in terms of standards for new equipment by both 
the cable and consumer electronics industries towards 
achieving more effective compatibility in the near future. 
The final step would encourage the development of con 
sumer equipment and cable technologies that are more 
fully compatible in the long term. Consistent with this 
general plan, the Commission made a number of rec 
ommendations for specific steps to improve compatibility. 
These steps reflect the requirements for regulations speci 
fied in Section 17 and also include many elements of the 
plan suggested by the CAG. including reliance on sup 
plemental equipment and consumer education to address 
problems with existing equipment, the use of the Decoder 
Interface connector and component descrambler/decoders 
to achieve more effective compatibility with new equip 
ment and a requirement that new and rebuilt cable systems
use a standard channelization plan. The Commission fur 
ther indicated that these recommendations would form the 
basis for its proposals for compatibility regulations.
16. On November 10. 1993. the Commission adopted the 
Notice in this proceeding, proposing rules for ensuring 
compatibility between cable systems and consumer equip 
ment that are consistent with the recommendations in the 
"Compatibility Report." Comments and/or replies respond 
ing to the Notice were submitted by 49 parties. 10
DISCUSSION
17. Our goal in this proceeding is to assure compatibility 
between cable service and consumer electronics equipment 
so that cable subscribers can use the special features and 
functions of their TV sets and VCRs when receiving cable 
signals. Our compatibility rules must also allow for the 
needs and interests of cable operators in protecting their 
signals against theft or unauthorized use. We further be 
lieve it is important that these rules provide for and en 
courage competition in the market for equipment used by 
subscribers to receive cable service. Such equipment in 
cludes channel converters, remote control units and other 
customer premises equipment. The new regulatory pro 
gram and rules set forth in the following sections are 
intended to reflect a balance of these considerations, while 
also minimizing the burdens they impose on consumers, 
cable operators and manufacturers of consumer electronics 
equipment.
Basic Approach for Achieving Compatibility
18. In the Notice, we proposed to employ the three-phase 
plan recommended in the "Compatibility Report" for 
achieving compatibility between cable systems and con 
sumer electronics equipment. The first phase of this plan 
seeks to provide immediate relief for the existing base of 
equipment. In this first step, cable operators would be 
required to offer their subscribers supplemental equipment 
for resolving the specific compatibility problems addressed 
in Section 17. refrain from scrambling signals carried on 
the basic service tier, provide consumer education and 
allow the use of customer-owned remote controls. The 
second phase would specify measures as are necessary that 
relate to new equipment to be taken by both cable systems 
and consumer electronics manufacturers to achieve more 
effective compatibility in the near future. These measures 
would include new technical standards for "cable ready" 
consumer equipment, the use of Decoder Interface connec 
tors and associated component descrambler/decoders and a 
standard cable channel plan for new "cable ready" con 
sumer equipment and cable systems. The final step would 
be to develop standards for the next generation of cable 
and consumer electronics equipment. In this regard, we 
indicated that we intended to standardize the system used 
by the cable industry for digital transmissions. We recog 
nized, however, that developmental work in this area is 
still in progress. We therefore requested suggestions for a
14 The Decoder Interface would be an extension of the 
"multiport" connector that was included in a few TV receiver 
models several years ago. The multiport connector generally did 
not achieve significant use. however. Additional description of 
the Decoder Interface connector and the associated component 
descrambler/decoder is provided in the "Compatibility Report." 
infra.
15 See "Report To Congress On Means Of Assuring Compati 
bility Between Cable Systems and Consumer Electronics 
Equipment," Federal Communications Commission, adopted 
October 5. 1993.
16 The parties filing comments and/or replies are listed in 
Appendix B.
1984
9 FCC Red No. 10 Federal Communications Commission Record FCC 94-80
regulatory plan that would complete the development of a 
digital cable standard in a manner that would allow for 
timely and efficient introduction of consumer products that 
could receive digital cable service.
19. In the Notice, we also indicated that while the above 
approach appears to be the most practical solution for 
resolving the major problems of compatibility between ca 
ble systems and the special functions of consumer electron 
ics equipment, we nonetheless believe the most desirable 
solution is for cable systems to use technologies that pro 
vide all authorized signals "in the clear." 17 We therefore 
stated that we intend to encourage the use and develop 
ment of cable signal delivery methods, such as traps, inter 
diction, addressable filters and other clear channel delivery 
systems, that eliminate the need for any additional equip 
ment on the subscriber's premises.
20. Most of the commenting parties generally concur 
with the basic approach of our proposal for achieving 
compatibility, although many disagree with, or suggest 
modifications to. specific elements of that plan. 1 * For exam 
ple, the CAG submits that our proposals represent a 
milestone toward realization of the objectives of Section 17 
and that it supports the overall thrust and most of the 
details of this plan. The CAG states that greater ease-of-use 
improvements and cost savings are achievable only after a 
longer period of time, as both cable and consumer equip 
ment are redesigned, and that the advent of digital cable 
transmission methods provides an opportunity to "get it 
right." It also agrees that our proposals to rely on an 
updated Decoder Interface connector and associated 
descrambler/decoder units, conformance by both cable sys 
tems and "cable ready" consumer equipment with a stan 
dard channel plan and new tuner and shielding standards 
for "cable ready" consumer equipment will avoid the need 
for use of set-top boxes in a cost effective manner for both 
cable system operators and their subscribers. Many other . 
parties representing the interests of cable operators, manu 
facturers of consumer electronics consumer and consumers 
present similar statements and/or express support for the 
position expressed by the CAG. These parties generally 
agree that, given the large embedded base of consumer 
television equipment, the goal of improving compatibility 
cannot be achieved in a single step or completed in an 
abbreviated period of time.
21. O.D. Page (Page) and the Titan Corporation (Titan) 
argue that rather than adopt the Decoder Interface ap 
proach, which would result in ownership of more 
descrambler/decoder units by cable operators, we should 
allow subscribers to purchase descrambling equipment 
from third parties, while allowing cable operators to main 
tain control over the conditional access functions of the 
devices. They contend that current encryption technology 
is sufficiently secure to effectively prevent "piracy" even 
when incorporated in consumer equipment. Titan states 
that cases where the security system might be compromised 
could be handled by including security circuitry on re 
placeable "smart cards." Page and Titan argue that this 
approach would avoid the current cable industry monopoly
on such equipment and allow the production of consumer 
equipment that would be more compatible with cable ser 
vice.
22. A number of parties urge that we proceed cautiously 
in developing and applying standards for new equipment. 
These parties believe that rules adopted now to ensure 
compatibility may not provide the flexibility needed for 
development of future technologies, which will involve the 
increasing convergence of digital video, telecommunica 
tions, computing and other types of information process 
ing. For example. General Instrument Corporation (GI), 
Greater Media. Inc. (Greater Media) and Tele-Communica 
tions. Inc. (TCI) argue that a rule requiring all cable 
services to be delivered through the Decoder Interface 
would stifle the introduction of innovative cable technol 
ogies and services. The American Telegraph and Telephone 
Company (AT&T) and Bell Atlantic submit that the pro 
posed regulations regarding use of the Decoder Interface 
could inadvertently inhibit the development of competing 
video delivery service, such as video dialtone, and standards 
for future technologies. Bell Atlantic points out that the 
transmission parameters of the new Decoder Interface stan 
dard being developed by the CAG are markedly different 
from those of the Asymmetric Digital Subscriber Line 
(ADSL) technology it is deploying for a video dialtone 
trial. AT&T and the United States Telephone Association 
(USTA) submit that we should apply the rules adopted 
herein only to today's analog equipment. BellSouth Tele 
communications, Inc. (BellSouth) asks that we clarify that 
the compatibility regulations being adopted herein apply 
only to cable systems and do not apply to local exchange 
carriers providing video dialtone services. In its reply com 
ments, the, National Cable Television Association (NCTA) 
disagrees with the concerns of those parties that argue the 
Decoder Interface standard might not be appropriate for 
use with distribution media other than cable or that it 
might impede the introduction of new services. NCTA 
states the Decoder Interface proposed by the CAG should 
be able to accommodate new technological developments 
without ever requiring the use of set-top boxes on TV 
receivers and VCRs equipped with Decoder Interfaces.
23. The New York City Department of Telecommunica 
tions and Energy (NYC) and the Lakes Region Cable Tele 
vision Consortium (LRCTC). an organization of several 
communities in New Hampshire, support our intent to 
encourage use of cable security technologies that provide 
signals to subscribers "in the clear." NYC and LRCTC 
indicate that their constituents are experiencing the types 
of problems resulting from use of set-top devices that are 
discussed in Section 17 and the Notice. For example, 
LRCTC states that its constituents have been confused and 
frustrated by the local cable system's recently-initiated 
scrambling of satellite-delivered signals. Multichannel Com 
munications Sciences. Inc. (MCSI) submits that we should 
take specific steps to encourage use of "in the clear" tech 
nologies. MCSI argues that the Decoder Interface standards 
development process is likely to be lengthy and that con 
sumer equipment with Decoder Interface connectors will 
not be available before the year 2000. It believes we should 
only rely on the Decoder Interface for accommodating
' With "in the clear" technologies, all of the signals a sub 
scriber purchases are available simultaneously, so that multiple 
signals may be tuned, for viewing or recording, at the same 
time.
18 The commenting parties' requests for modification and/or 
clarification of specific aspects of our proposals are discussed in 
the sections which follow.
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FCC 94-80 Federal Communications Commission Record 9 FCC Red No. 10
digital transmissions. MCSI therefore recommends that 
more substantial compatibility be achieved in two separate 
steps: the first would implement channel tuning and RF 
interface improvements; the second would implement a 
Decoder Interface for accommodating digital transmissions. 
To provide an incentive for cable operators to use "in the 
clear" technologies, it asks that we allow higher benchmark 
rates for tiered program services delivered "in the clear." 
In its reply comments, the Consumer Electronics Retailers 
Coalition agrees that specific incentives would be useful to 
promote the development and use of "in the clear" tech 
nologies.
24. On the other side, commenting parties representing 
cable interests argue that we should abandon our pref 
erence for "in the clear" service. For example. TCI states 
that "in the clear" technologies have shortcomings as cable 
security measures and that we should not influence cable 
operators to use such technologies in lieu of scrambling. 
The CAG similarly argues that while traps, interdiction, 
broadband scrambling and related techniques each may 
have certain virtues, they all have limitations and char 
acteristics that prevent them from being a reasonable a 
mandatory solution to compatibility issues. TCI further 
argues that we should not provide a competitive advantage 
to technologies competing with scrambling. GI contends 
that our preference for clear channel technologies is con 
trary to the demonstrated virtues of scrambling.
25. Cablevision Systems Corporation (CVS) opposes the 
general approach of our proposals for improving compati 
bility. CVS contends that our short-term proposals regard 
ing supplementary equipment and mandatory provision of 
basic tier signals "in the clear" threaten to compromise 
signal security, create further consumer confusion and re 
verse advances in "set-top devices made to resolve interfer 
ence, picture quality, channelization and signal leakage 
problems. Rather than the multiple provisions proposed in 
the Notice, CVS believes that it would be preferable to 
require only a consumer information and education pro 
gram in the short term.
26. Several parties, including CVS. Continental 
Cablevision. Inc. (Continental) and GI argue that any re 
quirements and standards that we adopt for cable should 
also be applied to other multichannel video programming 
providers, such as direct broadcast satellite service (DBS). 
TV receive-only (TVRO) satellite service, satellite master 
antenna TV systems (SMATVs) and video dialtone. These 
parties submit that similar problems of compatibility exist 
with respect to other video delivery media and are also 
concerned that the compatibility regulations for the cable 
industry could leave cable operators at a competitive dis 
advantage with respect to other video media. In its reply 
comments. DIRECTV. Inc. disagrees with these parties, 
arguing that subjecting other video media to the cable 
compatibility requirements would constrain the ability of 
such media to employ alternative video interfaces and digi 
tal delivery systems.
27. We find that the three-phase approach proposed in 
the Notice will provide the most efficient and effective 
means for achieving compatibility between cable systems 
and consumer electronics equipment. 19 The provisions of 
the first phase of this program recognize the difficulties 
inherent in improving compatibility between existing cable 
system and consumer equipment that cannot be readily 
modified. The thrust of these provisions is to ensure that 
cable subscribers are aware of compatibility problems and 
to require cable operators to take a series of meaningful 
steps to minimize the effects of compatibility differences. 
Cable operators will be required to assist their subscribers 
in overcoming the most troublesome problems, particularly 
those involving the use of multiple tuning functions that 
are addressed in Section 17 of the 1992 Cable Act. The 
plan of the second phase is to take advantage of the op 
portunity for designing new equipment to achieve more 
effective compatibility. The final phase will seek to ensure 
compatibility between cable systems and consumer equip 
ment in the transition to the next generation of cable 
technologies, while also attempting to allow maximum 
flexibility for new technologies and services to develop.20
28. We believe the gradual nature of this regulatory 
program reasonably balances the statutory factors we are 
required to consider in prescribing these regulations.21 Our 
approach will minimize the burdens of achieving compati 
bility for both industry and consumers, while also bringing 
the benefits of cable compatibility to consumers by mini 
mizing the interference to. or nullification of. the special 
functions of TV receivers and VCRs." We have also at 
tempted to minimize the burdens of the specific provisions 
of this plan and to distribute those burdens across the cable 
operators, manufacturers of consumer electronics equip 
ment and consumers. Moreover, with the exception of 
programming carried on the basic tier of service, the new 
rules will continue to allow cable operators to use their 
own discretion in choosing the method they use to protect 
their programming from theft.
29. We disagree with Page and Titan that we should 
require cable operators to allow consumers to own 
descrambling equipment and to purchase such equipment 
from third parties. While we are aware that there have 
been advancements in encryption technology, we also un 
derstand that it is most important to cable operators that 
they be able to control the means used to access their 
programming. Moreover, signal thieves have been notori 
ously successful at defeating security systems for video pro 
gramming services. We therefore will not require cable 
systems to allow their subscribers to own descrambling 
equipment. We do. however, recognize that it is possible to 
separate access control functions from other functions that 
may be performed in conjunction with the use of cable 
service, such as display of menus and decompression of 
digital signals. As discussed in the next section, we support 
separation of these functions as a means for promoting 
competition in the market for equipment used to receive 
cable service.
|l) We also conclude that this phased-in regulatory approach is 
consistent with the requirements of Section 17 that we. within 
180 days after submission of the "Compatibility Report" to 
Congress, "issue such regulations as are necessary to assure such 
compatibility." and "review, and if necessary, modify the regu 
lations issued pursuant to this section in light of any actions 
taken in response to such regulations and to reflect improve 
ments and changes in cable systems, television receivers, 
videocassette recorders and similar technology." Sections 
624A(b)(l) and (d), Section 17 of the 1W2 Cable Act. supra.
20 The rules adopted herein are set forth in Appendix A.
21 Section 624A(c)(l). Section 17 of the 1W2 Cable Act. supra.22 Id.
1986
9 FCC Red No. 10 Federal Communications Commission Record FCC 94-80
30. We share the concerns of those parties who urge that 
we proceed cautiously in adopting compatibility rules and 
standards for new equipment, digital systems and other new 
technologies and services. While we expect that the De 
coder Interface connector will be flexible enough to ac 
commodate most, if not all. of the attributes of cable digital 
service, we also appreciate that any such standard could 
constitute a gateway that constrains the development of 
new technologies. Moreover, the potential for such a con 
straining effect is substantially greater in the current pe 
riod, where there is rapid development of new 
communications technologies and services that are distinct 
ly different from those available in the past. Further, as 
AT&T and Bell Atlantic observe, the development of cable 
digital services will also be accompanied by questions about 
the compatibility of those services with other media. In 
view of these considerations, we believe the best approach 
is to plan for compatibility with future technologies and 
services to the extent possible now, with the understanding 
that it may be necessary to accommodate new develop 
ments that may not be fully compatible with standards we 
adopt now. If new digital and other technologies have 
important features that are not compatible with the stan 
dards we adopt now, we will make appropriate changes in 
our rules to accommodate their operation. In this regard, 
we intend to initiate a separate proceeding, as discussed 
below, to consider digital standards for cable service. As 
part of that proceeding, we will ensure that new incompati 
bilities do not arise between the digital service provided by 
cable systems and the digital equipment used by consumers 
to receive that service.
31. We disagree with those parties who argue that we 
should not seek to promote the use of "in the clear" 
technologies. While scrambling provides a high degree of 
security for cable operators, it also is the greatest source of 
equipment compatibility problems for consumers. We are 
not convinced that it is not feasible to develop a security 
approach that provides comparable security at a cost effec 
tive price while delivering subscribers all authorized signals 
in the clear. We applaud the efforts of MCSI and others to 
develop and introduce "in the clear" security systems. 
While we are not mandating the use of any form of "in the 
clear" technologies, we will continue to pursue policies 
that will promote the development and use of such sys 
tems. MCSI's request that we allow higher benchmark rates 
for tiered cable services provided "in the clear" is beyond 
the scope of this proceeding.
32. We reject CVS's suggestion that we limit our first- 
phase rules for ensuring compatibility to requirements for 
consumer' education and information. We believe that the 
additional compatibility measures we are requiring provide 
more effective compatibility and. contrary to CVS's sugges 
tion, continue to provide signal protection. Thus, we con 
clude that CVS's approach would not effectively ensure 
that there is compatibility between cable service and con 
sumer electronics equipment, and therefore would not as 
effectively implement the thrust of Section 17 of the 1992 
Cable Act as our approach.
33. In response to the issues raised by BellSouth. CVS, 
Continental and GI about application of the cable compati 
bility rules to other video media, we are clarifying that the 
rules adopted herein will apply only to operations by a 
cable system, as defined in Section 76.5(a) of our rules.23 
Application of these rules to other video media is beyond 
the scope of this proceeding. We will consider issues con 
cerning compatibility among alternative services in the ap 
propriate context, as they might arise.
Decoder Interface Connector
34. In the Notice, we proposed to require that "cable 
ready" equipment include a Decoder Interface connector 
that meets the specifications of the existing multiport stan 
dard, EIA/ANSI 563." We also noted that the CAG, in 
conjunction with the Joint Engineering Committee (JEC) 
of the EIA and the NCTA was developing an updated 
version of this standard to provide a hybrid analog/digital 
Decoder Interface that would be able to be used for both 
present analog signals and new digital TV signals. 25 The 
new Decoder Interface standard is also being designed to 
accommodate further advances in video transmission sys 
tems and services. We therefore proposed to adopt this 
updated standard, as an alternative to the multiport stan 
dard, if it were available in sufficient time for us to obtain 
comment on it before we complete our decision in this 
matter. We also proposed to require cable system operators 
that do not use "in the clear" signal delivery technology to 
supply their subscribers with component de- 
scrambler/decoders to process scrambled and/or digital vid 
eo service through the Decoder Interface and to provide 
service in a form that is compatible with a component 
descrambler/decoder. Consistent with our recommendations 
in the Compatibility Report, we further proposed to re 
quire cable operators to provide component descramblers 
to subscribers without a separate charge for the equipment 
or its installation.
35. The majority of the commenting parties support our 
proposal to promote fuller compatibility through use of a 
Decoder Interface connector and associated component 
descrambler/decoder devices. They also strongly recom 
mend that we adopt the updated Decoder Interface stan 
dard being developed by the JEC. rather than the current 
EIA/ANSI 563 standard. The CAG indicates that while the 
JEC's efforts to develop a new standard are not yet com 
plete, it has made substantial progress in that endeavor.211 
The commenting parties therefore urge that we invoke the 
substantial discretion accorded to the Commission by Sec 
tion 17 and adopt rules regarding the Decoder Interface 
requirements after completion of the new standard.
36. In recommending this course of action, the CAG 
states that the cable and consumer electronics industries 
believe that the JEC's updated standard would be much
" 47 C.F.R.  76.5(a).
24 See The Electronics Industry Association/American National 
Standards Institute's "Standard Baseband (Audio/Video) Inter 
face Between NTSC Television Receiving Devices and Periph 
eral Devices." EIA/ANSI-563-1WO (EIA/ANSI 563).
25 These future digital video signals would include both com 
pressed standard definition and advanced television signals.
The CAG included a copy of the "Interim Report of the
JEC's Decoder Interface Subcommittee on EIA IS-105" that 
presents the current state of the work on developing the new 
Decoder Interface standard. This interim report states that the 
new EIA IS-105 standard will provide complete compatibility 
with all of today's analog scrambling systems and has also been 
designed to be extensible to future digital services. This docu 
ment also indicates the work that remains to be completed.
1987
FCC 94-80 Federal Communications Commission Record 9 FCC Red No. 10
more beneficial for cable subscribers than the existing 
EIA/ANSI 563 standard and that they are firmly committed 
to completing the development and implementation a new 
Decoder Interface connector.27 GI, Greater Media and TCI 
point out that EIA/ANSI 563 is incompatible with certain 
analog scrambling methods, digital video compression and 
the numerous interactive media on the horizon. The Joint 
Cable Commenters and Zenith Electronics Corporation 
(Zenith) submit that the improvements in the new stan 
dard, particularly the ability to accommodate all current 
analog scrambling methods and to provide a solid transi 
tion path to digital transmissions, are worth the wait for 
the new standard to be completed. CVI notes that the 
updated standard will also support on-screen display and 
force tuning functions. The Interactive Media Association 
(IMA) believes that the new standard will provide a good 
foundation for the development of new products and ser 
vices while insulating consumers from the costs and com 
plexities of evolving technology. NCTA. in its reply 
comments, indicates that the design of the updated De 
coder Interface will provide the necessary avenues for new 
services, whether transmitted in analog mode or modulated 
digital or baseband digital modes.28
37. Several parties, including Circuit City Stores. Inc. 
(Circuit City). Mitsubishi Electronics of America 
(Mitsubishi) and News Datacom, Inc. (News Datacom) sub 
mit that the Decoder Interface standard should provide for 
separating conditional access technology, i.e., security mea 
sures, from other functions performed through the De 
coder Interface connector. These parties state that this 
approach is needed to provide for a competitive market in 
equipment used to receive cable service. They are con 
cerned that the Decoder Interface standard could otherwise 
allow cable operators to bundle into component 
descrambler/ decoder dnits devices, and thereby achieve a 
monopoly on. circuitry for features other than security, 
such as decompression, program selection and menus. 
These parties state that separating conditional access tech 
nology from other functions in the Decoder Interface stan 
dard would allow processing circuitry for new features of 
cable service to be integrated into new TV receivers and 
VCRs or into new set-top or decoder/descrambler equip 
ment that would be available on the open market. 
Mitsubishi observes that the JEC has made significant 
progress towards a standard for an inexpensive "conditional 
access card" that isolates all security elements into one 
removable medium and that this could be incorporated 
into the updated Decoder Interface standard. Circuit City 
and Mitsubishi urge that we advise the CAG to implement 
the conditional access card as part of the Decoder Interface 
standard.
38. Many parties also address our proposals with regard 
to cable operators' responsibilities to supply subscribers 
with component descrambler/decoders. to do so without 
separate charges and to provide service in a format that is 
compatible with these devices. On a related issue. MCSI 
requests that we clarify our policy with regard to charges 
by cable systems for descrambling equipment that may be
located either inside or outside of a subscriber's premises. 
MCSI believes that cable operators should be allowed to 
charge separately for this equipment, which it argues per 
forms the same functions as set-top descramblers.
39. We concur with the commenting parties that the 
public interest would be better served by adopting an up 
dated Decoder Interface standard. The introduction of this 
feature in new consumer TV equipment and its use with 
component descrambler/ decoders will constitute a signifi 
cant step toward achievement of more effective compatibil 
ity between cable systems and consumer electronics 
equipment at reasonable cost. The numerous improve 
ments in the forthcoming standard, particularly its capabil 
ities for serving all existing scrambling systems, for 
accommodating new cable technologies and services and 
for providing a migration path to digital cable service, 
make it a clear choice over the existing EIA/ANSI 563 
standard. Moreover, as noted by the IMA, the improve 
ments in the new standard are expected to provide a sub 
stantial buffer to consumers against new incompatibilities 
that typically arise from the differences in equipment cy 
cles in the consumer electronics and cable industries.2"
40. We recognize that the JEC has been working 
diligently on the new standard and that considerable 
progress has been made relatively quickly in these efforts. 
We also note that the time period available for addressing 
the complex technical and design issues in this standard 
has been very short, and that additional time is needed to 
complete this work. Accordingly, we will establish a De 
coder Interface standard and address all aspects of rules 
regarding its use, including consideration of whether we 
should not allow cable operators to charge separately for 
component descrambler/decoders and require them to pro 
vide service in a format that is compatible with these 
devices, pending completion of an acceptable updated stan 
dard. We will also address MCSI's request for clarification 
of our policy on separate charges for equipment that can 
be located either inside or outside a cable subscriber's 
premises after the completion of an acceptable Decoder 
Interface connector standard.
41. We wish to emphasize that we consider the Decoder 
Interface connector and associated component de 
scrambler/decoders to be an important part of our equip 
ment compatibility program and therefore are concerned 
that the new standard be completed as expeditiously as 
possible. We believe a period of 90 days from the publica 
tion of this decision should be sufficient for the JEC to 
complete its work on the Decoder Interface standard. We 
urge the JEC to continue in its efforts and to finalize the 
new Decoder Interface standard within this 90-day period. 
If the new standard is not available after that period, we 
will establish a standard using our own internal resources.
42. We agree with those commenting parties who argue 
that the Decoder Interface should provide the capability to 
separate signal access control functions from other func 
tions served through the connector. This capability will 
allow non-security functions to be provided through new 
products offered by retail vendors or to be incorporated
- The CAG also indicates that the cost of including the
Decoder Interface in consumer TV equipment will be relatively
low.
28 NCTA explains that the Decoder Interface is expected to
include approximately 20 pins, plus both RF and IF connectors.
It states that by designing the point of compatibility as the
juncture where the television receiver or VCR interface receives 
the pins of the companion component descrambler/decoder. vir 
tually any service or distribution technology can be accom 
modated.
M Thus, we conclude that it is not necessary to adopt rules 
regarding a Decoder Interface connector standard at this time.
1988
9 FCC Red No. 10 Federal Communications Commission Record FCC 94-80
into TV receivers and VCRs. thereby promoting competi 
tion in the market for equipment used to receive cable 
service. We therefore are advising the parties developing 
the new standard that the Decoder Interface standard we 
adopt must allow access control functions to be separated 
from other functions. While our statutory mandate directs 
us to ensure compatibility between consumer electronics 
equipment and cable systems, we do not wish to accom 
plish that goal at the expense of impeding consumer access 
to competing video delivery systems, such as home satellite 
dish, Direct Broadcast Satellite and wireless cable. We 
therefore urge that representatives of those and other af 
fected industries be included in the Decoder Interface stan 
dard deliberations.
Rules for Existing Equipment
43. Supplemental Equipment . In the Notice, we proposed 
to require cable systems that use scrambling to provide 
their subscribers with supplemental equipment, such as 
set-top devices with multiple descramblers and/or timers 
and by-pass switches, to enable the operation of extended 
features and functions of TV receivers and VCRs that make 
simultaneous use of multiple signals. This equipment 
would be provided upon the request of individual subscrib 
ers. We further proposed to require cable operators to 
provide their subscribers the option of receiving all signals 
whose reception does not require use of a converter di 
rectly at the subscriber's TV receiver or VCR, without 
passing through a set-top device. This capability could be 
provided through use of by-pass switches or similar equip 
ment, or by avoiding the need for use of set-top devices 
altogether. We also proposed to allow cable systems to 
provide supplemental equipment for improving compatibil 
ity at the request of individual subscribers and to permit 
them to charge for this equipment and its installation in 
accordance with our rate regulations for customer premises 
equipment used to receive the basic service tier. 10
44. The commenting parties generally support the pro 
posed requirements for provision of supplemental equip 
ment by cable systems. The CAG and GI submit that, 
collectively, these measures will facilitate the use of ad 
vanced picture generation and display features in TV re 
ceivers, allow subscribers to watch one program while 
recording another and permit sequential recording of pro 
grams on different channels, albeit with some additional 
cost and wiring complications. The CAG indicates that the 
widespread availability of supplementary hardware will 
ameliorate many of the compatibility problems Section 17 
seeks to address. TCI states that given the unsynchronized 
technology cycles of the cable and consumer electronics 
industries, these supplementary devices will always play an 
important role in achieving compatibility.
45. A number of the commenting parties suggest modi 
fications to our proposals regarding supplemental equip 
ment. To save consumers time and money. John Fitzgerald, 
a cable subscriber, suggests that the rules also provide that 
subscribers may pick-up the supplemental equipment from 
their cable system's operations center and install it them 
selves. The Joint Cable Commenters ask that the language 
relating to delivery of unscrambled programming "without
passing through the set-top device" be clarified, as many 
set-top devices have internal bypass switches. NYC recom 
mends that we require that supplementary equipment pro 
vided by cable operators to improve compatibility include 
stereo outputs on baseband audio terminals. The Sacra 
mento Metropolitan Cable Television Commission 
(SMCTC) recommends that these requirements be 
strengthened to specify that the "more consumer-friendly" 
set-top boxes have at least an 8-event/7 day 
programmability capability.
46. Parties representing cable interests generally favor 
our proposal to allow cable operators to charge for sup 
plementary equipment in accordance with the provisions 
of our rate regulations. TCI, Time Warner Entertainment 
Company. L.P. (Time Warner) and others state that this 
approach will allow cable operators to recover all the cost 
of such equipment and also will distribute the cost to those 
who need the equipment. NYC also agrees that we should 
allow cable operators to charge for supplemental equip 
ment in accordance with our rate regulations, but recom 
mends that we not allow cable operators to charge for its 
installation. NYC states that prohibiting charges for in 
stallation would encourage cable operators to fully inform 
subscribers of installation options at the time of the initial 
installation. SMCTC submits that we should allow a one- 
time installation charge for supplementary hardware, but 
not allow separate ongoing monthly charges. CVS submits 
that we should not require cable operators to offer sub 
scribers both multiple descramblers and bypass switches. It 
argues that this would create consumer confusion and con 
tribute to signal leakage, low picture quality and other 
technical problems. CVS submits that cable operators 
should be allowed to determine the appropriate mix of 
technology for resolving compatibility problems. Greater 
Media requests that we clarify that dual descrambler de 
vices would be available from cable operators, rather than 
from retailers.
47. We conclude that the supplemental equipment pro 
posed in the Notice offers the means to achieve immediate 
relief for the compatibility problems between existing cable 
systems and consumer electronics equipment in cases 
where cable systems use" scrambling technology and set-top 
boxes that do not deliver all authorized signals "in the 
clear." In such cases, devices such as by-pass switches and 
set-top devices that include multiple descramblers and/or 
timers that can be programmed to tune to alternative chan 
nels sequentially can. to a significant degree, provide cable 
subscribers with the ability to operate the types of special 
functions with their VCRs and TV receivers that are ad 
dressed in Section 17 of the 1992 Cable Act. We therefore 
are adopting our proposal to require cable operators that 
use scrambling systems to offer their subscribers supple 
mental equipment to enable the operation of extended 
features and functions of TV receivers and VCRs that make 
simultaneous use of multiple signals.-" We also conclude 
that compatibility problems resulting from use of set-top 
devices can be reduced if subscribers are able to receive "in 
the clear" all signals that need to be processed by the 
device. This capability can generally be provided through a 
by-pass switch, or as indicated by the Joint Cable Oper-
M See 47 C.F.R.  76.923.
" As discussed below, in the section addressing the consumer 
education program, cable operators will also be required to 
advise their subscribers that, except for hardware used only to
control signal access, e.g., set-top boxes with multiple 
descramblers, supplemental equipment for improving compati 
bility may also be obtained from retail outlets.
1989
FCC 94-80 Federal Communications Commission Record 9 FCC Red No. 10
ators. through internal by-pass circuitry in a set-top box. 
We therefore are requiring cable operators to offer their 
subscribers the capability to receive "in the clear" all sig 
nals that do not need to be processed by descrambling or 
other special circuitry in a set-top device.
48. We are not specifying a particular "package" of 
supplemental hardware that must be provided by cable 
systems nor the performance characteristics of the features 
of such equipment. The amount and types of supplemental 
hardware needed to resolve compatibility problems will 
vary depending on a variety of factors, including the con 
sumer electronics equipment used by individual cable sub 
scribers, the types of compatibility problems subscribers 
desire to address, whether they desire special features such 
as stereo or multiple-day timing capability, and how much 
consumers are willing to pay for the improvements they 
want. In order to provide cable operators latitude to tailor 
supplemental hardware to the needs of individual subscrib 
ers, the rules only will identify the general types of sup 
plemental hardware to be offered and the types of 
compatibility problems that are to be addressed through 
such hardware. We will simply require cable operators to 
undertake a good faith effort to provide the types of equip 
ment needed by individual subscribers. While we encour 
age cable operators to allow subscribers to pick up 
supplemental equipment from the cable system's oper 
ations center, we are not requiring this practice. This is 
consistent with our existing policy that allows cable oper 
ators to determine their own installation practices. 
Inasmuch as the purpose of supplemental equipment is to 
improve individual subscribers' use of cable service, we 
believe the cost of this equipment and its installation 
should be the responsibility of those subscribers who re 
quest it. We therefore will allow cable operators to charge 
for this equipment and its installation in accordance with 
our rate regulations for customer premises equipment used 
to receive basic service. Subscribers may. of course, choose 
to use supplemental equipment obtained from retailers for 
resolving compatibility problems, rather than obtain that 
equipment from their cable system. As indicated below, 
cable operators will be required to notify their subscribers 
that supplemental equipment for improving compatibility 
may be obtained from retail outlets. In response to Greater 
Media's concern, these requirements do not require that 
cable system operators allow subscribers to use multiple 
descrambler/decoder equipment that might be obtained 
from retailers or other parties.
49. Scrambling of Signals on the Basic Service Tier. In the 
Notice, we proposed to prohibit cable systems from 
scrambling signals carried on the basic tier of cable service. 
This proposal was intended to ensure that consumers who 
have purchased TV receivers and VCRs capable of tuning 
basic service channels are able to continue to receive ser 
vice on those channels without the need for a set-top 
device. We also observed that cable systems often include
additional channels on their basic tier beyond those re 
quired to be on the basic tier under our rules.32 We 
requested comment on whether such signals should be 
exempted from the prohibition on scrambling of signals on 
the basic tier.
50. The CAG. GI, NYC. Pacific Bell. SMCTC. Time 
Warner and others generally support our proposal to pro 
hibit scrambling of signals on the basic tier. Several of 
these parties note that, as we observed in the Notice, in 
current practice the basic service tier is nearly always 
unscrambled. They state that this is because theft of basic 
service is less of a problem than is theft of other services, 
and that it is beneficial to allow subscribers to access basic 
tier channels without using a descrambling set-top box. 
Pacific Bell and John Fitzgerald point out that scrambling 
any basic tier signals necessitates that subscribers rent a 
set-top descrambler from the cable system to receive all of 
the signals purchased. Pacific Bell states that prohibition 
on scrambling of basic tier signals will avoid the need for 
this additional equipment and thereby reduce consumers' 
real cost to subscribe to basic only service. In joint reply 
comments, the Consumer Federation of America and the 
Home Recording Rights Coalition (CFA/HRRC) suggest 
that cable operators should not be allowed to scramble any 
signals on regulated tiers of service that were not scrambled 
prior to the enactment of the 1992 Cable Act.33 They state 
that it is reasonable to presume that if a signal were not 
scrambled before the 1992 Cable Act. there is no need to 
scramble the signal now or later. CFA/HRRC submits that 
for exceptions to this rule, we should establish a procedure 
allowing for public comment, where an operator would 
have the burden of demonstrating that a significant security 
threat that did not exist previously now exists or that a new 
service offered as part of a regulated tier should not be 
offered in the clear.
51. Most of the commenting parties that support prohib 
iting the scrambling of basic tier signals also believe that a 
waiver procedure is needed to allow cable systems exper 
iencing theft of service problems to scramble basic chan 
nels. -u The CAG states that such a procedure should pro 
vide for expedited handling of waiver requests and that a 
more exacting burden of proof should apply to waivers 
involving mandatory basic tier signals, e.g., local broadcast 
signals or access channels for public, education, or govern 
ment services, than waivers involving non-mandatory chan nels.35
52. A number of commenting parties representing cable 
interests oppose our proposal to prohibit scrambling of 
signals carried on the basic service tier. These parties gen 
erally submit that scrambling of signals on the basic tier is 
not a problem because such scrambling is not a common 
practice. These parties further argue that in some cases 
scrambling of basic service is needed to protect against 
signal theft. Continental states that a prohibition of 
scrambling on the basic tier will discourage cable operators
32 Section 76.901(a) of our rules provides that the basic service 
tier shall, at a minimum, include all signals of domestic broad 
cast stations provided to any subscriber (except a signal secon 
darily transmitted by satellite carrier beyond the local service 
area of such station, regardless of how such signal is ultimately 
received by the cable system), any public, educational and gov 
ernmental (PEG) programming required by the franchise to be 
carried on the basic tier and any additional video programming 
signals added to the basic tier by the cable operator. See 47 
C.F.R. 76.901(a).
33 Regulated tiers include the basic service tier and cable 
programming service tiers, as defined in Section 76.9()l(a) and 
(b) of our rules. 47 C.F.R. 76.9()l(a) and (b).
34 The CAG states that cable systems at increased risk of signal 
theft may include those for which demand is highly affected by 
seasonal considerations, those that have high subscriber 
turnover, and those that experience measurable loss of effective 
ness in their existing security techniques.
 i5 The signals required to be carried on the basic tier are 
specified in Section 76.901 of the rules, 47 C.F.R. 76.9<)l(a).
1990
9 FCC Red No. 10 Federal Communications Commission Record FCC 94-80
from adding services to that tier. CVS states that where 
recurrent non-payment situations are common, scrambling 
also reduces costs by allowing the cable operator to manage 
service without a truck-roll to disconnect and reconnect 
service. CATA also is concerned that the use of compressed 
video could be viewed as scrambling and that the proposed 
rule could then preclude small systems with a limited 
number of channels from using compression technology.
53. Barden Cablevision (Barden) argues that a prohibi 
tion on scrambling signals on the basic tier would ignore 
serious exposure to theft for single tier cable operators. 
Barden suggests that, if we adopt the scrambling prohibi 
tion, we modify it for single tier cable systems to either 
delay its implementation until such time as new technol 
ogies are readily available to facilitate compatibility be 
tween signal scrambling and consumer equipment, or 
exempt such systems where they have already installed 
scrambling.
54. Many parties representing cable interests argue that, 
at a minimum, we should exempt from the scrambling 
prohibition all channels carried on the basic tier beyond 
those required to be carried there. Barden and the Joint 
Cable Commenters state that such an exemption would 
preserve cable operators' ability to use scrambling to pro 
tect programming that is susceptible to theft. Barden also 
states that since most cable operators do not scramble basic 
tier signals, permitting them to scramble signals beyond the 
required tier components would have little impact on the 
overall effectiveness of our program for improving equip 
ment compatibility. Continental suggests that if we decide 
to prohibit scrambling on the basic tier, we should also 
grandfather existing systems that have historically scram 
bled basic signals as an anti-theft measure, and provide a 
waiver process for systems facing serious theft problems. 
NYC. Pacific Bell and SMCTC believe that the prohibition 
on scrambling of signals on the basic tier should apply to 
all signals carried on that tier. Pacific Bell argues that since 
the price of basic service includes the cost of any non- 
mandatory channels added to the basic tier, cable subscrib 
ers are entitled to receive those channels without the need 
to use additional equipment for which an additional fee is 
charged.
55. We find that our proposal to prohibit scrambling of 
signals carried on the basic tier is appropriate as a means 
to promote compatibility between cable service and con 
sumer electronics equipment. We also conclude that the 
prohibition on scrambling of basic signals should include 
both signals carried on the basic tier and any other signals 
that cable operators may choose to add to that tier. This 
rule will significantly advance compatibility by ensuring 
that all subscribers are able to receive basic tier signals "in 
the clear" and that basic-only subscribers will not need 
set-top devices at all. This rule also will have minimal 
impact on the cable industry in view of the fact that most 
cable systems now generally do not scramble basic tier 
signals.
56. We recognize that cable operators may have a stron 
ger interest in protecting "non-mandatory" signals carried 
on the basic tier than the required signals. However, the 
fact that cable operators generally do not scramble non- 
mandatory signals carried on the basic tier now is indica 
tive of the fact that theft of these signals is not a major
problem and that the scrambling prohibition will not dis 
courage cable operators from adding signals to the basic 
tier. On the other hand, as indicated by Pacific Bell and 
John Fitzgerald, routine scrambling of these signals would 
pose a problem for basic-only subscribers, because it would 
require them to rent a set-top descrambler and perhaps 
also to obtain supplemental equipment, at additional cost 
and inconvenience. Accordingly, we are prohibiting cable 
operators from scrambling any signals carried on the basic 
service tier.
57. We do, however, understand that there are instances 
where cable operators may need to scramble signals to 
prevent theft of service or to address other operating prob 
lems such as the billing situation indicated by CVS. To 
accommodate such cases, cable operators may seek a waiv 
er of the scrambling prohibition. Cable operators request 
ing such waivers will be required to demonstrate either a 
substantial problem with theft of basic tier service or a 
strong need to scramble basic signals for other reasons. As 
recommended by CFA/HRRC, cable operators will also be 
required to notify subscribers of waiver requests. Specifi 
cally, a cable operator must notify subscribers by mail that 
it has filed a request for waiver of the scrambling prohibi 
tion with the Commission. The notice to subscribers must 
be mailed no later than thirty calendar days from the date 
the request waiver was filed with the Commission. !6 The 
notice shall state the following:
On (date of waiver request was filed with the Com 
mission), (cable operator's name) filed with the Fed 
eral Communications Commission a request for 
waiver of the rule prohibiting scrambling of channels 
on the basic tier of service. 47 C.F.R. Section 
76.630(a). The request for waiver states (a brief sum 
mary of the waiver request). A copy of the request 
for waiver is on file for public inspection at (the 
address of the cable operator's local place of busi 
ness).
Individuals who wish to comment on this request for 
waiver should mail comments to the Federal Com 
munications Commission by no later than 30 days 
from (the date the notification was mailed to sub 
scribers). Those comments should be addressed to 
the: Federal Communications Commission. Cable 
Services Bureau. Washington. D.C. 20554. and 
should include the name of the cable operator to 
whom the comments are applicable. Individuals 
should also send a copy of their comments to (the 
cable operator at its local place of business).
A cable operator may file comments in reply to subscriber 
comments no later than 7 days from the date subscriber 
comments must be filed. In assessing the waiver request, 
the Commission will consider issues raised in the sub 
scriber comments and the cable operator's response to such 
issues in light of the criteria indicated above in determin 
ing whether to grant a waiver.
58. Although we are not adopting CFA/HRRCs sugges 
tion that cable operators not be allowed to scramble any 
signals carried on regulated tiers that were not scrambled 
prior to the enactment of the 1992 Cable Act. we agree
 ih Cable operators must inform the Commission in writing, as 
soon as possible, of the date on which they mail the notification
to subscribers in order to allow the Commission to calculate 
correctly the filing deadline for subscriber comments.
1991
FCC 94-80 Federal Communications Commission Record 9 FCC Red No. 10
that such a policy merits further consideration. We agree 
with CFA/HRRC's position that it seems reasonable to 
presume that if a signal carried on a regulated tier was not 
scrambled before the 1992 Cable Act, there is no need to 
scramble that signal now or in the future. Moreover, as 
observed by Pacific Bell and John Fitzgerald, the routine 
scrambling of these signals also causes significant compati 
bility problems for subscribers by necessitating the use of 
set-top descramblers. However, we believe an expanded 
record on this issue will better aid us in our deliberations. 
Therefore, we intend to include consideration of this issue 
in the same upcoming Further Notice of Proposed Rule 
Making that will address the Decoder Interface standard 
and related issues.
59. In response to CATA's concern regarding compressed 
video carried on the basic tier, the Decoder Interface ap 
proach that we are pursuing should provide for processing 
of compressed video signals. We intend to investigate this 
matter further in our future proceeding on digital video 
transmission standards, as discussed below. We are not 
persuaded that our scrambling prohibition should be modi 
fied for single tier cable systems. Where such systems might 
experience signal theft problems they are free to re-tier as 
appropriate.
60. Remote Controls. In the Notice, we proposed to re 
quire cable operators that offer subscribers the option of 
renting remote control units to operate set-top devices to 
permit the operation of their set-top devices with such 
commercially available remote control units, and take no 
action that would prevent the use of such remote control 
units.J
61. The commenting parties that address this issue sup 
port our proposals for regulation of cable system remote 
control practices as consistent with the provisions of Sec 
tion 17. Greater Media states that cable operators may need 
to disable remote control functions either to respond to a 
request by a subscriber or to avoid conflicts between de 
vices in cases where two separate descramblers are used. 
CFA/HRRC submits that we should also prohibit cable 
operators from changing the infrared codes they use for 
remote controls if the new infrared codes will adversely 
affect the operation of previously-compatible remote con 
trols. CFA/HRRC states that, absent such a prohibition, 
new infrared codes could disable a remote control that was 
compatible when it was purchased, and consequently cable 
subscribers would be reluctant to purchase remote controls 
from retail outlets.
62. We are adopting a requirement that cable operators 
allow their set-top devices that incorporate remote control 
capability to be operated with subscriber-owned remote 
controls or otherwise take no action to prevent the use of 
such remote controls. This requirement is somewhat more 
encompassing than our proposal, which would only have 
applied this requirement to cable systems that rent remote 
control units. However, on reviewing Section 624(c)(2)(E) 
of Section 17 of the 1992 Cable Act. we find that the
statute mandates that this requirement apply to all cable 
systems.38 We advise cable operators that this requirement 
obliges them to actively enable the remote control func 
tions of set-top devices where those functions do not op 
erate without a special activation procedure.3M As an excep 
tion to this rule, we will permit cable operators to disable 
the remote control functions of a set-top device in cases 
where the subscriber so requests. Under this exception, a 
cable operator that needs to disable the remote control 
functions of a set-top box to resolve a problem, such as the 
conflict between two descramblers mentioned by Greater 
Media, could do so with the consent of the subscriber.
63. Our requirement that cable operators otherwise take 
no action to prevent the use of subscriber-owned remote 
controls also includes CFA/HRRC's suggestion that we pro 
hibit cable operators from changing the infrared codes used 
to operate the remote control capabilities of the set-top 
devices they employ. This requirement will necessitate that 
the remote control capabilities of any replacement cus 
tomer equipment provided to subscribers employ the same 
infrared codes for remote control that are used with the 
subscriber's existing set-top equipment. This will avoid the 
need for subscribers to replace remote control units they 
own if the cable operator changes their set-top box. We do 
not believe this will be a significant burden for cable 
operators, as they can simply chose replacement equipment 
that operates with the same infrared codes as their existing 
equipment.40 This requirement will not prevent cable oper 
ators from using new equipment that includes additional 
infrared codes for new remote control functions that were 
not included in existing models of equipment.
64. Consumer Education. In the Notice, we proposed to 
require cable operators to provide a consumer education 
program on compatibility matters to their subscribers. This 
information would be provided to cable subscribers in 
writing at the time they first subscribe and at least once a 
year thereafter.41 As proposed, the consumer education 
program would include a written notification that, in cases 
where a set-top device is used to receive service, subscribers 
may not be able to use special features and functions of 
their TV receivers, including functions that allow the sub 
scriber to:
- View a program on one channel while simulta 
neously recording a program on another channel:
- Record two or more consecutive programs that 
appear on different channels; and.
- Use advanced picture generation and display fea 
tures such as "Picture-in-Picture." channel review 
and other functions that necessitate channel selection 
by the consumer device.
The proposed consumer education program would further 
require cable operators to inform subscribers that some 
models of TV receivers and VCRs may not be able to
 ' We also proposed to permit cable operators to disable the 
remote control functions of a subscriber's set-top device in cases 
where the subscriber so requests.
 '" Section ()24A(c)(2)(E), Section 17 of the 1W2 Cable Act. 
supra.
 !U We note that the remote control functions of many existing 
models of set-lop devices do not operate unless they are ac 
tivated by a code transmitted from the cable system headend.
4(1 In quantity orders, cable operators will be able to specify the 
specific codes to be used in new equipment. 
4 ' After the initiation of service, cable systems would be 
permitted to choose the time and means by which to meet the 
annual consumer information requirement. For example, cable 
systems could choose simply to include the yearly consumer 
information on compatibility in a mailing with one of their 
regular billings to subscribers.
1992
9 FCC Red No. 10 Federal Communications Commission Record FCC 94-80
receive all of the channels offered by the cable system 
when connected directly to the cable system. It would also 
briefly explain the types of channelization incompatibilities 
subscribers could encounter when connecting their equip 
ment directly to the cable system and offer suggestions for 
resolving channelization problems. Such solutions could 
include the use of a set-top channel converter device that 
subscribers could obtain from either the cable operator or 
a third party retail vendor.
65. We also proposed to require cable operators that 
offer remote control capability with their set-top devices to 
include in their consumer education program a written 
notification that subscribers may purchase from other 
sources a remote control unit that is compatible with the 
set-top devices. Under this proposal, cable systems would 
be required to list the models of remote control units that 
are compatible with the set-top devices they employ and to 
provide a list of sources where those models can be ob 
tained in the local area. This list would be required to be 
current as of no more than 60 days before the yearly 
mailing of consumer information.
66. The commenting parties generally support our pro 
posal for a consumer information program. For example, 
the CAG believes the proposed consumer information re 
quirements will satisfy the information requirements of 
Section 624A(c)(2)(B) and will generally assist cable sub 
scribers in understanding compatibility problems they may 
encounter. It indicates that although these requirements 
will apply to the cable industry, the consumer electronics 
industry will assist in developing educational materials for 
meeting the new requirements.
67. The commenting parties also request modifications to 
some of the specific requirements of our proposal. CVS 
asks that we clarify that the requirement to inform sub 
scribers of the availability of set-top converter devices from 
third party vendors applies to basic converters without 
descrambling capability and that cable operators do not 
have to advise their subscribers of the commercial avail 
ability of descrambling equipment, including addressable 
decoders. Greater Media notes that a subscriber's remote 
control equipment may no longer be functional if the cable 
system changes his/her converter unit. It requests that in 
such cases a cable operator's responsibility not extend be 
yond the need to caution subscribers that such situations 
may occur from time to time. NYC requests that the 
consumer education requirements be extended to encour 
age or require cable operators to produce and carry com 
patibility education programs, to provide such programs to 
governmental access channel operators and to refer their 
subscribers to educational information through announce 
ments in their billing statements.
68. TCI requests that we specify that cable systems elect 
ing not to offer their subscribers the option of renting a 
remote control do not have to comply with the remote 
control provisions of the consumer education require 
ments. In this regard, TCI observes that pursuant to new 
Section 624A(c)(2)(E) of the Communications Act of 1934. 
as amended, cable systems will not be allowed to disable 
the remote control capability of their set-top devices. It 
observes that cable systems could provide remote control 
capability, and indeed most will have to because most 
models of set-top boxes incorporate that capability, and also 
choose not to rent remote controls.
69. The commenting parties universally argue that the 
proposed requirement for cable operators to list all of the 
specific models of commercially available remote controls
that are compatible with their set-top devices and specific 
vendors of those devices is too burdensome. Many parties 
state that with literally hundreds of models of remote con 
trols on the market, it is simply not practical to expect that 
accurate lists of compatible remote controls can be com 
piled or that such lists would remain accurate for any 
length of time. They also point out that it would be dif 
ficult to identify merchants carrying compatible remote 
control units and to determine relevant market areas. NYC 
notes that in a city like New York, a list of retailers that 
carry compatible remotes would be extremely long and 
would be subject to constant revision. Media General Cable 
of Fairfax County. Inc. (Media General) argues that local 
retailers can adequately communicate the availability of 
their products to consumers themselves.
70. The commenting parties suggest a number of alter 
native approaches for informing cable subscribers about 
the availability of compatible remote controls that are in 
tended to minimize the burden of this task. The CAG 
recommends that cable operators be required to provide 
information explaining the different types of remote con 
trols that are compatible with its set-top boxes and to 
compile and distribute lists that show the names and tele 
phone numbers of remote control manufacturers and/or 
marketers. It also recommends that cable operators be re 
quired to supply subscribers periodically with the manufac 
turers and model numbers of the set-top devices they 
supply. The CAG and Greater Media further state that a 
good faith omission of a particular manufacturer should 
not expose a cable operator to legal liability. CVI. Con 
tinental. Media General. SMCTC and TCI suggest that we 
require cable operators to inform subscribers of the manu 
facturers and model numbers of the equipment'they em 
ploy and advise them that compatible remote controls may 
be available from retail suppliers. TCI also proposes that 
the mailing encourage subscribers to contact the cable 
operator to ask about the compatibility of a particular 
device they might be considering.
71. We continue to believe that a requirement for cable 
operators to provide their subscribers a consumer educa 
tion program at regular intervals is necessary and desirable 
to inform subscribers of compatibility issues and solutions 
and to advise them of the availability of set-top converters 
and remote control units from third parties, as required by 
Section 17 of the 1992 Cable Act. While we find that our 
proposed plan for the consumer education program is gen 
erally appropriate for these purposes, the final require 
ments we are adopting include a number of modifications 
in response to the submissions of the commenting parties. 
Accordingly, we are adopting our proposed consumer edu 
cation program with the modifications and clarifications 
indicated below.
72. First, in response to the concern expressed by CVS. 
we are clarifying that the requirement to advise subscribers 
of the availability of set-top devices from retailers applies 
only to basic converters without descrambling or other 
access control functions. This is consistent with our posi 
tion, as discussed above, that we do not believe it is desir 
able to require cable operators to make their security 
technology available for ownership by the public. Consis 
tent with the requirements for cable operators to offer 
subscribers supplemental equipment for improving com 
patibility, cable operators will also be required to advise 
their subscribers that supplemental equipment for improv 
ing compatibility may also be obtained from retail
1993
FCC 94-80 Federal Communications Commission Record 9 FCC Red No. 10
outlets.42 In response to Greater Media's request regarding a 
caution to subscribers about changes in the operation of 
remote controls if the cable operator changes set-top boxes, 
we note that, as indicated above in paragraph 63. we are 
prohibiting cable operators from changing the infrared 
codes used to operate the remote control capabilities of the 
set-top devices they employ. Thus, subscribers will not 
need to be cautioned about loss of use of their remote 
controls in such cases.
73. We find that, except as discussed below, the basic 
structure and content of our proposed consumer education 
program provides an appropriate balance between the need 
to properly inform cable subscribers about matters of com 
patibility and the burden the requirements impose on cable 
operators. We therefore are not extending the consumer 
education requirements to include the additional elements 
suggested by NYC. In response to TCI's request, we are 
clarifying that cable systems that elect not to offer their 
subscribers the option of renting a remote control will still 
have to comply with the remote control provisions of the 
consumer education requirements. Although Section 17 
only refers to systems that rent remote controls, we none 
theless conclude that the interests of ensuring compatibility 
necessitate that the consumer education provisions regard 
ing remote controls apply to ail cable systems that employ 
subscriber equipment that is capable of being remotely 
controlled. We also wish to clarify that the requirement for 
the consumer information program to be provided to sub 
scribers annually does not necessitate that the information 
be provided to individual subscribers on the anniversary of 
the date they first subscribed to the service. This require 
ment may be satisfied through a once-a-year mailing to all 
subscribers.
74. We are persuaded that the proposed requirements for 
cable operators to list all of the models of commercially 
available remote control devices that are compatible with 
their set-top devices and vendors that carry those models 
would, in fact, be impractical and overly burdensome. We 
therefore are adopting a revised plan that will provide 
adequate information to cable subscribers about the avail 
ability of compatible remote control units while minimiz 
ing the burden on cable operators of providing that 
information. The revised plan is a composite of all the 
alternatives discussed above. Under this plan, cable oper 
ators that employ subscriber equipment that is capable of 
being remotely-controlled will be required to include in 
their consumer education program a written notification 
that subscribers may purchase from other sources a remote 
control unit that is compatible with the set-top devices. 
They will also be required to identify the models of set-top 
devices they provide to their subscribers and to include a 
representative list of the remote control units currently 
available from retailers that are compatible with the set-top 
devices they employ. Cable operators will be required to 
make a good faith effort in compiling the list of currently 
available compatible remote controls: they will not be held 
accountable for inadvertent omissions. We are not requir 
ing cable operators to list local retailers that carry compati 
ble remotes. Rather, we encourage cable operators and 
their industry associations to coordinate with the suppliers 
of their set-top devices and the consumer electronics in 
dustry to compile lists of compatible remotes. These lists
will be required to be current as of no more than six 
months before the yearly mailing of consumer information. 
Finally, cable operators will be required to encourage sub 
scribers to contact the cable operator to ask whether a 
particular remote control unit would be compatible with 
the subscriber's set-top box.
75. Implementation of Rules for Existing Equipment. In the 
Notice, we indicated that it appears that the rules for 
improving compatibility between cable system and con 
sumer equipment can be implemented relatively quickly. 
We therefore proposed to make these requirements effec 
tive six months after we adopt final rules for equipment 
compatibility.
76. The commenting parties generally agree that these 
rules can be implemented in the time period proposed in 
the Notice. The CAG and Time Warner also recommend 
that we permit scrambling of basic signals that was occur 
ring as of December 1, 1993, when the Notice was released, 
to continue pending the adjudication of waiver requests 
filed in a timely manner. The CAG further states that an 
exception needs to be made regarding provision of dual- 
tuner set-top devices by cable systems. The CAG submits 
that some cable box manufacturers do not yet have such 
products available and that it may take an additional 12 
months before this equipment can be expected to be gen 
erally available. It suggests allowing an 18-month period 
before requiring cable systems to provide dual-tuner set-top 
boxes.
77. We conclude that the rules for existing equipment 
generally can be implemented expeditiously. that is. within 
six months, without imposing substantial burdens on cable 
operators. These requirements can be met with existing 
models of supplemental equipment, minor reconfigurations 
of, or software changes to, existing cable facilities and 
preparation of relatively brief texts and lists of equipment 
to inform cable subscribers about compatibility problems 
and how they can be resolved. Accordingly, the compatibil 
ity rules for existing equipment will be effective October 
31. 1994. We are. however, providing several exceptions to 
this schedule. First, we are making the prohibition on 
scrambling of signals carried on the basic tier of service 
effective July 31. 1994. We believe that this approximately 
three month period is an adequate amount of time for 
cable systems to alter their operations or construction plans 
to comply with the scrambling prohibition. In accordance 
with the information provided by the CAG, we will also 
delay implementation of the requirement for cable oper 
ators to provide set-top devices with multiple tuners until 
October 31, 1995. We advise cable operators that the re 
quirements for other items of supplemental equipment will 
become effective on the six-month schedule. We also find 
that it will not be difficult for cable systems to comply with 
the requirements to allow their set-top devices that incor 
porate remote control capability to be operated with sub 
scriber-owned remote controls. The requirement for cable 
system operators to allow their set-top boxes to be operated 
with subscriber-owned remote controls therefore will be 
come effective May 31. 1994.
42 This notification requirement will not apply to hardware 
used only to control signal access, e.g., set-top boxes with mul 
tiple descramblers.
1994
9 FCC Red No. 10 Federal Communications Commission Record FCC 94-80
Rules for New Equipment
"Cable Ready" Consumer Equipment Standards
78. Definition of "Cable Ready" Equipment. In the Notice, 
we proposed to require that all consumer electronics 
equipment marketed as "cable ready" or otherwise 
marketed as intended for connection directly to cable ser 
vice comply with the new "cable ready" equipment stan 
dards.
79. The CAG, Sharp Electronics Corporation (Sharp) 
and Zenith submit that the proposed definition of "cable 
ready" equipment is too broad. In statements representative 
of their position, the CAG indicates that the inclusion of 
"equipment otherwise marketed as intended for connection 
directly to cable service" in the definition would preclude 
consumers from having access to products that are capable 
of being connected to cable service, but which are not 
claimed to be "cable ready" as defined in the rules. It 
argues that the consumer electronics industry should re 
main free to manufacture and market, and consumers 
should be free to purchase, products that have none, or 
only some, of the characteristics to be required of "cable 
ready" sets. Zenith states that TV equipment that can tune 
most or all of cable channels, but does not include the 
other features required under the "cable ready" standard, is 
needed to continue to serve millions of consumers with a 
low cost product. The CAG recommends that we simply 
apply the new standards to those products which are ex 
pressly claimed to be "cable ready" or for which the same 
claim is made using substantially the same language.
80. On the other side. Cox Cable Communications and 
Newhouse Broadcasting Corporation (Cox), the Joint Cable 
Commenters and TCI believe that we should require all TV 
receivers and VCRs that can tune cable channels to comply 
with the technical standards for "cable ready" equipment. 
This would prohibit the marketing of consumer TV equip 
ment with an extended tuning range that does not conform 
to the "cable ready" requirements. These parties argue that 
the inclusion of tuning capability beyond the broadcast 
channels in a TV receiver or VCR is tantamount to imply 
ing that the device is meant for connection to cable service. 
As an alternative to prohibiting equipment that has an 
extended tuning range but does not fully comply with the 
"cable ready" standards, the Joint Cable Commenters sug 
gest that we require such equipment be labeled to warn 
potential purchasers that it may not operate properly when 
connected directly to cable service.
81. TCI and Time Warner believe that we should adopt 
point-of-sale notification and labeling requirements for the 
consumer electronics industry to advise consumers of po 
tential compatibility problems that may occur if a "non- 
cable-ready" TV set or VCR is connected directly to cable 
service. They state that consumer education by cable oper 
ators will do little good if the TV receiver or VCR exper 
iencing a problem was purchased by a consumer who was 
not properly informed of possible problems at the point- 
of-sale. TCI therefore recommends that we require that. 
prior to purchase, consumers be notified that some features 
of a "non-cable-ready" TV or VCR may not work or may 
not be necessary if the unit is connected to a cable system.
and that they be encouraged to consult their local cable 
operator for further information. TCI also suggests that we 
require that "non-cable-ready" consumer TV equipment be 
labeled to indicate the tuning range of the device and to 
inform consumers that certain features of the device may 
not be compatible with some of the services they may 
choose to purchase from cable operators. It further pro 
poses that we require manufacturers of third-party remote 
controls to list on a unit's packaging the cable set-top 
devices with which it is compatible.
82. We agree with the CAG. Sharp and Zenith that our 
proposed application of the "cable ready" equipment stan 
dards would be too broad. We do not believe it is desirable, 
from the standpoint of either consumers or manufacturers 
of consumer electronics equipment, to preclude marketing 
of consumer TV equipment that has some, but not all. of 
the characteristics of "cable ready" equipment. For exam 
ple, a TV receiver that has the capability to tune some or 
all of the cable channels but is not equipped with a De 
coder Interface connector or enhanced receiver perfor 
mance features may be satisfactory for many consumers. In 
this regard, we observe that not all consumers are affected 
by equipment compatibility problems and that others may 
be satisfied with resolving such problems through use of 
supplemental equipment. Similarly, not all consumers will 
be affected by emissions ingress and egress problems as a 
result of connection of their TV equipment directly to 
cable service. In such cases, consumers should not have to 
bear the added cost of equipment that provides full com 
patibility when they do not need it. We therefore will 
apply the technical standards for "cable ready" consumer 
electronics equipment only to devices specifically marketed 
as "cable ready" or "cable compatible." J
83. We nonetheless are concerned that simply limiting 
the applicability of the "cable ready" standards in this 
manner and allowing all other products that have varying 
features intended to enhance their suitability for use with 
cable service could lead to confusion for consumers about 
the extent to which the products that are available to them 
in the market are compatible with cable service. To dif 
ferentiate "cable ready" products from other products with 
features intended for use with cable service, we are requir 
ing that consumer TV receivers and VCRs that incorporate 
features intended to be used with cable service but do not 
fully comply with the "cable ready" standards be labeled 
with an advisory that appears on the device and on its 
packaging. This advisory shall indicate that the product 
does not fully comply with the FCC's requirements for 
cable compatible equipment. As a corollary, the new rules 
also provide that equipment that does not comply with the 
"cable ready" standards may not be marketed with ter 
minology that describes the device as "cable ready" or 
"cable compatible." or that otherwise conveys the impres 
sion that the device h fully compatible with cable service.
84. We are not extending the labeling and advisory re 
quirements to remote control units. These units are not 
subject to requirements that they have the capability to 
command cable set-top devices and therefore may not be 
intended for use with a cable set-top device. We also be-
4-! We consider the terms "cable ready" and "cable compatible" to be equivalent 
and interchangeable. Consistent with the provi sions 
of Section 624A(c)(2) of Section 17 of the 1992 Cable Act,
supra, the new technical standards adopted herein will apply to 
consumer electronics equipment marketed as "cable ready" or 
"cable compatible."
1995
FCC 94-80 Federal Communications Commission Record 9 FCC Red No. 10
lieve that consumer electronics manufacturers will have an 
incentive to advise consumers of which, if any. set-top 
devices their remote controls are able to command.
85. Channel Tuning. In the Notice, we proposed to re 
quire that "cable ready" TV receivers and VCRs have the 
capability to tune all cable channels over a frequency range 
of 54 MHz to 1 GHz in accordance with the cable channel 
identification plan specified in the new EIA IS-132 stan 
dard developed by the JEC.44 We also requested comment 
on whether it might be desirable to provide a "migration 
plan" to full 1 GHz tuning capability that would first 
require cable channel tuning capability somewhat lower 
than 1 GHz. such as 750 MHz. and then later require full 1 
GHz capability.
86. The commenting parties addressing this issue support 
the use of EIA IS-132 as the standard channel plan for 
cable service and the tuning standard for "cable ready" TV 
receivers and VCRs. They generally agree that use of this 
plan will minimize the need to use set-top converters for 
tuning purposes. These parties differ, however, with regard 
to their views on the upper frequency to which "cable 
ready" equipment should be required to tune. The CAG 
recommends that "cable ready" consumer equipment be 
required to tune to 800 MHz, rather than 1 GHz. In 
support of the CAG's position. Zenith states that a require 
ment to tune to frequencies higher than 800 MHz would 
be unnecessary with the vast majority of cable systems in 
view of the trends in technology towards digital compres 
sion, which reduces the need for cable systems to use 
higher frequencies. Zenith also submits that a higher mini 
mum upper tuning requirement would add to the cost of 
consumer electronics equipment. It submits that the tuning 
range requirement could be increased in the future if 
appropriate. CVI recommends that "cable ready" equip 
ment be required to tune frequencies up to 750 MHz and 
that devices with digital and/or HDTV capability be able to 
tune channels up to 1 GHz. CVS, Mitsubishi. NYC. 
SMCTC and TCI believe that all new TV receiver equip 
ment should be capable of tuning up to 1 GHz to avoid the 
renewed use of set-top converters when cable systems are 
inevitably built to operate up to that frequency. Mitsubishi 
believes that no migration path to the higher frequency 
range is needed. NYC states that a migration plan would 
only serve to confuse consumers.
87. GI submits that it is possible that digital transmission 
channels might use a bandwidth larger or smaller than 6 
MHz and that we therefore should apply the EIA IS-132 
channel plan only to analog video signals. TCI submits that 
while it supports a 1 GHz tuning requirement, it believes 
the best solution would be to require "cable ready" TV 
receivers and VCRs to incorporate modular tuners. It states 
that adding modularity to consumer equipment would pro 
tect consumers from premature obsolescence caused by the 
unsynchronized cycles of the cable and consumer electron 
ics industries.
88. Bell Atlantic submits that use of frequencies below 
54 MHz is feasible for cable service and that use of these 
frequencies may be preferable for digital video services. It 
suggests that we extend the lower range of the channel 
tuning capability of consumer electronics equipment to 
include the 5 to 54 MHz frequency band.
89. We continue to believe that adoption of the EIA 
IS-132 channel plan as the standard cable television chan 
nel plan will further compatibility between cable systems 
and consumer TV receivers and VCRs. As noted by the 
commenting parties, adherence to this standard will mini 
mize the need to use set-top converters for tuning pur 
poses. This standard also provides channels across all 
frequencies from 54 MHz up to 1 GHz and beyond and is 
consistent with the channel plan currently used by most 
cable systems. We concur with the CAG and Zenith that 
800 MHz seems adequate as the minimum required upper 
tuning frequency for cable channels. In this regard, we 
agree with Zenith that 800 MHz is an appropriate choice 
for this standard in light of expectations for the upper 
range of frequencies that will be used by cable systems and 
the fact that a higher tuning requirement would unneces 
sarily add to the cost of consumer TV sets and VCRs. In 
considering 800 MHz as the minimum upper tuning re 
quirement, we also observe that currently all TV broadcast 
receivers are required by our rules to be capable of receiv 
ing all channels allocated to the television broadcast ser 
vice. Under this requirement, TV receivers are required to 
tune up to and including UHF channel 69. or 800-806 
MHz. Inasmuch as TV receivers normally incorporate a 
single tuner for both cable and broadcast channels and the 
appropriate upper range for cable is essentially the same as 
the existing broadcast tuning requirement, we believe it 
would be appropriate to adopt the minimum tuning range 
for broadcast channels as the upper cable channel tuning 
requirement for "cable ready" equipment. Accordingly, we 
will require "cable ready" TV receivers and VCRs to tune 
to cable channels specified by the EIA IS-132 standard up 
to a minimum frequency range of 806 MHz. We will, of 
course, monitor developments in this area and take appro 
priate action in the future to alter the minimum tuning 
range requirement for "cable ready" equipment if neces 
sary.
90. New "cable ready" consumer TV equipment will not 
be required to use the EIA IS-132 channel plan for recep 
tion of digital signals. As discussed below, we will consider 
an appropriate channel plan for digital cable service in the 
context of our future proceeding on cable digital cable 
transmission standards. We also do not believe it is desir 
able to require that "cable ready" TV receivers and VCRs 
incorporate modular tuners. While manufacturers will 
have discretion to include modular tuners as features of 
new equipment, we do not find that there is sufficient 
likelihood that an alternative channel plan to EIA IS-132 
will arise to warrant requiring modular tuners in "cable 
ready" consumer equipment. Finally, we see no indication 
that cable services will be provided on channels in the
44 The new channel plan is an amended version of the former 
EIA/ANS1 IS-d channel plan. This new standard is known as the 
Electronic Industry Association's "Standard Cable Television 
Channel Identification Plan, IS-132, May 1994" (EIA IS-132). We 
note that EWANSI IS-6 accommodates full 1 GHz cable opera 
tion and that the new. amended channel plan maintains the 
former channel allocations for frequencies up to 1002 MHz, The 
new EIA IS-132 channel plan specifies frequency slots and as 
signs each a number for frequencies up to 1002 MHz and 
specifies a methodology for creating additional channels at high 
er frequencies. For example, a 1 GHz system using the new 
plan, would operate between 54 and 1002 MHz and would have 
the potential for 158 active channels. The CAG points out that 
EIA IS-132 does not require cable systems to deliver, or TV 
equipment to tune, any particular number of channels.
1996
9 FCC Red No. 10 Federal Communications Commission Record FCC 94-80
frequency range 5 to 54 MHz. We therefore will not extend 
the tuning standard for "cable ready" equipment to this 
area of the spectrum.
91. Receiver Performance Standards. In the Notice, we 
proposed various technical performance standards for "ca 
ble ready" consumer electronics equipment. These propos 
als were designed both to ensure proper operation of 
"cable ready" TV receivers, VCRs, and other consumer TV 
equipment with cable service and to prevent such equip 
ment from causing interference to cable systems. In par 
ticular, our proposals included technical standards to 
protect "cable ready" TV receivers and VCRs against adja 
cent channel interference, tuner overload and direct pick 
up of undesired signals. We also proposed standards for 
consumer electronic device signals conducted onto the ca 
ble system, radiated emissions, input selector switch isola 
tion and by-pass switch attenuation. The CAG submitted 
detailed comments on the proposed technical standards 
that include suggestions for several changes to the proposed 
standards and measurement procedures.45 CAG indicates 
that the technical standards it recommends for "cable 
ready" equipment are the result of a consensus agreement 
among the consumer equipment manufacturers and cable 
system operators. We are according CAG's comments con 
siderable weight since they generally appear to be based on 
sound engineering analysis and to represent an industry 
consensus. Each of the various elements of the new tech 
nical standards are discussed below.
92. A. Adjacent Channel Interference. To reduce interfer 
ence from signals on adjacent channels, we proposed to 
require that "cable ready" equipment not exceed a cri 
terion of "just perceptible" interference to the desired sig 
nal from an adjacent channel signal whose visual carrier 
level is 3 dB above the visual carrier level of the desired 
signal.4h We also requested comments on alternate test 
methods that do not rely on subjective observations of the 
television display.
93. The CAG indicates that, although adjacent channel 
performance is a combined response to lower and upper 
adjacent visual, chroma, and aural signals, industry exper 
ience has shown that interference from the lower adjacent 
aural carrier predominates. CAG also notes that, in prac 
tice the aural carrier of TV signals carried on cable systems 
is generally between 10 and 17 dB below the visual carrier 
signal level. Therefore, it believes that a standard based on 
a single unmodulated interfering carrier located 1.5 MHz 
lower in frequency and 10 dB lower in signal level than 
the visual carrier of the desired NTSC channel is sufficient 
to achieve our goal of adequate adjacent channel perfor 
mance. In addition, the CAG recommends that we evaluate 
compliance through objective measurements made at the 
TV receiver IF output port rather than subjective observa 
tions of "just perceptible" interference. Specifically, CAG 
submits that a 55 dB suppression ratio, as measured at the 
unfiltered IF output port of the television receiver, would 
be equivalent to "just perceptible" interference and there 
fore would be appropriate.
94. We find that CAG's statements and recommendations 
regarding the adjacent channel performance standard are 
technically sound. We agree with the CAG's position that 
measurement of lower adjacent channel interference will 
provide an adequate indication of the adjacent channel 
performance of a "cable ready" television receiver. Further, 
we find that the standard proposed by the CAG is generally 
equivalent to our proposal and will provide sufficient adja 
cent channel interference protection. We also observe that 
the CAG's proposed measurement method would be more 
accurate and reliable than our proposed method because it 
is based on objective, rather than subjective, tests. Objective 
testing would also be less burdensome for manufacturers, 
since these tests can be automated easily. Accordingly, we 
are adopting the standard and testing methods suggested by 
the CAG.
95. B. Tuner Overload. To avoid tuner overload, we 
proposed to require that the tuners of "cable ready" con 
sumer devices suppress distortion products on any fre 
quency in the desired channel at least 55 dB below the 
visual carrier.47 We also invited recommendations for a 
measurement procedure. The CAG proposes a procedure 
for measuring tuner overload and. based on this procedure, 
recommends that we require 51 dB suppression rather than 
55 dB. It further recommends that the standard apply only 
for signals up to 750 MHz.
96. The CAG's proposed test method calls for measuring 
the amplitude of spurious signals falling within the 6 MHz 
wide unfiltered IF relative to the amplitude of any tuned 
carrier. The CAG suggests that measurements be performed 
with a test signal that exposes the RF input of a "cable 
ready" television receiver to a comb of unmodulated car 
riers. The individual unmodulated carriers would have am 
plitudes of + 15 dBmV and be located at all possible visual 
carrier frequencies in the standard plan delineated in the 
EIA IS-132 standard. The CAG states that the +15 dBmV 
amplitude for the unmodulated carriers corresponds to the 
maximum amplitude of signals carried on cable signals. It 
also states that the comb of CW signals is appropriate for 
this test due to the mixing that can occur with multiple 
signals carried simultaneously on cable systems. The CAG 
believes it would be appropriate to require 51 dB suppres 
sion of distortion products with this test procedure, rather 
than our proposed 55 dB standard, because the average 
power levels of normal NTSC television signals is 6 dB 
lower than the CW carriers used for the measurements.
97. The CAG believes that the upper limit of the comb 
test signal should be 750 MHz because digital, rather than 
analog signals, will likely be used in cable systems that 
operate above this frequency. It states that the signal 
strength of digital transmissions is likely to be lower than 
NTSC analog transmissions by 5-10 dB. It further submits 
that digital signals will be more benign because the visual 
effect is more like a slight increase in noise rather than a 
discernable beat pattern in the picture. CAG also believes
45 The CAG asked Working Group II (WGII) of the JEC to 
examine tuner performance specifications and the specific tuner 
performance criteria proposed in the Notice. A copy of WGII's 
comments and recommendations was appended to CAG's com 
ments. CAG states that the comments and recommendations of 
WGII represent a consensus of the both the cable television and 
consumer electronics industries.
4" A 3 dB higher adjacent channel signal corresponds to the 
variation in adjacent channel signals permitted under Section 
76.605(4)(i) of our rules, 47 C.F.R. 76.605(a)(4)(i). 
4 ' Tuner overload results from the presence of many strong 
signals that interact and degrade the performance of the re 
ceiver.
1997
FCC 94-80 Federal Communications Commission Record 9 FCC Red No. 10
that if analog signals are used at these higher frequencies, 
they will be attenuated much more than lower frequency 
signals due to the differential loss in the drop cable.
98. We find that the test method suggested by the CAG is 
an adequate and appropriate means for measuring tuner 
overload performance. We are not persuaded, however, 
that the suppression level for distortion products should be 
51 rather than 55 dB. The CAG's suggested test method 
initially provides for input test signals that are 5 dB lower 
than the maximum limit of the amplitude of individual 
visual carriers ( + 20 dBmV) for cable systems specified in 
EIA Draft Standard IS-23.48 Accordingly, we are adopting 
our proposal that the tuners of "cable ready" consumer 
equipment suppress distortion on any frequency in the 
desired channel products at least 55 dB below the visual 
carrier. We generally accept CAG's argument that tuner 
overload need not be tested at higher frequencies. However, 
we will require testing up to 806 MHz, rather than CAG's 
proposal of 750 MHz, because this corresponds to the 
required tuning capability of "cable ready" TV receivers 
and VCRs.
99. C. DPU Interference. To address direct pick-up (DPU) 
interference, we proposed to require that "cable ready" 
equipment not exceed a criterion of "just perceptible" in 
terference in the presence of a 100 mV/m field generated 
by a CW source. The CAG suggests an alternative standard 
that employs measurements of interfering signal levels at 
the TV receiver IF referenced to specific carrier-to- 
interferer ratios, rather than subjective observations of "just 
perceptible" interference. Under the CAG's proposed test 
method, the receiver under test would be exposed to an 
external ambient radio frequency field whose amplitude is 
100 mV/m and whose frequency is 2.55 MHz above the 
visual carrier of the channel to which the receiver is tuned. 
Tests would be performed with the receiver tuned to each 
of six EIA IS-132 television channels (two each in the low 
VHP. high VHP and UHF broadcast band) whose individ 
ual RF levels are 0 dBmV. Susceptibility measurements 
would be made by rotating the unit under test 360 degrees 
until the maximum response in the unfiltered IF passband 
is obtained. The CAG recommends that with this measure 
ment procedure, we require suppression level on each test 
channel, as measured at the unit's IF output terminals, to 
be at least 45 dB below the response of the desired chan 
nel, i.e., a 10 dB reduction from the -55 dB proposed 
reference level. It further recommends that we require that 
the average of the suppression obtained for all of the 
channels tested be at least 50 dB. i.e., a 5 dB reduction. At 
frequencies between 800 MHz and 1002 MHz, in the case 
of equipment designed to tune in that range, the CAG 
suggests that tests be performed on six EIA IS-132 channels 
spaced approximately equally throughout the band. It rec 
ommends that the required suppression in this range be at 
least 35 dB on each individual channel and at least 40 dB 
for the average suppression of all channels measured.
100. The CAG believes that its proposed standard and 
measurement criteria are consistent with our proposed per 
formance criteria. In recommending requirements for sup 
pression ratios that are less than 55 dB. the CAG submits
test data indicating that susceptibility is strongly dependent 
on receiver orientation. It observes that, in conditions of 
actual use, receivers will be oriented randomly with respect 
to external fields, so that the average susceptibility will 
certainly be less than the tested maximum. It also states 
that the 100 mV/m external ambient field was based on 
signals present outdoors and does not take into account the 
average attenuation effects of buildings and other struc 
tures.
101. CVI believes that it would be more appropriate to 
use 250 mV/m as the maximum external ambient field 
strength for measuring DPU performance. In support of 
this proposal, CVI submits field intensity data measured in 
five communities. It claims that these measurements, 
which were made outdoors, show that the field intensity 
was greater than 250 mV/m in 19 percent of the samples 
and greater than 100 mV/m in 85 percent of the samples. 
CVI acknowledges, however, that some additional signal 
attenuation will occur due to structural shielding. It further 
states that although none of its submitted data included 
measurements made on UHF stations, it believes that field 
intensities from UHF stations tend to be higher than VHP 
stations. CVI believes this evidence supports a 250 mV/m 
field intensity for the DPU performance standard. In its 
reply comments. Zenith states that protecting consumer TV 
equipment against DPU in the presence of 250 mV/m 
external ambient field would not be technically practicable 
and is beyond what is economically justifiable in light of 
any potential advantage for consumers. SMCTC concurs 
with our proposal for DPU above 54 MHz. but recom 
mends the requirements include a 3 volts/m immunity 
standard below 30 MHz to protect against AM broadcast 
stations, Amateur Radio and Citizens Band stations which 
all could be in close proximity to cable subscriber.
102. We agree with the CAG that the direct measure 
ment of DPU interference at the TV receiver IF is prefer 
able to subjective measurements based on "just 
perceptible" interference. We further agree with the CAG 
that, given the directional variation in receiver DPU per 
formance, it is appropriate to establish standards for both 
individual channel DPU performance and the average of 
DPU performance for all measured channels. We also find 
the less stringent performance standards suggested by the 
CAG are appropriate in light of the fact that signal levels 
outdoors can be expected to be attenuated by walls and 
other structural components at indoor locations. The aver 
age susceptibility of the receiver in the home will in all 
probability be less than that determined under the pro 
posed test method.
103. While we recognize that ambient external fields may 
sometimes exceed 100 mV/m. as CVI indicates, we none 
theless agree with the CAG that 100 mV/m is the appro 
priate standard to specify for the level of the external 
ambient field. In this regard, we are concerned that a more 
stringent standard might result in significantly higher 
prices for "cable ready" equipment that would discourage 
consumers from purchasing these units. We also find that 
the level of protection that would be provided under the 
standard suggested by the CAG would be a significant
4S See Electronic Industries Association "RF Interface Speci 
fications for Television Receiving Devices and Cable Television 
Systems, EIA Draft Standard IS-23" (EIA IS-23). The specifica 
tions of this standard are used by the cable industry and con 
sumer electronics manufacturers to provide an effective
interface between cable service and consumer electronics equip 
ment that are intended for connection to cable service. EIA 
IS-23 provides that the maximum visual carrier level of individ 
ual signals carried on a cable system should be not more than 
+ 20 dBmV.
1998
9 FCC Red No. 10 Federal Communications Commission Record FCC 94-80
improvement over the current DPU performance of con 
sumer TV receivers and VCRs. The 100 mV/m level for 
external ambient field strength provides an appropriate 
balance of the competing concerns of the equipment cost 
and DPU protection. We also recognize CVI's point that 
field intensities in the UHF broadcast band may be some 
what higher than VHP. However, UHF fields also suffer 
greater attenuation through walls and other structural com 
ponents. We therefore are not adopting different standards 
for ambient fields on UHF frequencies. We also are not 
adopting SMCTCs proposal to extend the DPU standards 
adopted herein to frequencies below 54 MHz. as this area 
of the spectrum is not within the tuning range of receivers 
being considered in this proceeding. Accordingly, we are 
adopting standards to protect against DPU interference on 
"cable ready" consumer electronics equipment and asso 
ciated test methods as suggested by the CAG. The standards 
we are adopting will require measurement of DPU perfor 
mance of "cable ready" equipment on frequencies up to 
806 MHz. in accordance with our decision to specify 806 
MHz as the minimum upper tuning range for "cable 
ready" equipment.
104. D. Image Channel Interference. In the Notice, we 
indicated that it was our belief that consumer equipment 
that complies with the DPU ingress standard would also be 
less likely to experience interference from both cable and 
off-the-air signals on the "image frequencies." i.e., frequen 
cies that are removed 14 and 15 channels from the desired 
channel. The CAG states that when conventional 45 MHz 
IF frequencies are used in receivers along with high-side 
local oscillator (LO) injection, the receiver will have a 
potential response to the 15th higher channel on the sys 
tem regardless of the DPU shielding provided. The CAG 
further states that image channel response is primarily a 
function of the internal circuitry design of the receiver, not 
the external shielding efficiency, as both desired and image 
channels are received on the same cable. Thus, it believes 
that separate requirements are needed for image channel 
performance.
105. The CAG suggests that receivers whose conversion 
frequencies are such that a potential image frequency falls 
within the cable system bandwidth should be required to 
reject the image signal by at least 60 dB from 54 MHz up 
to and including 750 MHz. In this case, the CAG's recom 
mended suppression is 5 dB more stringent than the 55 dB 
equivalent of "just perceptible" interference. The extra 5 
dB is intended to provide for the variations in cable system 
signal levels that are permitted in a 1 GHz bandwidth 
system under Part 76 of our rules.4M Although Part 76 
allows a maximum variation of 17 dB in a 1 GHz system, 
the CAG contends that in a well-maintained cable system, 
the variation over approximately 90 MHz (15 channels) 
will be considerably less. From 750 MHz up to and includ 
ing 1002 MHz. the CAG recommends a minimum of 50 
dB rejection. The CAG's relaxed specification at higher 
frequencies reflects its previously stated position that these 
frequencies are likely to be used for low amplitude digital 
signals.
106. We agree with CAG's position that an image rejec 
tion performance standard is needed for consumer equip 
ment sold as "cable-ready." In this regard, we are 
persuaded that DPU specifications will not prevent image 
problems in consumer equipment. We also agree that, in 
order to allow for variations in cable signal levels 
permitted under Part 76 of our rules, a standard that is 5 
dB more stringent than the equivalent of "just perceptible" 
interference is justified for this standard. The CAG's rec 
ommendation for reducing the image channel suppression 
standard for frequencies above 750 MHz also appears rea 
sonable in light of the expectation that signals on fre 
quencies in this range will be of relatively lower amplitude. 
Further, to be consistent with our decision on the mini 
mum upper tuning requirement for "cable ready" equip 
ment, upper limit of the image rejection standard will be 
806 MHz. It seems reasonable to extend this limit from 750 
MHz up to the upper tuning range limit. Accordingly, we 
are requiring that "cable ready" equipment suppress image 
signals by at least 60 dB from 54 MHz up to and including 
806 MHz.50
107. E. Conducted Emissions. In the Notice, we proposed 
to require that the level of RF emissions conducted onto a 
cable system by a "cable ready" consumer device be no 
more than -37 dBmV, referenced to 75 ohms, over the 
frequency range 54 MHz to 1002 MHz. The CAG believes 
our proposed conducted emissions limit is too stringent. It 
argues that our proposal is based on worst case conditions 
that are not likely to occur and fails to take into account 
variations in the factors that cause conducted interference. 
For example, it notes that our proposed limit assumes that 
the cable subscriber is receiving the minimum signal level 
of 0 dB required under our rules. The CAG submits that 
in most cases the signal delivered to the subscriber is 
considerably stronger. It observes that we also assumed that 
the cable system provides the minimum isolation between 
subscriber drops required under the rules. It submits that 
in most cases greater isolation is provided. The CAG fur 
ther notes that there is considerable variability in the levels 
and the frequencies at which internally generated emissions 
are produced in equipment. It states that this fact should be 
weighed against the low probability that other near-by ca 
ble subscribers will be tuned to a channel receiving the 
interfering emissions. The CAG therefore argues that it is 
likely that most conducted emissions from consumer TV 
equipment will be well below the proposed -37 dBmV 
limit. The CAG also claims that manufacturers will design 
their products with sufficient compliance margin to ac 
count for variations in performance across production 
units.
108. The CAG recommends that we adopt two different 
standards for conducted emissions: one for emissions 
caused by signals generated internally within the device 
and another for emissions caused by retransmission of sig 
nals introduced into the device from external sources. For 
conducted emissions caused by local oscillator emissions 
and other signals internally generated within the consum 
er's device. CAG proposes the following limits:
49 See 47 C.F.R. 76.605(a)(4)(ii).
511 In testing for compliance with this standard, image rejection 
shall be the ratio of desired to undesired RF carriers measured 
within the IF passband of the receiver. The undesired signal 
shall be a CW carrier equal in amplitude to the desired channel 
visual carrier and located 90 MHz above the visual carrier 
frequency of the channel to which the receiver is tuned. The
desired signal shall be an NTSC signal with visual carrier levels 
of 0 dBmV and + 15 dBmV modulated with a 10 IRE flat field 
and an unmodulated aural carrier level that is 10 dB below the 
visual carrier level. Tests are to be conducted with the receiver 
tuned to ten evenly spaced channels specified in the E1A-542 
channel plan.
1999
FCC 94-80 Federal Communications Commission Record 9 FCC Red No. 10
From 54 MHz up to and including 300 MHz -26 dBmV 
From 300 MHz up to and including 450 MHz-20 dBmV 
From 450 MHz up to and including 1.002 MH-d5 dBmV
Devices would be required to comply with these standards 
on any frequency in the applicable ranges. Further. CAG 
proposes that in the band 450 MHz to 1002 MHz. in 
addition to allowing a -15 dBmV maximum level for any 
individual frequency, we require that the average of mea 
surements made on six channels equally spaced in fre 
quency be no greater than -20 dBmV. The CAG submits 
that its proposals for less stringent standards take the above 
factors into account. In addition, it states that the progres 
sive relaxations in the standards with increasing frequency 
are based on the increased cable drop losses that occur at 
higher frequencies.
109. For conducted emissions caused by retransmission 
of external signals, the CAG recommends that we limit 
conducted signals on any frequency to less than -26 dBmV 
when the device is operated in an external ambient RF 
field whose frequency varies between 54 MHz and 1002 
MHz and whose field strength is 100 mV/m. CAG states 
that the same considerations that underlie its proposal that 
we specify -26 dBmV as the standard for conducted emis 
sions caused by internally generated signals also apply in 
the case of conducted emissions induced by external 
sources.
110. GI supports the CAG's proposal for conducted 
emissions standards. CVI agrees with the CAG that the 
proposed limit is more stringent than necessary for TV 
receivers and VCRs with double conversion tuners that 
generally have their local oscillator above the highest fre 
quency the units are capable of tuning. However, for single 
conversion tuners, which typically have their local oscilla 
tor 45.75 MHz above the tuned channel. CVI supports the 
Notice's tighter standard of -37 dBmV. Greater Media and 
CVS. with support from the Joint Commenting Parties and 
SMCTC. argue that the we should extend the frequency 
range of the conducted emissions standard down to 5 MHz. 
These parties state that cable systems are beginning to 
operate two-way transmission technologies that use fre 
quencies between 5 MHz and 30 MHz for subscriber return 
signals which need protection from conducted emissions 
produced by subscriber equipment.
111. We agree with CAG that the worst case conditions 
that underlie the proposed conducted emissions standard 
are not typical of cable system operation and that the 
proposed standard therefore would be unnecessarily protec 
tive and too burdensome for consumer equipment manu 
facturers. We also concur with the CAG that less stringent 
limits on conducted emissions in accordance with its plan 
for internally generated emissions, as indicated above, 
would be appropriate to minimize interference from con 
sumer equipment in light of the operating characteristics of 
a typical cable system and the fact that losses through cable 
drops increase with frequency, and therefore provide addi 
tional attenuation between subscribers. As losses through
drop cables will affect both internally generated and exter 
nally induced interference signals, we will apply the same 
standard for conducted emissions irrespective of whether 
the source of the conducted signal is internal or external.
112. Different test methods are needed for internal and 
external sources of conducted emissions. In this regard, we 
are specifying that measurements for conducted emissions 
caused by internal sources are to be made with the device 
operating in a shielded room. Since the RF ingress meth 
ods and sources will be the same as in the case of DPU 
interference, measurements for conducted emissions from 
external sources will be made when the device is operated 
in an external ambient RF field whose field strength is 100 
mV/m, following the same test conditions to be used in 
measuring receiver DPU.
113. We disagree with CVI that it would be appropriate 
to apply different conducted emissions standards based on 
the type of frequency conversion employed in the tuner of 
a device. We recognize that a device with a double conver 
sion tuner incorporating an IF outside the frequency range 
of cable system operation could be expected to produce 
lower levels of conducted emissions in the applicable 
ranges of the standards. However, if such a device were, in 
fact, to generate high levels of conducted emissions, what 
ever their source, those emissions would have the potential 
to cause the same harm to other subscribers of the cable 
system as emissions from a device with a standard tuner. 
We also are not persuaded that we should extend the 
applicability of the conducted emissions standard to fre 
quencies below 54 MHz, as suggested by Media General 
and CVS. These parties have not provided any information 
showing that there is a real risk of interference to cable 
system operation from conducted emissions in this fre 
quency range. It is not likely that conducted emissions 
from consumer equipment will be strong enough to inter 
fere with subscriber return signals that are intended to 
reach the cable system headend. In addition, the standards 
we are adopting address an entirely different interference 
scenario, i.e., interference from one subscriber to another, 
not interference from a subscriber to cable return transmis 
sion signals. Accordingly, we will not adopt a limit on 
conducted emissions below 54 MHz.
114. F. Radiated Emissions. In the Notice, we proposed to 
require that "cable ready" units be tested to comply with 
the existing Part 15 limits on radiated emissions from 
unintentional radiators when connected to cable service.51 
We proposed to require that compliance be demonstrated 
with input signals on six cable channels distributed evenly 
over the frequency range of 54 MHz to 1002 MHz and with 
the signal level of the input cable signal varied from 0 to 
25 dBmV. We asked for comment as to whether such tests 
should be required over the entire range from 0 to 25 
dBmV, or whether testing only at the two extremes would 
suffice. We also proposed to apply these performance and 
testing requirements to cable system terminal devices 
(CSTDs)."
51 The Part 15 emissions limits that apply to consumer TV 
equipment are set forth in Section 15.109(a) of the rules. See 47 
C.F.R. 15.109(a). The tests for radiated emissions when con 
nected to a cable signal would be in addition to the existing tests 
required for radiated emissions when connected to an antenna 
input. See 47 C.F.R.15.31(n).
52 Cable system terminal devices are TV interface devices that 
serve, as their primary function, to connect a cable system to a 
TV receiver or other subscriber premise equipment. See M 
C.F.R. !5.3. These devices are subject to the general Part 15 
emissions limits for unintentional radiators, as set forth in 
Section 15.1(W(a) of the rules. See 47 C.F.R. 15.1(W(a).
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9 FCC Red No. 10 Federal Communications Commission Record FCC 94-80
115. As an alternative to our proposed use of the Part 15 
radiated emissions limits, the CAG proposes that we em 
ploy the more stringent radiated emissions limits for cable 
systems specified in Part 76 of our rules as the standard for 
re-radiated emissions of cable signals by "cable ready" 
equipment.' ' It contends that signal leakages, whether from 
the cable plant or from receivers connected to that plant, 
are required to be within the limits set in Part 76, rather 
than Part 15. CAG also recommends a receiver input cable 
signal level of +15 dBmV for compliance testing. This 
corresponds to the maximum input level provided to sub 
scriber equipment by typical cable systems. The CAG fur 
ther suggests that, where a device is furnished with 
interconnecting cables, radiated emissions be measured 
with those cables attached in a normal configuration.
116. The Joint Cable Commenters support CAG's con 
tention that Part 76 radiated emissions limits should apply 
to consumer equipment connected to a cable system. They 
also agree that measurements of radiated emissions should 
be made with an input signal level of + 15 dBmV. SMCTC 
believes that our proposal to require testing on only six 
evenly spaced channels for radiated emissions testing is 
inadequate for determining compliance. It proposes that 
testing be conducted using a full complement of 158 poten 
tial cable channels.
117. While we agree with the CAG that application of 
the Part 76 emission limits to "cable ready" receivers may 
provide slightly greater assurance than the Part 15 limits 
that "cable ready" TV equipment does not cause harmful 
interference, we are not convinced that such a standard is 
necessary. As we observed in our previous decision to 
apply the Part 15 radiated emissions standards to CSTDs. 
the emissions characteristics of consumer TV receiving de 
vices differ distinctly from those of a cable system distribu 
tion plant. 54 The Part 76 emission limits were designed to 
apply to open air cable installations where radiated emis 
sions would not be attenuated significantly by surrounding 
structures. On the other hand, radiation from television 
receiving equipment, which are point sources, is subject to 
propagation losses that are greater than the cable system as 
a whole. Emissions by TV receiving equipment are also 
attenuated by the structure within which it is located. We 
note that CSTDs. which connect to cable systems and are 
currently allowed the higher emission levels of Part 15. 
have not been a threat to the operation of cable systems. 
We therefore find that it would be unnecessarily burden 
some and costly to require manufacturers of "cable ready" 
TV receiving equipment to comply with tighter emission 
standards when their devices pose no greater threat than 
cable set-top boxes and other CSTDs. Accordingly, we are 
adopting our proposal to apply the radiated emission limits 
of Section 15.109(a) to "cable ready" consumer TV equip 
ment.
118. We also find that a single input cable signal level of 
+ 15 dBmV. as suggested by the CAG. is appropriate for 
testing "cable ready" equipment for compliance with the 
radiated emissions standard, rather than a range of 0 dBmV
to +25 dBmV. We therefore will require that a +15 
dBmV NTSC signal be used as the input cable signal in 
testing for compliance with this standard. We are not 
adopting SMCTC's suggestion that we require radiated 
emissions tests to be performed with the device tuned to 
each of the cable channels the device is capable of tuning. 
Such testing would be burdensome for manufacturers and 
SMCTC has not provided any technical information or 
other grounds that would indicate the need for performing 
the test with a full complement of 158 potential cable 
channels. We therefore will require that compliance be 
demonstrated with input signals on six EIA IS-132 cable 
channels distributed evenly over the frequency range of 54 
MHz to 1002 MHz.
119. G. Input Selector Switch Isolation. RF emissions can 
also leak from and/or enter into cable systems through 
input selector switches (also called A/B switches) used to 
alternate between service from a cable system, an antenna 
for reception of broadcast signals, or other equipment such 
as a VCR or videodisc player, if the switches do not 
provide adequate isolation between their various ports. Un 
der the existing Part 15 rules, input selector switches used 
to alternate between cable and antenna service that are 
included in TV receivers and TV interface devices, such as 
VCRs and CSTDs. are required to comply with isolation 
standards.55 In the Notice, we proposed to clarify that the 
input selector switch isolation standards would apply to all 
transfer switches used to alternate between a cable service 
and other inputs, including stand-alone units that are not 
part of a "cable ready" TV receiver or a TV interface 
device. We also noted that the input selector switch isola 
tion rules currently are specified only for frequencies up to 
550 MHz. In considering this issue, we recognized that it 
becomes more difficult to achieve high levels of isolation at 
higher frequencies and that the amount of isolation needed 
also decreases with increasing frequency. We therefore re 
quested comment on the appropriate standard or standards 
to specify for the frequency range from 550 MHz to 1002 
MHz to conform with cable service that might use chan 
nels up to this frequency range.
120. The CAG recommends that we only extend the 
isolation requirements for input selector switches used with 
cable service up to 800 MHz. It submits that switch isola 
tion can be expected to deteriorate gradually above 800 
MHz. The CAG further observes that TV antennas con 
nected to an input selector switch are inefficient radiators 
above 800 MHz. It therefore suggests that we require input 
selector switches used with cable service to provide 55 dB 
isolation between ports in the frequency range 550-800 
MHz. CVS supports extending the Part 15 isolation require 
ments to frequencies up to 1 GHz. NYC also supports 
extending the Part 15 isolation standards for input selector 
switches up to 1 GHz and applying these requirements to 
all selector switches, including stand-alone units. SMCTC 
believes that the current requirement for 60 dB should be 
extended from 550 MHZ up to 1002 MHz.
SJ The radiated emissions standards for cable systems are set 
forth in Section 76.605(a)( 12). These standards provide that 
radiated emissions on frequencies less than 54 MHz and over 
316 MHz must not exceed 15 mV/m at 30 meters and that 
radiated emissions on frequencies over 54 MHz up to and in 
cluding 216 MHz must not exceed 20 mV/m at 3 meters. See 47 
C.F.R. 76.605(a)(12).
54 < See Report and Order. GEN Docket No. 85-301, 2 FCC Red 
3304 (1987).
55 See 47 C.F.R. 15.115(c) and 15.117(h). These sections 
currently provide that transfer switches must provide 80 dB of 
isolation for signals in the frequency range 54 to 216 MHz and 
60 dB for signals at frequencies from 216 to 550 MHz.
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FCC 94-80 Federal Communications Commission Record 9 FCC Red No. 10
121. We continue to believe that it is necessary to extend 
the isolation requirements for input selector switches used 
with cable service to higher frequencies and to apply these 
requirements to all such switches, including stand-alone 
units. We also concur with the CAG that 55 dB isolation 
will provide adequate protection against leakage of higher 
frequency cable signals. We further recognize the 
difficulties inherent in designing economical switches that 
can provide a high degree of isolation at frequencies above 
800 MHz and agree with the CAG that the broadcast 
receiving antennas connected to these switches can be ex 
pected to be less effective radiators above 800 MHz. In view 
of the expectation that cable systems generally will not use 
higher frequencies, there also does not appear to be a need 
to ensure that these switches provide significant isolation 
above the 800 MHz range. Accordingly, we are adopting a 
requirement that input selector switches used to alternate 
between cable service and an antenna provide 55 dB isola 
tion between input ports over the frequency range 550 
MHz up to and including 806 MHz.56 We are also clarify 
ing that isolation requirements for input selector switches 
used with cable service apply to all such switches, includ 
ing stand-alone units.
122. H. Attenuation of By-pass Switches and Other De 
vices. In the Notice, we proposed to require that switches 
and other devices, such as filters that are intended to be 
used to bypass cable set-top devices or other equipment, 
not attenuate the input cable signals more than 6 dB at any 
output port. This proposal was intended to ensure that 
acceptable service is obtained when using supplemental 
equipment to improve compatibility between cable service 
and consumer equipment. The requirement would apply 
both to devices that are built into TV receivers and VCRs 
and to stand-alone bypass switches and filters.
123. The CAG and NYC support our proposal to estab 
lish a standard for attenuation at the output ports of by 
pass switches. CAG also suggests that we allow a slightly 
higher limit for attenuation of signals on frequencies above 
550 MHz. It recommends that attenuation be limited to 6 
dB in the frequency range 54-550 MHz. and 8 dB in the 
range 550-1002 MHz. The CAG states that higher losses 
should be permitted at higher frequencies because compo 
nent losses, plus cabling and possibly switching losses, gen 
erally increase at the higher frequencies. SMCTC. however, 
believes that the amount of attenuation through input se 
lector switches should be no greater than 1 dB.
124. We find our proposed 6 dB attenuation limit is 
appropriate and adequate to ensure acceptable service 
through bypass switches and filters from signals on fre 
quencies at and below 550 MHz. We also believe a slightly 
higher limit is appropriate for signals on frequencies above 
550 MHz for the reasons indicated by the CAG. The 1 dB 
standard suggested by SMCTC is unnecessarily stringent for 
switches and inappropriate for splitters. While 1 dB attenu 
ation may be an achievable performance level for some 
switches, a less stringent 6 dB standard will provide a 
margin for variations in design and production and still 
ensure that satisfactory signal levels pass through switches. 
We observe that non-amplified signal splitters, by their 
design, divide the input signal strength among two or more 
output ports, so that the signal levels at individual output
ports generally will be substantially lower than the input 
signal. Accordingly, we will require that switches and other 
devices intended to be used to by-pass cable set-top devices 
(or the internal circuitry in such devices) and other equip 
ment not attenuate input cable signals at any output port 
more than 6 dB for signals on frequencies at or below 550 
MHz, or more than 8 dB for signals on frequencies above 
550 MHz. These requirements will apply both to devices 
that are built into TV receivers and VCRs and to stand 
alone units. We also wish to clarify that the limits that we 
adopt here do not apply to our procedure for the measure 
ment of receiver noise figures, which allows 4 dB to be 
subtracted to allow for a signal splitter between the RF 
input connector of the receiver and the UHF tuner under 
test.
125. Equipment Authorization. In the Notice, we request 
ed comment on whether we should subject "cable ready" 
television receivers and component descrambler/decoders 
to authorization under the notification or certification pro 
cedures, rather than the verification procedure to which 
these devices are currently subject.57
126. In its comments, the CAG states that television 
receivers have very good levels of compliance under the 
Commission's verification procedure. It therefore believes 
there is no need for the Commission to impose new bur 
dens on manufacturers or itself by applying either of the 
more rigorous notification or certification procedures to 
"cable ready" consumer TV equipment. The CAG argues 
that as the new rules become effective, any non-compliance 
is likely to be detected by rival consumer electronics man 
ufacturers or by cable operators and brought to the atten 
tion of the Commission, which could then correct the 
violations. SMCTC and NYC urge the Commission to sub 
ject these devices to the certification process, where com 
pliance is determined by the Commission before a grant of 
equipment authorization is made. SMCTC believes that a 
lesser procedure such as verification is too tempting for 
some manufacturers to resist taking short-cuts to obtain 
unfair competitive advantage over complying manufactur 
ers. NYC believes that the verification procedure may be 
insufficient because the new standards for "cable ready" 
equipment will entail substantial improvements in the 
technical performance of TV equipment. NYC believes the 
close scrutiny of the certification procedure is needed to 
permit the Commission to monitor compliance.
127. We find that our verification procedure is sufficient 
to ensure that TV receivers. VCRs and similar consumer 
electronics equipment comply with our technical require 
ments, including the new "cable ready" standards. Our 
decision to subject this equipment to verification is influ 
enced by the long standing record of compliance of televi 
sion receivers under verification in the Commission's 
equipment authorization program. Moreover, we believe 
the requirements adopted herein do not involve any new 
or advanced technology which would challenge the current 
capability of the television receiver industry. In response to 
NYC's concern regarding the lack of compliance monitor 
ing by the Commission under the verification procedure, 
we intend to closely monitor "cable ready" equipment for
5(1 We are specifying the slightly higher 806 MHz upper limit 
to be consistent with the upper minimum tuning requirement 
for "cable ready" equipment decided above.
57 The verification, notification and certification procedures 
are set forth in Section 2, Subpart J of the rules. See 47 C.F.R. 
2. Subpart J.
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9 FCC Red No. 10 Federal Communications Commission Record FCC 94-80
compliance with the standards adopted herein through our 
sampling program provided for in Section 15.29(d) of the 
Rules.
128. Implementation of Rules for New Consumer Equip 
ment. In the Notice, we proposed to require that all con 
sumer electronics equipment manufactured or imported 
after December 31, 1996, that is marketed as "cable ready" 
or otherwise marketed as intended for connection directly 
to cable service comply with the new "cable ready" tech 
nical standards. This proposal was based on indications by 
the CAG and the JEC that they would complete their work 
on the new channel plan and the updated Decoder Inter 
face standard by the end of 1993.
129. The CAG believes a slightly longer period is needed 
for implementation of the new equipment rules to ensure a 
smooth transition. First, it states that the "cable ready" 
equipment rules should be made effective in the spring 
season, when new products are generally introduced, rather 
than in the middle of the busy holiday season. Second, it 
submits that cable systems should be required to be in a 
position to provide component descrambler/decoders when 
Decoder Interface equipped receivers first become avail 
able, rather than after the deadline for all "cable ready" 
sets to incorporate Decoder Interface connectors. The CAG 
states that current information suggests that cable hardware 
suppliers may not be in a position to supply decoders in 
volume before the end of 1996. Based on these consider 
ations, it suggests that the date for compliance with the 
"cable ready" standards be changed to June 30. 1997. It 
further recommends that cable operators be required to 
make decoders available to subscribers no later than De 
cember 31. 1996. six months before the deadline for inclu 
sion of Decoder Interface connectors in "cable ready" 
consumer equipment.58 The CAG also submits that al 
though products that meet the "cable ready" requirements 
will not be immediately available, it recommends that the 
rule prohibit use of the term "cable ready" to describe 
equipment that does not meet these new standards become 
effective promptly. NYC similarly submits that until these 
standards become effective, we should prohibit manufactur 
ers from using the term "cable ready" in connection with 
their products unless they disclose to consumers that some 
features of the equipment may not be operable when it is 
connected to a cable service. Most of the other comment 
ing parties either did not address the implementation date 
for the new equipment or agreed with our proposed im 
plementation schedule for new equipment.
130. We find that the schedule suggested by the CAG 
provides an acceptable plan for implementation of the new 
equipment rules. The relatively short additional time re 
quested by the CAG will accommodate the normal in 
troduction cycle of new consumer TV products and the 
production of component descrambler/decoders for distri 
bution by cable operators with only a modest delay from 
our proposed schedule. This schedule will also allow addi 
tional time for completion of the Decoder Interface stan 
dard so that this feature can be incorporated into all new 
"cable ready" equipment. Accordingly, we will require that 
new TV receivers and VCRs marketed using the terms 
"cable ready" or "cable compatible" after June 30, 1997. 
comply with the "cable ready" equipment standards. We 
will consider the CAG's suggestion to require that cable
operators provide component descrambler/decoders to sub 
scribers with "cable ready" equipment when we finalize the 
Decoder Interface standard.
131. We also agree with the CAG and NYC that the rule 
restricting use of the term "cable ready" to describe new 
consumer electronics equipment should be implemented 
promptly in order to minimize confusion for consumers. 
Accordingly, we are prohibiting use of "cable ready," "ca 
ble compatible," and other terms and descriptors that con 
vey the impression a device is fully compatible with cable 
service, in the labeling and packaging of consumer TV 
receivers and VCRs manufactured or imported for sale to 
consumers in this country after October 31, 1994. unless 
that equipment complies with the "cable ready" technical 
standards.
Standards for Cable Systems
132. Channelization. We proposed to require that cable 
systems built or re-built after one year from the effective 
date of the new rules use the new EIA IS-132 cable chan 
nel plan for channels up to 1 GHz, consistent with our 
proposals for "cable ready" consumer equipment standards, 
and to require all cable systems to use this channel plan 
after 10 years. We also requested comment on how our 
adoption of the EIA IS-132 channel plan would affect the 
use of compression methods or multiplexing of cable chan 
nels.
133. The commenting parties generally support our pro 
posal to require cable systems to use the EIA IS-132 
channel plan. For example, the CAG agrees that this re 
quirement is needed to ensure compatibility with the tun 
ers of consumer electronics equipment. Greater Media and 
the Joint Cable Commenters submit that cable systems 
should be allowed to use other channel schemes for trans 
mitting digital and other non-standard signals. The CAG 
submits that compliance with the EIA IS-132 channel plan 
is likely to present minimal difficulties for most cable 
systems and therefore believes that it would be reasonable 
to implement this standard on a more expedited timetable 
than that proposed. It recommends that the compliance 
date for all cable systems be established as June 30. 1997. 
the same date it proposes for making effective the technical 
standards for "cable ready" consumer equipment. The 
CAG further believes that we should provide for accom 
modating cable operators that are not able to meet this 
deadline.
134. To complete our adoption of the EIA IS-132 cable 
channel plan, we are requiring all cable systems to use this 
plan for transmitting analog television service. We wish to 
clarify that cable systems will not have to activate channels 
for all of the channels specified in EIA IS-132. but rather 
will be required to adhere to the frequency plan in this 
standard for the analog channels that they provide to their 
subscribers. While cable systems may use other channel 
plans for providing digital service, we advise cable oper 
ators that, consistent with our plan to adopt cable digital 
transmission standards as indicated below, we intend to 
adopt a channel plan for digital cable service at an appro 
priate time in the future.
135. We are also adopting the proposed transition plan 
recommended by the CAG for requiring cable systems to 
implement this new standard. As the portion of EIA IS-132
58 We are deferring this issue to our subsequent action on the Decoder Interface standard.
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FCC 94-80 Federal Communications Commission Record 9 FCC Red No. 10
that addresses frequencies under 1 GHz has been substan 
tially defined for some time and is already used by most 
cable systems so that hardware is available, we believe one 
year is an adequate amount of time for new and re-built 
cable systems to comply with that standard. We similarly 
find that it would not be unduly burdensome to require 
that all cable systems comply with the EIA IS-132 channel 
plan by June 30, 1997. As the CAG notes, this would 
ensure that all cable systems are using the channel plan 
standard when the "cable ready" equipment standards be 
come effective. Accordingly, cable systems built or re-built 
after May 31. 1995 will be required to comply with the 
new cable channel standard, and all cable systems must 
comply with this standard by June 30, 1997.
Future Technologies
136. In the Notice, we indicated that in order to avoid 
future compatibility problems that could arise with the 
introduction of digital transmission methods by the cable 
industry, it will be necessary to standardize the system used 
for digital transmissions. We noted that the CAG has stated 
that it would be feasible to establish standards for digital 
compression/decompression and a standard security inter 
face system on a schedule that takes place over the next 
several years.5" We recognized that developmental work in 
this area is still in progress, and therefore requested sugges 
tions for a regulatory plan that would require completion 
of a digital cable transmission standard in a manner that 
would allow for timely and efficient introduction of con 
sumer products that could receive service under the new 
standard.
137. A number of parties agree that we should establish 
standards for transmission of digital signals on cable sys 
tems. The CAG states that a firm understanding that digital 
standards will be prescribed is important to the current 
cooperative efforts of the cable and consumer electronics 
industries and to assure consumers and legislators that the 
kinds of problems that led to enactment of Section 17 do 
not occur. The CAG further states that it plans to finish its 
work on defining digital transmission and tuner specifica 
tions by the end of 1994. It indicates that the JEC is 
investigating on-going digital standards activities both do 
mestically and internationally and will provide a report on 
this work in mid-1994 that could serve as the basis for a 
further rule making action by the Commission.60 Pacific 
Bell believes the CAG's schedule for developing a cable 
digital standard is overly ambitious and does not allow time 
for proper completion of work in a number of complex 
areas, including technical and market testing. It expresses
concern that any standards developed prematurely could 
face consumer rejection or technical obsolescence. Pacific 
Bell believes that a more reasonable estimate for complet 
ing a digital cable standard is late 1995.
138. Consistent with their position on standards for the 
Decoder Interface connector and associated component 
descrambler/decoders, Circuit City, Mitsubishi and News 
Datacom submit that to provide for a competitive market 
in hardware and software functions, we should: 1) establish 
a standard for digital cable transmissions, including secu 
rity: 2) only allow functions directly related to security to 
be reserved to hardware/software provided by cable oper 
ators; and, 3) require that other functions be accommo 
dated in a manner that would allow them to be provided 
on a competitive basis. News Datacom. Pacific Bell and 
SMCTC submit that we should begin to develop standards 
for cable digital transmission now, to avoid new compati 
bility problems in the future. Titan similarly requests that 
we initiate an inquiry into the standardization of digital 
525-line television service. News Datacom further recom 
mends that the cable digital standard be compatible with 
MPEG-2. The Joint Cable Commenters note that the EIA 
IS-132 channel plan does not define the multiplexing of 
digitally compressed channels within a 6 MHz channel and 
submit that the appropriate time to further define the 
channel plan in this regard would be at the time digital 
transmission standards are set.
139. GI and the Joint Cable Commenters oppose stan 
dardization of cable system security technology or rules 
that would allow the incorporation of security circuitry 
into consumer equipment. GI argues that such an ap 
proach would give "pirates" a single technical design to 
attack and thereby undermine the ability of cable operators 
to protect their signals. Hewlett-Packard and Titan, how 
ever, recommend that we also establish a standard security 
system for cable digital service. They indicate that modern 
encryption/security methods make it feasible to achieve 
adequate security in a digital system that separates the 
signal coding (program information) and access control 
(security) functions by using standard interfaces and that 
such an approach would not be less secure than current 
approaches. Titan states that this approach would allow 
both the decoder and access control functions to be incor 
porated into consumer equipment and that access control 
could be provided through a secure chip within a "smart 
card." They urge that we proceed expeditiously toward 
adoption of a standard security system for component 
descrambler/decoders.
5U The CAG indicates that standards for the digital cable 
environment could be established in accordance with the fol 
lowing timetable:
1W3: Define "cable ready"
19 4: Define transmission and tuner specifications
No later than 1W5: Set target dates for standards for 
decompression and a standard security interface system. 
See "Supplemental Comments of the Cable-Consumer Electron 
ics Compatibility Advisory Group," ET Docket No. 43-7, filed 
with the Commission July 21. 1993.
nn The CAG indicates that its work will attempt to balance the 
need for early identification of proposed standards with the 
importance of preserving necessary flexibility to permit tech 
nological innovation and the development of new services and
consumer electronics features. The CAG submits that its work 
does not intend to foreclose the development of new technology, 
including new scrambling systems, or the development and 
delivery of new services such as on-line data services, video 
games, video telephony, digital music and others. The CAG also 
states that such services should not be precluded by strict 
enforcement of the new channelization plan. It indicates that 
the new Decoder Interface connector is being designed in a 
fashion which should be able to accommodate new scrambling 
methodologies and other new services. It further submits that 
the cable and consumer electronics industries envision estab 
lishing procedures whereby new services and scrambling meth 
odologies can be tested for compatibility with the Decoder 
Interface.
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9 FCC Red No. 10 Federal Communications Commission Record FCC 94-80
140. Mitsubishi and Titan believe that we should link a 
standard for cable digital transmissions to the standard for 
broadcast advanced television (ATV) service. They state 
that conforming digital standards for broadcast and cable 
television will avoid the investment of billions of dollars in 
incompatible systems and provide clear guidance for in 
dustry. The Interactive Multimedia Association (IMA) be 
lieves that we should also, in the near term and 
synchronous with the development of digital cable stan 
dards, define a return data path from consumer electronics 
devices to cable service. It states that such a return path is 
needed to allow the implementation of new interactive 
multimedia services. The IMA submits that the return path 
should be compatible with the new Decoder Interface stan 
dard and should include a definition of a standard bi 
directional protocol for connecting interactive services to 
consumer equipment.
141. GI. TCI and Home Box Office (HBO) urge that we 
refrain from proceeding to adopt a digital transmission 
standard for cable systems now. They state that while digi 
tal transmission standards may be useful eventually, the 
dynamic nature of these emerging technologies could lead 
to inefficient outcomes if we were to adopt such standards 
too soon. HBO believes that whatever standard may prove 
necessary for digital cable transmission will be developed 
most efficiently through market evolution. TCI states that 
we should rely on industry groups to develop and recom 
mend cable digital standards. HBO also states that any 
standards setting action by the Commission now would 
lead to a halt in the existing transition to digital systems by 
satellite cable services.
142. AT&T, Bell Atlantic and USTA also argue that we 
should provide for consideration of all types of video trans 
port services in setting digital transmission, compression 
and interface standards. AT&T recommends that we initiate 
a broad ranging inquiry to address interfaces among equip 
ment in the home and to transmission and information 
processing standards for future digital multimedia products 
and standards.
143. We recognize the need to proceed with caution in 
this area and to ensure that our processes and regulations 
do not unnecessarily impair the development of new cable 
technologies and services and of appropriate interfaces be 
tween such technologies and services with other media. 
Notwithstanding these considerations, we find that stan 
dards for cable digital transmissions are necessary to avoid 
future compatibility problems when cable systems use digi 
tal transmission methods, and to allow the mass production 
of economical consumer equipment that is compatible with 
cable digital services. In the latter regard, we believe that 
standardization is needed to ensure the establishment and 
effective operation of a competitive market in consumer 
hardware and software products for connection to digital 
cable service.
144. As observed by a number of the commenting par 
ties, the development of cable digital standards will have to 
address a number of important and complex technical and 
policy issues in addition to the question of compatibility 
between cable systems and consumer electronics equip 
ment. Some of these include the appropriate compression 
and signalling technologies, our policy towards encryption 
methods, the relationship of the cable digital system to the 
terrestrial broadcast ATV standard and multimedia, wheth 
er to require all new and innovative services to adhere to 
the standards, and the interfaces between cable digital tech 
nology and the technologies used to deliver service by
alternative media such as video dialtone and direct satellite 
broadcasting. In view of the broad scope of the issues 
involved in defining cable digital transmission standards 
and related policies, we believe it is more appropriate to 
defer these matters to a separate proceeding. Accordingly, 
we will not take any further steps toward adoption of cable 
digital standards in this proceeding. We will address these 
and other issues relating to digital video technologies and 
services in a future Notice of Inquiry that will initiate an 
omnibus proceeding on digital video services.
PROCEDURAL MATTERS
145. Pursuant to Section 603 of the Regulatory Flexibil 
ity Act, 5 U.S.C. Section 601. et seq., the Commission 
incorporated an initial regulatory flexibility analysis 
(IRFA) in the Notice of Proposed Rule Making in this 
proceeding. Written comments were requested on the 
IFRA. Our final regulatory analysis is as follows:
I. Need for and Objective of the Rules: Section 17 of the 
Cable Television Consumer Protection and Competition 
Act of 1992 requires the Commission to prescribe regula 
tions for assuring compatibility between TV receivers and 
VCRs and cable systems, consistent with the need to pre 
vent theft of cable service. We believe that the rules we are 
adopting will ensure compatibility between cable systems 
and consumer equipment while imposing the least burden 
on equipment manufacturers, cable systems and consum 
ers.
III. Any Significant Alternatives Minimizing the Impact on 
Small Entities and Consistent with Stated Objectives. Wher 
ever possible, we have attempted to minimize costs for both 
cable operators and consumer electronics manufacturers. 
The regulatory burdens we are adopting are necessary to 
ensure that the public receives the benefits of compatibility 
between cable systems and their TV receivers and VCRs. 
The major area where alternatives are possible is in the 
choice of the Decoder Interface connector as a means for 
avoiding the need to use set-top devices. Use of a Decoder 
Interface will resolve the need for set-top devices and also 
provide a path to compatibility with future services that 
use digital compression. While the Decoder Interface con 
nector will be a new requirement for manufacturers, the 
cost of this feature is expected to be recoverable through a 
modest premium in the prices of "cable ready" TV receiv 
ers and VCRs. The amount of this increase is likely to be 
less for cable subscribers than the cost of technologies that 
would provide subscribers all authorized signals "in the 
clear." We will continue to examine alternatives in the 
future, particularly with regard to the technical standard 
for the Decoder Interface standard, with the objective of 
minimizing any significant impact of our regulations on 
small entities.
146. The Commission's Secretary will send a copy of this 
First Report and Order to the Chief Counsel for Advocacy 
of the Small Business Administration.
147. Accordingly. IT IS ORDERED that Parts 15 and 76 
of the Commission's rules ARE AMENDED as set forth in 
Appendix A. effective 30 days after the publication of a 
summary of this First Report and Order in the Federal 
Register. This action is taken pursuant to authority pro 
vided in Sections 4(i). 7(a). 302. 303(c). 303(f), 303(g). 
303(r) and 324A of the Communications Act of 1934. as 
amended 47 U.S.C. Sections 154(i). 157(a). 302. 303(c). 
303(0. 303(g), 303(r) and 324A.
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FCC 94-80 Federal Communications Commission Record 9 FCC Red No. 10
FEDERAL COMMUNICATIONS COMMISSION
William F. Caton 
Acting Secretary
APPENDIX A
Amendments to the Rules
Parts 15 and 76 of Chapter I of Title 47 of the Code of 
Federal Regulations are amended as follows:
Part 15 RADIO FREQUENCY DEVICES
1. The authority citation for Part 15 is revised to read as 
follows:
AUTHORITY: Sees. 4, 302, 303, 304, 307 and 624A of the 
Communications Act of 1934, as amended, 47 U.S.C. Sec 
tions 154, 302, 303, 304, 307 and 544A.
2. Section 15.3 is amended by adding a new paragraph 
(aa) to read as follows:
15.3 Definitions.
(A) * * *
(aa) Cable ready consumer electronics equipment. Con 
sumer electronics TV receiving devices, including TV re 
ceivers, videocassette recorders and similar devices, that 
incorporate a tuner capable of receiving television signals 
and an input terminal intended for receiving cable televi 
sion service, and are marketed as "cable ready" or "cable 
compatible." Such equipment shall comply with the tech 
nical standards specified in Section 15.118 of this chapter.
3. Section 15.19 is amended by adding a new paragraph 
(d) to read as follows:
15.19 Labeling requirements.
(A) * * *
(d) Consumer electronics TV receiving devices, including 
TV receivers, videocassette recorders and similar devices, 
that incorporate features intended to be used with cable 
television service, but do not fully comply with the tech 
nical standards for cable ready equipment set forth in 
Section 15.118 of this chapter, are subject to the following 
labeling requirements:
(1) Such equipment shall be labeled with an advisory 
indicating that the device does not fully comply with the 
Federal Communications Commissions standards for cable 
ready consumer electronics equipment. The advisory must
appear on the device and on its packaging. This require 
ment applies to consumer TV receivers, videocassette re 
corders and similar devices manufactured or imported for 
sale in this country on or after June 30, 1997.
(2) Such equipment shall not be marketed with ter 
minology that describes the device as "cable ready" or 
"cable compatible." or that otherwise conveys the impres 
sion that the device is fully compatible with cable service. 
This requirement applies to consumer TV receivers. 
videocassette recorders and similar devices manufactured or 
imported for sale in this country on or after October 31, 
1994.
4. Section 15.115 is amended by revising paragraph 
(c)(l)(i) and adding new paragraphs (h) and (i) to read as 
follows:
15.115 TV interface devices, including cable system ter 
minal devices.
(A)
(c)
(1)
(i) For a cable system terminal device or a TV interface 
device equipped for use with a cable system or a master 
antenna, as defined in paragraph (b)(3) of this section, the 
isolation between the antenna and cable input terminals 
shall be at least 80 dB from 54 MHz to 216 MHz. at least 
60 dB from 216 MHz to 550 MHz and at least 55 dB from 
550 MHz to 806 MHz. The 80 dB standard applies at 216 
MHz and the 60 dB standard applies at 550 MHz. In the 
case of a transfer switch requiring a power source, the 
required isolation shall be maintained in the event the 
device is not connected to a power source or power is 
interrupted. The provisions of this sub-paragraph regarding 
frequencies in the range 550 MHz to 806 MHz are effective 
June 30. 1997.
(h) Stand-alone switches used to alternate between cable 
service and an antenna shall provide isolation between the 
antenna and cable input terminals that is at least 80 dB 
from 54 MHz to 216 MHz. at least 60 dB from 216 MHz to 
550 MHz and at least 55 dB from 550 MHz to 806 MHz. 
The 80 dB standard applies at 216 MHz and the 60 dB 
standard applies at 550 MHz. In the case of stand-alone 
switches requiring a power source, the required isolation 
shall be maintained in the event the device is not con 
nected to a power source or power is interrupted. The 
provisions of this paragraph are effective June 30, 1997.
(i) Switches and other devices intended to be used to 
by-pass the processing circuitry of a cable system terminal 
device, whether internal to such a terminal device or a 
stand-alone unit, shall not attenuate the input signal more 
than 6 dB from 54 MHz to 550 MHz. or more than 8 dB 
from 550 MHz to 806 MHz. The provisions of this para 
graph are effective June 30, 1997,'ASection 15.117 is 
amended by revising paragraph (h) to read as follows:
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9 FCC Red No. 10 Federal Communications Commission Record FCC 94-80
15.117 TV broadcast receivers.
(A) * * *
* * # * *
(h) For a TV broadcast receiver equipped with a cable 
input selector switch, the selector switch shall provide, in 
any of its set positions, isolation between the antenna and 
cable input terminals of at least 80 dB from 54 MHz to 216 
MHz, at least 60 dB from 216 MHz to 550 MHz and at 
least 55 dB from 550 MHz to 806 MHz. The 80 dB 
standard applies at 216 MHz and the 60 dB standard ap 
plies at 550 MHz. In the case of a selector switch requiring 
a power source, the required isolation shall be maintained 
in the event the device is not connected to a power source 
or power is interrupted. An actual switch that can alternate 
between reception of cable television service and an an 
tenna is not required for a TV broadcast receiver, provided 
compliance with the isolation requirement specified in this 
paragraph can be demonstrated and the circuitry following 
the antenna input terminal(s) has sufficient bandwidth to 
allow the reception of all TV broadcast channels authorized 
under this chapter. The provisions of this paragraph re 
garding frequencies in the range 550 MHz to 806 MHz are 
effective June 30, 1997.
6. New Section 15.118 is added to read as follows:
15.118 Cable ready consumer electronics equipment.
(a) All consumer electronics TV receiving equipment 
marketed in the United States as cable ready or cable 
compatible shall comply with the provisions of this section. 
Consumer electronics TV receiving equipment that in 
cludes features intended for use with cable service but does 
not fully comply with the provisions of this section are 
subject to the labelling requirements of Section 15.19(d).
(b) Cable ready consumer electronics equipment shall be 
capable of receiving all NTSC or similar video channels in 
the frequency range 54 MHz to 804 MHz in accordance 
with the channel allocation plan set forth in the Electron 
ics Industries Association's "Cable Television Channel 
Identification Plan, EIA IS-132. May 1994" (EIA IS-132). 
This incorporation by reference was approved by the Di 
rector of the Federal Register in accordance with 5 U.S.C. 
522(a) and 1 CFR Part 51. Copies of EIA IS-132 may be 
obtained from: Global Engineering Documents. 2805 
McGraw Ave., Irvine CA 92714. Copies of EIA IS-132 may 
be inspected during normal business hours at the following 
locations: Federal Communications Commission, 1919 M 
Street, NW, Dockets Branch (Room 239). Washington. DC. 
or the Office of the Federal Register. 800 North Capitol 
Street, NW. Suite 700. Washington. DC.
(c) Cable ready consumer electronics equipment must 
meet the following technical performance requirements. 
Compliance with these requirements shall be determined 
by performing measurements at the unfiltered IF output 
port. Where appropriate, the Commission will consider 
allowing alternative measurement methods.
(1) Adjacent channel interference. In the presence of a 
lower adjacent channel CW signal that is 1.5 MHz below 
the desired visual carrier in frequency and 10 dB below the 
desired visual carrier in amplitude, spurious signals within 
the IF passband shall be attenuated at least 55 dB below 
the visual carrier of the desired signal. The desired input
signal shall be an NTSC visual carrier modulated with a 10 
IRE flat field and the aural carrier should be unmodulated. 
Measurements are to be performed for input signal levels 
of 0 dBmV and + 15 dBmV, with the receiver tuned to ten 
evenly spaced channels specified in the EIA IS-132 channel 
plan.
(2) Image channel interference. Image channel interfer 
ence within the IF passband shall be attenuated below the 
visual carrier of the desired channel by at least 60 dB from 
54 MHz to 806 MHz. In testing for compliance with this 
standard, the desired input signal is to be an NTSC visual 
carrier modulated with a 10 IRE flat field and the aural 
carrier should be unmodulated. The undesired test signal 
shall be a CW signal equal in amplitude to the desired 
visual carrier and located 90 MHz above the visual carrier 
frequency of the desired channel. Measurements shall be 
performed for input signals of 0 dBmV and +15 dBmV. 
with the receiver tuned to ten evenly spaced channels 
specified in the EIA IS-132 channel plan.
(3) Direct pickup interference. The direct pickup (DPU) 
of a co-channel interfering ambient field by a cable ready 
device shall not exceed the following criteria. The ratio of 
the desired to undesired signal levels at the IF passband on 
each channel shall be at least 45 dB. The average ratio over 
the six channels shall be at least 50 dB. The desired input 
signal shall be an NTSC signal having a visual carrier level 
of 0 dBmV. The equipment under test (EUT) shall be 
placed on a rotatable table that is one meter in height. Any 
excess length of the power cord and other connecting leads 
shall be coiled on the floor under the table. The EUT shall 
be immersed in a horizontally polarized uniform CW field 
of 100 mV/m at a frequency 2.55 MHz above the visual 
carrier of the EUT tuned channel. Measurements shall be 
made with the EUT tuned to six EIA IS-132 channels, two 
each in the low VHF. high VHP and UHF broadcast bands. 
On each channel, the levels at the IF passband due to the 
desired and interfering signals are to be measured.
(4) Tuner overload. Spurious signals within the IF 
passband shall be attenuated at least 55 dB from 54 to 806 
MHz below the visual carrier of the desired channel using 
a comb spectrum input with each signal individually set at 
+ 15 dBmV. Measurements shall be made with the receiver 
tuned to ten evenly spaced EIA IS-132 channels.
(5) Cable input conducted emissions. Conducted 
spurious emissions that appear at the cable input to the 
device must meet the following criteria. The input shall be 
an NTSC video carrier modulated with a 10 IRE flat field 
at a level of 0 dBmV and with a visual to aural ratio of 10 
dB. The aural carrier shall be unmodulated. The peak level 
of the spurious signals will be measured using a spectrum 
analyzer connected by a directional coupler to the cable 
input of the equipment under test. Spurious signal levels 
must not exceed the limits in the following table:
From 54 MHz up to and including 300 MHz-26 
dBmV
From 300 MHz up to and including 450 MHz-20 
dBmV
From 450 MHz up to and including 806 MHz-15 
dBmV
The average of the measurements on multiple channels 
from 450 MHz up to and including 806 MHz shall be no 
greater than -20 dBmV. Measurements shall be made with 
the receiver tuned to at least four EIA IS-132 channels in
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FCC 94-80 Federal Communications Commission Record 9 FCC Red No. 10
each of the above bands. The test channels are to be evenly 
distributed across each of the bands. Measurements for 
conducted emissions caused by sources internal to the de 
vice are to be made in a shielded room. Measurements for 
conducted emissions caused by external signal sources shall 
be made in an ambient RF field whose field strength is 100 
mV/m. following the same test conditions as described in 
paragraph (c)(3) of this section.
(d) The field strength of radiated emissions from cable 
ready consumer electronics equipment shall not exceed the 
limits in Section 15.109(a) when measured in accordance 
with the applicable procedures specified in Section 15.31 
and Section 15.35 for unintentional radiators, with the 
following modifications. During testing the NTSC input 
signal level is to be +15 dBmV, with a visual to aural ratio 
of 10 dB. The visual carrier is to be modulated by a 10 
IRE flat field: the aural carrier is to be unmodulated. 
Measurements are to be taken on six EIA IS-132 channels 
evenly spaced across the required RF input range of the 
equipment under test.
Note: The provisions of paragraphs (a) through (d) of 
this section are effective June 30, 1997.
Part 76 CABLE TELEVISION SERVICE
7. The authority citation for Part 76 is revised to read as 
follows:
AUTHORITY: Sees. 2, 3, 4, 301, 303, 307, 308, 309, 324A 
48 Stat., as amended, 1064, 1065, 1066, 1081, 1082, 1083, 
1084, 1085, 1101; 47 U.S.C. Sees. 152, 153, 154, 301, 303, 
307, 308, 309, 532, 533, 535, 542, 543, 544A, 552 as 
amended, 106 Stat. 1460.
8. Section 76.605 is amended by redesignating the exist 
ing paragraphs (a)(2) through (a)(12) as paragraphs (a)(3) 
through (a)(13). and adding a new paragraph (a)(2) and to 
read as follows:
76.605 Technical standards.
(a) * * *
(2) Cable systems shall transmit channels to subscriber 
premises equipment on frequencies in accordance with the 
channel allocation plan set forth in the Electronics Indus 
tries Association's "Cable Television Channel Identification 
Plan. EIA IS-132. May 1994" (EIA IS-132). This 
incorporation by reference was approved by the Director of 
the Federal Register in accordance with 5 U.S.C. 522(a) 
and 1 CFR Part 51. Cable systems are required to use this 
channel allocation plan for signals transmitted in the fre 
quency range 54 MHz to 1002 MHz. This incorporation by 
reference was approved by the Director of the Federal 
Register in accordance with 5 U.S.C. 522(a) and 1 CFR 
Part 51. Copies of EIA IS-132 may be obtained from: 
Global Engineering Documents. 2805 McGraw Ave.. Irvine 
CA 92714. Copies of EIA IS-132 may be inspected during 
normal business hours at the following locations: Federal 
Communications Commission, 1919 M Street. NW, Dock 
ets Branch (Room 239). Washington. DC. or the Office of 
the Federal Register. 800 North Capitol Street. NW. Suite
700. Washington, DC. This requirement is effective on May 
31. 1995. for new and re-built cable systems, and on June 
30. 1997. for all cable systems.
9. New Section 76.630 is added to read as follows:
76.630 Compatibility with consumer electronics equip 
ment.
(a) Cable system operators shall not scramble or other 
wise encrypt signals carried on the basic service tier. 
Requests for waivers of this prohibition must demonstrate 
either a substantial problem with theft of basic tier service 
or a strong need to scramble basic signals for other reasons. 
As part of this showing, cable operators are required to 
notify subscribers by mail of waiver requests. The notice to 
subscribers must be mailed no later than thirty calendar 
days from the date the request waiver was filed with the 
Commission, and cable operators must inform the Com 
mission in writing, as soon as possible, of that notification 
date. The notification to subscribers must state:
On (date of waiver request was filed with the Com 
mission), (cable operator's name) filed with the Fed 
eral Communications Commission a request for 
waiver of the rule prohibiting scrambling of channels 
on the basic tier of service. 47 C.F.R. Section 
76.630(a). The request for waiver states (a brief sum 
mary of the waiver request). A copy of the request 
for waiver is on file for public inspection at (the 
address of the cable operator's local place of busi 
ness).
Individuals who wish to comment on this request for 
waiver should mail comments to the Federal Com 
munications Commission by no later than 30 days 
from (the date the notification was mailed to sub 
scribers). Those comments should be addressed to 
the: Federal Communications Commission. Cable 
Services Bureau. Washington. D.C. 20554. and 
should include the name of the cable operator to 
whom the comments are applicable. Individuals 
should also send a copy of their comments to (the 
cable operator at its local place of business).
Cable operators may file comments in reply no later than 7 
days from the date subscriber comments must be filed.
(b) Cable system operators that provide their subscribers 
with cable system terminal devices and other customer 
premises equipment that incorporates remote control capa 
bility shall permit the remote operation of such devices 
with commercially available remote control units or other 
wise take no action that would prevent the devices from 
being operated by a commercially available remote control 
unit. Cable system operators are advised that this require 
ment obliges them to actively enable the remote control 
functions of customer premises equipment where those 
functions do not operate without a special activation proce 
dure. Cable system operators may. however, disable the 
remote control functions of a subscriber's customer prem 
ises equipment where requested by the subscriber.
(c) Cable operators may not alter the infrared codes used 
to operate the remote control capabilities of the customer 
premises equipment they employ in providing service to
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9 FCC Red No. 10 Federal Communications Commission Record FCC 94-80
subscribers. Cable operators may. however, use new equip 
ment that includes additional infrared codes for new re 
mote control functions that were not included in existing 
models of customer premises equipment.
(d) Cable system operators that use scrambling, 
encryption or similar technologies in conjunction with 
cable system terminal devices, as defined in Section 15.1(e) 
of this chapter, that may affect subscribers' reception of 
signals shall offer to supply each subscriber with special 
equipment that will enable the simultaneous reception of 
multiple signals. This equipment could include, for exam 
ple, set-top cable system terminal devices with multiple 
descramblers/decoders and/or timers, and signal bypass 
switches.
(1) The offer of special equipment shall be made to new 
subscribers at the time they subscribe and to all subscribers 
at least once each year.
(2) Such special equipment shall, at a minimum, have 
the capability:
(i) To allow simultaneous reception of any two or more 
scrambled or encrypted signals and to provide for tuning to 
alternative channels on a pre-programmed schedule: and,
(HI To allow direct reception of all other signals that do 
not need to be processed through descrambling or 
decryption circuitry (this capability can generally be pro 
vided through a separate by-pass switch or through internal 
by-pass circuitry in a cable system terminal device).
(3) Cable system operators shall determine the specific 
equipment needed by individual subscribers on a case- 
by-case basis, in consultation with the subscriber. Cable 
system operators are required to make a good faith effort to 
provide subscribers with the amount and types of special 
equipment needed to resolve their individual compatibility 
problems.
(4) Cable operators shall provide such equipment at the 
request of individual subscribers and may charge for pur 
chase or lease of the equipment and its installation in 
accordance with the provisions of the rate regulation rules 
for customer premises equipment used to receive the basic 
service tier, as set forth in Section 76.923. Notwithstanding 
the required annual offering, cable operators shall respond 
to subscriber requests for special equipment for reception 
of multiple signals that are made at any time.
(e) Cable system operators shall provide a consumer 
education program on compatibility matters to their sub 
scribers in writing, as follows:
(1) The consumer information program shall be pro 
vided to subscribers at the time they first subscribe and at 
least once a year thereafter. Cable operators may choose 
the time and means by which they comply with the annual 
consumer information requirement. This requirement may 
be satisfied by a once-a-year mailing to all subscribers. The 
information may be included in one of the cable system's 
regular subscriber billings.
(2) The consumer information program shall include the 
following information:
(i) Cable system operators shall inform their subscribers 
that some models of TV receivers and videocassette record 
ers may not be able to receive all of the channels offered 
by the cable system when connected directly to the cable 
system. In conjunction with this information, cable system 
operators shall briefly explain, the types of channel com 
patibility problems that could occur if subscribers con 
nected their equipment directly to the cable system and 
offer suggestions for resolving those problems. Such sugges 
tions could include, for example, the use a cable system 
terminal device such as a set-top channel converter. Cable 
system operators shall also indicate that channel compati 
bility problems associated with reception of programming 
that is not scrambled or encrypted programming could be 
resolved through use of simple converter devices without 
descrambling or decryption capabilities that can be ob 
tained from either the cable system or a third party retail 
vendor.
(ii) In cases where service is received through a cable 
system terminal device, cable system operators shall in 
dicate that subscribers may not be able to use special 
features and functions of their TV receivers and 
videocassette recorders, including features that allow the 
subscriber to: view a program on one channel while si 
multaneously recording a program on another channel 
record two or more consecutive programs that appear on 
different channels; and, use advanced picture generation 
and display features such as "Picture-in-Picture," channel 
review and other functions that necessitate channel selec 
tion by the consumer device.
(iu) In cases where cable system operators offer remote 
control capability with cable system terminal devices and 
other customer premises equipment that is provided to 
subscribers, they shall advise their subscribers that remote 
control units that are compatible with that equipment may 
be obtained from other sources, such as retail outlets. 
Cable system operators shall also provide a representative 
list of the models of remote control units currently avail 
able from retailers that are compatible with the customer 
premises equipment they employ. Cable system operators 
are required to make a good faith effort in compiling this 
list and will not be liable for inadvertent omissions. This 
list shall be current as of no more than six months before 
the date the consumer education program is distributed to 
subscribers. Cable operators are also required to encourage 
subscribers to contact the cable operator to inquire about 
whether a particular remote control unit the subscriber 
might be considering for purchase would be compatible 
with the subscriber's customer premises equipment. Cable 
operators also may wish to advise subscribers that sub 
scriber-owned remote control units may not be functional 
if the cable system changes terminal devices.
Note: The provisions of paragraphs (a) and (b) of this 
section are effective July 31. 1994. and May 31, 1994, 
respectively. The provisions of paragraphs (c) 
through (e) of this section are effective October 31. 
1994. except for the requirement under section 
(d)(\)(i) for cable system operators to supply cable 
system terminal devices with multiple tuners, which 
is effective October 31. 1995. The initial offer of 
special equipment to all subscribers, as required un 
der paragraph (d) of this section shall be made by 
October 31. 1994.
APPENDIX B
Parties Filing Comments and/or Reply Comments
Parties Filing Comments
1. American Telegraph and Telephone Company
2. Barden Cablevision
3. Bell Atlantic
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FCC 94-80 Federal Communications Commission Record 9 FCC Red No. 10
4. BellSouth Telecommunications, Inc.
5. Cable-Consumer Electronics Compatibility Advi 
sory Group (The CAG also submitted an Erratum to 
Appendices C and D of its comments on February 
15. 1994)
6. Cable Telecommunications Association, Inc.
7. Cablevision Industries Corporation
8. Cablevision Systems Corporation
9. Christopher A. Catotti
10. Circuit City Stores. Inc.
11. Continental Cablevision. Inc.
12. Cox Cable Communications and Newhouse 
Broadcasting Corporation
13. Chris Carrier
14. John Fitzgerald
15. General Instrument Corporation
16. Greater Media, Inc.
17. Hewlett-Packard
18. Home Box Office
19. Interactive Multimedia Association
20. Joint Comments of InterMedia Partners. ML Me 
dia Partners and ML Media Opportunity Partners 
(Joint Cable Commenters)
21. Lakes Region Cable Television Consortium
22. Media General Cable of Fairfax County, Inc.
23. Howard N. Meyer
24. Mitsubishi Electronics America, Inc.
25. Multichannel Communications Sciences. Inc.
26. News Datacom, Inc.
27. New York City Department of Telecommunica 
tions and Energy
28. O.D. Page
29. Pacific Telesis Group. Pacific Bell and Nevada 
Bell (Pacific Bell)
30. Sharp Electronics Corporation
31. Sacramento Metropolitan Cable Television Com 
mission
32. Tele-Communications. Inc.
33. Time Warner Entertainment Company, L.P.
34. The Titan Corporation
35. United States Telephone Association
36. Zenith Electronics Corporation
Parties Filing Reply Comments
1. Ameritech
2. Cable-Consumer Electronics Compatibility Advi 
sory Group (The CAG also submitted an Erratum to 
Appendices C and D of its comments on February 
15. 1994)
3. Cable Telecommunications Association, Inc.
4. Cablevision Systems Corporation
5. Comcast Cable Communications. Inc.
6. The Consumer Electronics Group of the Electron 
ics Industries Association
7. Consumer Electronics Retailers Coalition
8. The Consumer Federation of America and the 
Home Recording Rights Coalition
9. Continental Cablevision, Inc.
10. DIRECTV. Inc.
11. General Instrument Corporation
12. GTE Service Corporation
13. Home Box Office
14. Joint Comments of InterMedia Partners. ML Me 
dia Partners and ML Media Opportunity Partners 
(Joint Cable Commenters)
15. Media General Cable of Fairfax County. Inc.
16. Multichannel Communications Sciences, Inc.
17. National Cable Television Association. Inc.
18. New York City Department of Telecommunica 
tions and Energy
19. Nobody Beats The Wiz. Inc.
20. NYNEX Telephone Companies
21. Pacific Telesis Group, Pacific Bell and Nevada 
Bell (Pacific Bell)
22. Progressive Retailers Organization. Inc.
23. Oregon Consumer League
24. Satellite Broadcasting and Communications Asso 
ciation of America
25. Scottsdale Television Labs
26. Tele-Communications. Inc.
27. Time Warner Entertainment Company. L.P.
28. The Titan Corporation
29. Viacom International Inc.
30. Zenith Electronics Corporation
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