SCTE is pleased to submit the attached as a response to the Request for 

Information from the National Institute of Standards and Technology [Docket 

No. 0909100442–0563–02] on the Effectiveness of Federal Agency 

Participation in Standardization in Select Technology Sectors for National 

Science and Technology Council’s Sub-Committee on Standardization. 

We look forward to the future activities of the Subcommittee, and would be 

pleased to provide any additional information that they would find worthwhile. 

Stephen P. Oksala 

Vice President, Standards 

(610) 594-7302 

soksala@scte.org
The Society of Cable Telecommunications Engineers (SCTE) is pleased to 

submit these comments in support of the effort to determine how the US 

Government can more effectively participate in the important standardization 

efforts underway today. SCTE is a non-profit professional association that 

provides technical leadership for the telecommunications industry and serves 

its members through professional development, standards, certification and 

information. SCTE is an ANSI-accredited standards development 

organization. 

SCTE has had involvement with the US Government; some of our standards 

have been adopted into regulations by the Federal Communications 

Commission and by various state governments, primarily via indirect 

participation but occasionally by direct participation1

. There is ample 

evidence that the issues involved both standards developers and industries. 

SCTE would therefore like to offer its thoughts as to key points for the US 

Government to consider as it moves forward. 

Regulations that reference standards need to be updated in a timely 

fashion. While in decades past, technologies and protocols for cable 

telecommunications equipment might not require updating for several years, 

current development cycles are often in the timeframe of 18 months. 

Agencies that adopt standards need to follow them closely enough to either 

move to new versions, or participate in a way that makes the transition easy. 

When the regulatory adoption is many versions behind, nobody benefits. 

Unfortunately, a number of SCTE standards have been adopted by the FCC, 

but the newer revisions of those standards have not been adopted. 

Government can productively facilitate standardization in complex, 

cross-sector environments but there remain nonetheless areas where 

market forces should apply. There are certain problems where standards 

are necessary for a solution, but where the scope of the problem is such that 

no single industry segment – and therefore no single standards developing 

organization – can provide the needed standards. In these cases, it is 

appropriate – even desirable – for the US Government to provide a level of 

facilitation to make sure that the work gets done. However in considering the 

use of a facilitation effort, the US Government must remember that facilitation 

of cross-industry standards programs is a very complex process. It is 

 

1 Current direct participation by the US Government is from NTIA, a unit of the Department of

Commerce, which is involved in standards that are approved both by SCTE and at the international

level by ITU.   
important that its use be limited to those problems that really need it; for 

many issues, simpler mechanisms that already exist will be more effective. 

Even when using those simpler mechanisms, it is necessary to determine 

that having a standard or standards in a particular area is, in fact, worthwhile. 

Sometimes it is better to let the market determine the solution rather than 

trying to work top down. 

Involve all stakeholders. If a standardization effort is important enough to 

merit specific attention from the US Government, it is also likely to be 

important enough to affect many different stakeholder communities. It is 

essential therefore that when the US Government selects an organization for 

standardization, it picks one that has well-defined consensus processes that 

ensure that all interested parties have the opportunity to participate. Predetermination by the US Government of the definition of stakeholder groups 

in order to streamline this process is almost certain to be unsatisfactory. As 

an example, there is common use of the term ICT (information and 

communications technology) to represent an industry – yet the organizations 

that participate in that space cover a wide variety of businesses and 

consequent standardization preferences. The so-called ICT industry 

includes telephone companies, cable companies, consumer electronics 

manufacturers, computer manufacturers, internet service providers, and 

application and service providers of all sorts. Needless to say it should be 

clear that defining an industry for possibly limiting participation or for 

establishing voting categories is a difficult if not impossible task. 

Encourage transparency and fairness. When choosing organizations for 

US Government participation, preference should be given to organizations 

that meet certain criteria for fair and open processes. The Federal Circular 

OMB A-115 defines those requirements clearly, as do the Essential 

Requirements used by the American National Standards Institute (ANSI) are 

an excellent basis for this. This does not mean that the US Government 

should limit its choices to ANSI-accredited organizations; however it does 

mean that they should give preference to those organizations that meet 

those criteria. 

US Government Agencies need to make sure that their participation is 

clear and coordinated. Agency participants may have significantly different 

roles and therefore significantly different objectives. Among these are policy 

makers, technology experts, and procurement managers. It is important in a 

standards setting that an agency’s participants speak with a consistent voice. 
It is also important that this voice be relevant to the technical issues at hand; 

in the past, there have been (particularly at the international level) policy and 

political impact on the technical work which does a disservice to the process. 

Similarly it is very helpful where more than one agency is involved that the 

agencies have done some coordination. We recognize that each agency has 

its own responsibilities, and that there is therefore not always a single US 

Government position on specific technical standards. 

Respect Intellectual Property Rights. Many standards organizations rely 

on the sale of their standards for survival. The US Government has done an 

excellent job over the years of supporting those organizations by reminding 

users of regulations that copyright remains with the standards developer; that 

support should continue. Given the trends in government outside the United 

States, the US Government should also resist the temptation to join the 

chorus of governments who advocate the elimination of intellectual property 

in standards. The US standards system has thrived with the current RAND 

system, and will continue to do so. 

Provide appropriate financial support. The most important financial 

support that the US Government can provide is for all agencies to pay their 

share of the expenses for the standards organizations that they use as well 

as for the US standards system coordinated by ANSI. While there may be a 

case for more specific funding such as is used by the European Commission 

to support regulations, the decentralized US standards system would make 

this kind of program very difficult since the funding would of necessity pick 

winners and losers of not only standards organizations, but of the industries 

and sub-industries they represent.