Digital Terminal Adapter (DTA) devices have no built-in return-path capabilities, making them unable to directly access video on demand (VoD) or other "two-way" cable services, but it turns out the simple channel-zappers can receive network instructions to "force-tune" to a particular channel.

And that could spark a debate over whether the devices should be viewed as "advanced" in the eyes of the Federal Communications Commission (FCC) , as it chews on newly proposed CableCARD rules.

Comcast Corp. (Nasdaq: CMCSA, CMCSK), in reply comments submitted last week, argued that this force-tuning capability -- already used to deliver Emergency Alert System (EAS) messages to DTAs -- doesn't make those inherently one-way devices interactive or somehow advanced.

How the FCC ends up viewing DTA force-tuning is important because the Commission is considering a blanket exemption for HD-capable versions. That would give MSOs the green light to buy and deploy them without worrying about obtaining separate waivers to sidestep the integrated set-top security ban of July 2007. (See FCC Inches Towards Net-Agnostic Gateways and FCC Chews on HD-DTA Exemption .)

MSOs such as Comcast, which has already deployed millions of standard-definition DTAs for its Project Cavalry analog reclamation initiative, are eager to use the HD-DTA as a low-cost option (unit pricing is expected to be less than $50 when volumes ramp up). (See Comcast's $1B Bandwidth Plan , Cable ONE Seeks $50 HD Box, and Comcast Lights Up DTA Encryption .)

However, the FCC, which has already awarded several waivers for SD-DTAs with integrated security, could forgo any blanket HD-DTA exemptions if it decides that the hi-def versions are "advanced" boxes. Key to the SD-DTA waivers was the notion that they are limited, one-way digital-to-analog video converter boxes that don't support traditional DVR services, come with native Internet connections, or support other relatively sophisticated features. (See Comcast's $1B Bandwidth Plan , FCC Believes in Evolution-ary DTAs, and Huawei Gets Box Break at the FCC .)

CableOne , still the only MSO to get a waiver to use HD-DTAs, has already argued that HD services should no longer be considered advanced because they represent critical competitive table stakes. (See Scoop! Cable ONE Makes HD-DTA Picks , and HD No Longer an 'Advanced' Service?)



The force-tuning issue comes up because Comcast acknowledged, in its comments, that the capability is in DTAs, for EAS delivery, and "could theoretically be extended to other services." But that doesn't mean the DTAs are two-way devices, the MSO argued, because the boxes themselves "cannot function as interactive devices."

As an example of one of those other services, Comcast has been asked if the iPad-driven Xfinity remote control, demonstrated at The Cable Show in May, could work with DTAs. Technically speaking, the app could be mapped to the boxes, but Comcast hasn't made any formal plans to do that. (See To Xfinity... & Beyond!.)

"This service is being developed for our two-way digital set-top boxes, not for DTAs," Comcast told the FCC. It might be possible to adapt the app for DTAs, but that "would require significant new standardization and development work."

Even if such work was done, Comcast holds that the DTA wouldn't count as an interactive device, since customers would still have to send requests to the headend via a discrete device (e.g., an iPad) using a separate Internet connection.

"This would be analogous to the old one-way converter boxes that could receive pay-per-view content if the customer placed an order for the content via a phone call to the cable operator. It cannot be credibly argued that this made the converters 'two-way,'" Comcast said.

The FCC isn't expected to vote on the new CableCARD rule changes until later this year, but some early comments have come out against any further agency dispensation for DTAs with baked in security.

For example, Beyond Broadband Technology LLC (BBT) , a cable consortium backed by some Tier 2 and Tier 3 MSOs, which has developed a downloadable security platform, has argued that one-way boxes can "directly or indirectly do essentially everything a two-way device can do, such as provide an electronic program." BBT also questioned the historic "no-DVR" restriction on DTAs, holding that it could be circumvented with a whole-home recording device or a "modular DVR add-on device." (See Policy Watch: TiVo, Cable Trade SDV Barbs and BBT Notches First Install .)

Public Knowledge claims the HD-DTA exemption would undermine the FCC's "common reliance goals" to help develop a retail market. Comcast (and the bulk of the US cable industry) has already poked a hole in that argument, noting that common reliance is already achieved because more than 21 million CableCARD-equipped boxes have been deployed. (See CableCARD Update .)

Although there's no indication that consumer electronics firms intend to sell DTAs directly to consumers, Panasonic Corp. (NYSE: PC), which favors the HD-DTA exemption, has asked that the FCC require cable to adopt standards that could underpin a retail market for such boxes by July 2011.

Comcast said it's willing to work with Panasonic and the rest of the cable industry on DTA retail efforts, "but does not support any new 'common reliance' mandate in this area."

— Jeff Baumgartner, Site Editor, Light Reading Cable