STATEMENT OF 
COMMISSIONER ROBERT M. McDOWELL
Re:  Cable Television Technical and Operational Requirements, MB Docket No. 12-217
I vote in support of this notice initiating a review of cable rules that establish standards to 
ensure subscribers receive good quality signals, as required under section 624(e) of the 
Communications Act, and protect spectrum users from potential harmful interference caused by 
so-called signal “leaks” from cable systems.  Today, approximately 80 percent of cable 
subscribers use digital systems to access video programming, but these rules have been based on 
analog technologies and standards.  In fact, these rules, for the most part, have remained 
unchanged for decades while technology and innovation have passed them by.  For example, the 
majority of the interference rules date back to 1984 when “Beverly Hills Cop” was the top 
grossing film and Prince’s “When Doves Cry” was Billboard’s song of the year.  The cable 
signal quality rules are vintage 1992 when “Aladdin” was the top grossing film and “End of the 
Road” by Boyz II Men topped the music charts.  A lot has happened since those days.  Thus, it 
makes sense – and is a matter of good government – to re-evaluate and modernize these rules 
based on today’s marketplace.  
The video market in general, and the cable industry in particular, are in a continuing state 
of evolution.  Cable operators are investing heavily in all-digital systems but they are also 
building Internet Protocol platforms for the delivery of their cable offerings.  Furthermore, this 
transformation is taking place in an environment where content is now delivered across multiple 
platforms blurring the boundaries between traditional and new media.  For instance, cable 
operators offer traditional cable service, but they also offer broadband Internet access which can 
be directly connected to high-definition televisions and mobile devices to access programming, 
making content available anywhere, anytime.  
This notice not only proposes quality standards for current industry delivery methods but 
also considers metrics for technologies in varying states of deployment.  These potential 
standards could also be applied to technologies yet to be developed.  As media convergence 
evolves, and as the cable industry migrates further into an all IP world, we need to ensure that, 
despite what may be the best of intentions, our regulations do not place an undue burden on 
industry, freeze tomorrow in yesterday’s technology, cause regulatory uncertainty, exceed our 
legal authority or stifle innovation. 
I look forward to engaging with all stakeholders regarding these matters as well as others 
this notice will assuredly raise.  I hope we can reduce the burdens of testing and recordkeeping 
on industry, while complying with the letter and spirit of the law, thus ensuring that Americans 
have reliable cable signals and preventing harmful interference to spectrum users.  
I applaud the Chairman for undertaking this review, along with proposing to eliminate 
and update other outdated cable regulations. I also thank the staff of the Media Bureau, 
especially the Engineering Division, for their diligent work on this item.  This order, once again, 
proves the importance of engineers to the Commission’s mission and our need to ensure that we 
can recruit and retain talented and dedicated engineers.