STATEMENT OF 
COMMISSIONER AJIT PAI
Re:  Cable Television Technical and Operational Requirements, MB Docket No. 12-217
In this Notice of Proposed Rulemaking, we seek comment on a variety of 
modifications to the Commission’s Part 76 technical rules to account for the rise in digital 
cable service.  Or, to put it another way, we begin the process of matching our cable 
regulations to the realities of the American marketplace.  The ongoing transition from 
analog to digital cable systems is bringing widespread benefits to consumers, enabling 
them to enjoy more advanced services, a wider range of programming choices, and better 
picture quality.  This item appropriately seeks to accelerate these trends.
I am pleased to support this effort and commend the Chairman for his leadership 
on this front.  Given the pace of change in the communications industry, it is imperative 
that we review our rules regularly and assess whether they should be updated or 
eliminated to reflect changes in technology or marketplace conditions.  As the technology 
used to transmit signals is changing, so too must the Commission’s rules.  In keeping 
with this approach, this item seeks to modernize our technical standards for cable systems 
while at the same time minimizing the burdens we place on the private sector.
I am optimistic that the proposals set forth in this Notice of Proposed Rulemaking 
represent a common-sense approach for moving ahead, and I look forward to reviewing 
the input of cable operators, consumer groups, local franchising authorities, and all other 
stakeholders.  There are, however, a couple of issues that merit special attention.
First, I do not oppose asking for comment on whether we should supplement our 
current “proof-of-performance” rules with qualitative measures to assess subjective 
consumer perceptions of video quality, but I do think we should proceed with caution in 
this regard.  Administrative rules should be clear and easy to administer, and it may be 
difficult to make an accurate judgment as to what is in the eyes of millions of beholders.
Second, we seek comment on a few ideas that could have the effect of increasing 
testing requirements on cable systems.  In assessing such proposals, I will carefully 
examine the record to see if the costs of these proposals are outweighed by their benefits.
Finally, I hope that this item portends further reforms to our Part 76 rules.  For 
example, I would support resolving another issue related to the transition from analog to 
digital cable service: basic tier encryption.  I stand willing to work with the Chairman and 
my fellow Commissioners on this and other matters that could bring cable regulation 
more fully in line with the times.
In conclusion, I want to thank the Bureau staff for their hard work on this 
complicated and highly technical item.  I particularly want to thank Jeff Neumann, 
Michelle Carey, and Alison Neplokh for translating several parts of it into plain English 
for me during a briefing earlier this week.