Charter Communications requested a two-year waiver of the FCC’s ban on set-tops with integrated security, with the MSO claiming the exemption is necessary to adopt a less expensive software-downloadable security solution like the one CEO Tom Rutledge previously deployed at Cablevision Systems.
“The waiver would enable Charter to initiate implementation of an open-standard, downloadable-security solution that supports third party retail devices,” the cable operator said in a Nov. 1 filing with the FCC.
Under Rutledge’s leadership, Charter plans to migrate all of its cable systems to all-digital, and the downloadable security system is a key component of that, according to the MSO.
“With the Commission’s support, Mr. Rutledge previously led Cablevision’s successful deployment of downloadable security in 2009-2010 [when he was the operator's chief operating officer],” Charter said. “Now Mr. Rutledge would like to do the same for Charter.”
Like Cablevision, “Charter needs similar temporary relief from the integration ban so that it can deploy these dual-security boxes and focus its technical and strategic resources on an efficient downloadable-security implementation,” the St. Louis-based operator said in the filing.
However, moving to downloadable security will be much more difficult for Charter than it was for Cablevision, according to Charter. Whereas Cablevision’s deployment was concentrated entirely in the New York City metropolitan area, Charter has more than 190 headends in 25 states, which pass a median of 23,000 homes. In addition, 75% of Charter’s subscribers live outside of the nation’s 20 biggest designated market areas (DMAs), according to the MSO.
Charter said the initial downloadable security devices will include two security systems: a chip that would serve as the future platform for non-integrated downloadable security, and traditional integrated security that would be used during the two-year transitional period before downloadable security is activated.
In arguing the waiver would support the public interest, Charter said that once downloadable security is operational, the operator will be able to procure lower-cost set-tops from a broad set of suppliers. That will “lower equipment costs borne by consumers, open the doors to a wider variety of devices and features, and facilitate a more efficient transition to an all-digital network by reducing the costs for terminal equipment needed to support consumers through that transition,” according to Charter.
Consumer-electronics manufacturers, meanwhile, would “be able to have more confidence in making investments to develop new retail downloadable-security products once they have seen that the system has actually been successfully implemented and that downloadable devices can work without the need for CableCards.” In addition, a security system that is partly software-based will be better position Charter to support an even wider variety of devices “if and when content providers grow more comfortable with software-based security.”
Charter’s planned downloadable set-top security system would combine software-based security with a hardware “root of trust,” housed in a commodity chip. The key ladder utilized for the hardware root of trust would be available in the same commodity chips that also support Cablevision’s downloadable security, and will be available on an open, royalty-free basis, according to Charter.
Even after downloadable security is initiated, Charter would continue to “simulcrypt” its services using both security technologies to avoid stranding customers with retail CableCard devices or Charter’s legacy leased set-top boxes, of which 2.75 million include CableCards. That reliance on CableCards also assures that Charter “has plenty of incentive to make sure that CableCards work in its systems to support the 33,000 CableCards it has provided to customers for their use in retail devices,” the MSO added.
Charter pointed out that the FCC has repeatedly described downloadable security as “the preferred path for complying with its separable security rules” and has sought to avoid rules that hinder the development of “a less expensive and more flexible system for both protecting system security and creating a consumer product interface.”
The commission also has granted exemptions to the integrated set-top ban, with Charter noting that “It is not necessary for 100% of navigation devices leased by cable operators to have the same security as third-party devices.”
Since the ban went into effect in 2007, the FCC has exempted analog devices. It later allowed MSOs to deploy digital transport adapters (DTAs) with integrated security “without any apparent adverse effect on cable operator support for retail CableCard devices,” Charter said.
During the first year in which the integration ban was in effect, Charter was granted a one-year waiver to continue deploying new integrated set-top boxes, also “with no adverse effect on its support for retail CableCard devices,” the operator said. “Likewise, there is no evidence that Cablevision’s support for its customers’ use of CableCards has in any way diminished as a result of its waiver for downloadable security.”