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Old 05-29-2012, 11:35 PM   #8461
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Originally Posted by pdhenry View Post
My entire point is that TiVo owners are not being singled out. If you want one set-top box from Comcast it comes bundled with your programming tier. If you want a second set-top box you pay $8.95 or whatever the additional outlet fee is.
I never suggested Tivo owners were singled out. In fact, I am asking because I am adding an HDhomerun Prime to the mix, not a second Tivo.

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If you have one TiVo you (should) pay the tier price less the Customer Owned Equipment discount. If you have a second TiVo you (should) additonally pay the additional outlet fee less an additional COE discount.

You don't have to like it but there's logic in how it works, when it works.
This rests on the premise that television providers aught to receive something for each television in the home. That is a tenuous premise for any number of reasons. I am aware of nowhere that the FCC has stated that this is the case. Comcast does not charge for DTA boxes. Analog cable could be split easily with little consequence when done properly, and at some point in time, the cable companies stopped worrying about that.

Just because there is A logic to it, doesn't mean that the logic is good, or lawful. The logic here is to maximize the money to the cable company.

As a general rule, there is no additional cost to the cable company for the consumer adding additional outlets in their home. If it doesn't cost them anything, then why should the consumer pay for it (in a regulated environment, not a purely free market)?

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Originally Posted by pdhenry View Post
Comcast regularly undercharges some subscribers according to their published tariff (example: Charging the $1.10 second cable card fee rather than additional outlet fee for a second TiVo, and then discounting the second outlet by $2.50, making 2 cable cards cheaper than one) but it doesn't follow that subscribers are getting ripped off when they're charged according to the tariff.
Clearly, individual cases do not speak to the greater point of what the law requires, or what the intent of the law is. This goes both ways, both overcharges and undercharges.
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Old 05-30-2012, 12:13 AM   #8462
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Originally Posted by ncfoster
Analog cable could be split easily with little consequence when done properly, and at some point in time, the cable companies stopped worrying about that.
Actually what's happening now is very much like what happened way back in the days of early cable. When cable first came out you needed to rent a box for each TV. Then TV's became "cable ready" so you didn't need to rent boxes, but cable companies started charging outlet fees. Sure you could split the cable yourself, but if the cable company came out and saw you had done so, they jacked your rates. Then the FCC became peeved and the cable companies dropped the fees such that it was one charge per household (though that charge began to go up).

Then digital cable came along, a cable company's dream come true, since not only did it require boxes again, but it was unhackable so no third party descrambler boxes. Cable companies moved to all or mostly digital and they could then charge per TV again, but along came digital cable ready TVs. What would the cable companies do now? Encrypt all their channel, making the TVs worthless. That wouldn't do so the FCC mandated cableCARDs, which cable companies reluctantly went along with, charging whatever they wanted per card (Comcast was actually cheaper than many other providers). Then the FCC said pricing had to be reasonable so we're back to cable companies charging outlet fees just like in the "olden days". Actually worse than olden days because an outlet is a box, not a TV. Two DVRs connected to one TV is two "outlets".

The cable companies will end up losing this battle though since multi-tuner DVRs and streaming boxes (like TiVo's upcoming ip set top box) will basically stop the per TV charge since the cable companies won't know how many TV's you are using. As far as they'll know you have one cable card. Basically the third party whole home DVR should kill outlet fees for good. Knowing cable companies though, they'll probably start charging per tuner on 3rd party boxes.


Outlet fees are and always have been a racket. It's like the cell phone companies charging for text messaging. Both cost their respective company next to nothing to provide so it's virtually 100% profit.
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Old 05-30-2012, 01:44 AM   #8463
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I had been paying nothing for two CableCards in my S3 for the last 5 years.
There was an $8 Digital Additional Outlet fee and 2 credits of $2.50 for Customer Owned Equipment. I was ok with that. I had unsuccessfully tried to argue the DAO fee a year or so ago with no luck. They wouldn't budge. That was before I familiarized myself with some of the FCC rulings. They come in handy when arguing with this corporation.
I recently added a second S3 and low and behold all my fees had changed. I was charged $1.10 per CableCard for a total of $4.40 plus TWO $8 DAO fees but SHOCK - my credits remained the same only 2 @ $2.50. Adding the 2nd TiVo increased my bill to an unreasonable Dollar amount. I had reached my limit and was finally ready to spend the time discussing this with as many people at Comcast as it would take. There was simply no way I was going to pay them $122.40 per year JUST to add my 2nd TiVo. I already pay through the nose for programming.
I called and was eventually transferred 3 levels up arguing about the customer owned equipment credits and the DAO fees, constantly citing the FCC rulings. After about 30 minutes on hold, the billing "specialist" I spoke with "admitted" they had made errors in my billing and agreed to remove the $8 fee (and credit me for 12 months of it), adjust the CableCard fees to charge for only the first card in each device (at $1.10), and confirm the customer owned equipment credits.
I just got my current statement and they did remove the DAO fee but sure enough - they added it back as a line item after removing it.
I just got off the phone with them and had it removed and was promised it wouldn't show up again next month.
So - to summarize, for 2 TiVo Series 3 with 2 CableCards each, Im paying $2.20 - $1.10 per TiVo.
The DAO fees are gone, as are the customer owned equipment credits.
Yes the Customer Owned Equipment credits are gone. I can easily live with this as I think those credits were to offset a bit of those ridiculously nefarious $8 fees.
Its absolutely crazy how many differences in pricing there are around the country and even within the same regions. Good luck to you if you have hours to spend on the phone arguing this billing practice. It worked for me hopefully it will for you too.
And what do I find tonight...? 2 unpaired cards in my 2nd S3. Seems that removing the DAO fee busted my pairing. We just can't win. Gotta call them back and escalate again.
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Old 05-30-2012, 09:52 AM   #8464
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Originally Posted by pdhenry View Post
The actual FCC rule text is here:
http://www.hallikainen.com/FccRules/2012/76/1205/
And Comcast is not adhering to those rules, because they do not charge a single, uniform rate to rent a card across their footprint. Yes, the rates are published, but the actual billing that occurs is all over the map - some people get cards for free, some cost $1.50 each. Or $1.10. Some people get customer owned equip credits, some do not. Sometimes A/O fees are applied, sometimes not. Same with 'HD tech fees' even if you don't have their box.

Every other cableCo charges a flat $2-4 or so fee to rent every card, which is exactly what the FCC intended with these rules. Comcast does not, and they are therefore in violation of those rules.

Keep filing FCC complaints, peeps.
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Old 05-30-2012, 12:20 PM   #8465
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Every other cableCo charges a flat $2-4 or so fee to rent every card, which is exactly what the FCC intended with these rules. Comcast does not, and they are therefore in violation of those rules.
Well no, unless the other cableCo also charges a visible fee to rent every set-top box. If the set-top box is included in the price of a tier the cableCo can't charge an additional fee for the card (it would violate the clause that reads "No service fee shall be imposed on a subscriber for support of a subscriber-provided device that is not assessed on subscriber use of an operator-provided device.") Since Comcast bundles the (first) box with their tiers they must apply a discount from the tier price for a card rather than applying a unique fee for the card.

Just my opinion but I don't think it's an FCC violation for Comcast to fail to charge as much as they should. I think it shows cableCards to be a systemic problem. The CSRs can't do the backend account linking properly to make the cards work, and they can't deal properly with all of the account perturbations (e.g., a customer wants a card with a programming tier that doesn't normally include a set-top box, multiple cards per device vs. multiple devices...) - it's too easy for a CSR to fail to get billing set up correctly, although in my case they've consistently underbilled (I'd be more motivated to help them get it right if they were to overbill).
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Old 05-30-2012, 02:23 PM   #8466
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That's the rate for the first outlet - Comcast's programming tiers include the rental for the first set-top box for those tiers that require a box.
That is not what it says. You are entitled to your own opinion. You are not entitled to your own facts.

When I first got cable in 1973 (fuzzyview in Tallahassee), they charged for each outlet. They stopped doing that at some point. I do not know if it was due to FCC regulations or some other reason. They were not charging for each outlet at the time of the digital conversion. Switching to all digital should not enable them to re-instate the per outlet charge. They pay the content providers per subscriber, not per outlet.

The phone company used to charge for each extension and you had to use their equipment.
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Old 05-30-2012, 06:56 PM   #8467
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That is not what it says. You are entitled to your own opinion. You are not entitled to your own facts.

When I first got cable in 1973 (fuzzyview in Tallahassee), they charged for each outlet. They stopped doing that at some point. I do not know if it was due to FCC regulations or some other reason. They were not charging for each outlet at the time of the digital conversion. Switching to all digital should not enable them to re-instate the per outlet charge. They pay the content providers per subscriber, not per outlet.

The phone company used to charge for each extension and you had to use their equipment.
Sigh. So you're saying that Comcast is saying that the first card in every device is free? And you're saying that no other fee should apply for that?

If you just want to stick the coax into the back of your clearQAM TV Comcast doesn't care. If you have an analog TV and want to receive channels 2-99 that you used to get with analog cable (plus a bunch of SD digital channels that your analog TV never could tune), Comcast will let you have for free up to three DTAs so you can watch ex-analog programming to your heart's content. But if you want to watch something that requires a digital set-top box from Comcast they'll charge you for that. If you want to use your device (TiVo, etc.) instead of a Comcast box they'll give you a price break compared to renting the Comcast box.

The equivalent to free additional analog outlets is still there and it's not anything with a CableCard.
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Old 05-30-2012, 07:59 PM   #8468
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Sigh. So you're saying that Comcast is saying that the first card in every device is free?
***Etremely heavy sigh*** That's exactly what I am saying. Otherwise it should read "$0 for first card, $1.10 for additional cards".

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And you're saying that no other fee should apply for that?
Are you being deliberately obtuse? What we are all saying is that FCC regulations REQUIRE them to clearly state what the fee for a CableCARD is. You are the one claiming that the outlet fee is for the CableCARD. They are in fact charging you a fee for the ability to receive all of the channels in your package at more than one outlet. I have never claimed that the fee is illegal or a violation of FCC regulations. Just that is sleazy and unjustified.

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If you just want to stick the coax into the back of your clearQAM TV Comcast doesn't care. If you have an analog TV and want to receive channels 2-99 that you used to get with analog cable (plus a bunch of SD digital channels that your analog TV never could tune), Comcast will let you have for free up to three DTAs so you can watch ex-analog programming to your heart's content. But if you want to watch something that requires a digital set-top box from Comcast they'll charge you for that. If you want to use your device (TiVo, etc.) instead of a Comcast box they'll give you a price break compared to renting the Comcast box.

The equivalent to free additional analog outlets is still there and it's not anything with a CableCard.
NO, IT IS NOT THE SAME. GUIDE DATA WAS AVAILABLE FOR THE ANALOG CHANNELS. IT IS STILL AVAILABLE FOR THE EX-ANALOG CHANNELS IF YOU ARE USING A DTA AND A TIVO 2. IT IS NOT AVAILABLE ON A TIVO 3 or 4 W/O A CABLE CARD.

There, was that clear enough for you or are you going to continue to obfuscate and spin what Comcast is doing? BTW, at least here, you get 2 free DTAs, not 3. I'm quite certain you wouldn't even get those if they weren't mandated by the FCC. I suspect Comcast is considering levying a charge for them as soon as the mandate expires later this year.
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Old 05-30-2012, 08:18 PM   #8469
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Originally Posted by pdhenry
If you just want to stick the coax into the back of your clearQAM TV Comcast doesn't care. If you have an analog TV and want to receive channels 2-99 that you used to get with analog cable (plus a bunch of SD digital channels that your analog TV never could tune),
That's a no to both those statements.

First off Comcast does care, which is why they asked for and got a waiver from the FCC to encrypt all channels. There is no clearQAM with Comcast anymore (read my previous post).

Second Comcast is aggressively removing analog channels from all their systems. About 2 years ago they removed all the analog channels except for the basic tier in my area, which is about 20 channels. Last month they removed those, so there are no analog channels anymore. They've done the same in most of their major markets.

So basically sticking a coax cable into the back of your clearQAM TV will get either snow or an error message. If not today where you are, then soon. They've completed the initial phase and they're currently 22% complete with the final phase.

http://www.lightreading.com/document...&site=lr_cable
http://www.lightreading.com/document...&site=lr_cable
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Old 05-31-2012, 06:35 AM   #8470
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Well no, unless the other cableCo also charges a visible fee to rent every set-top box. If the set-top box is included in the price of a tier the cableCo can't charge an additional fee for the card (it would violate the clause that reads "No service fee shall be imposed on a subscriber for support of a subscriber-provided device that is not assessed on subscriber use of an operator-provided device.") Since Comcast bundles the (first) box with their tiers they must apply a discount from the tier price for a card rather than applying a unique fee for the card.
Here's the pertinent section of the FCC orders that Comcast is violating for you:

( 1 ) CableCARD rental fees shall be priced uniformly throughout a
cable system
by such provider without regard to the intended use in
operator-supplied or consumer-owned equipment. No service fee shall be
imposed on a subscriber for support of a subscriber-provided device
that is not assessed on subscriber use of an operator-provided device.

Comcast DOES NOT bill a uniform price across their footprint for each card. For example, lpwcomp's sheet says that extra cards are $1.10 in a device. My sheet says it's $1.50. And that has nothing to do with what is actually billed, the pricing itself is not uniform. Same with the customer credits - some areas get $2.50 per card, some get $2.99. Some get nothing.

They are not complying with this pricing order, no ifs ands or buts. And it's even worse when you get down to the actual billing, which varies by area and by CSR.

Last edited by slowbiscuit : 05-31-2012 at 06:47 AM.
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Old 05-31-2012, 08:06 AM   #8471
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Originally Posted by slowbiscuit

Here's the pertinent section of the FCC orders that Comcast is violating for you:

( 1 ) CableCARD rental fees shall be priced uniformly throughout a
cable system by such provider without regard to the intended use in
operator-supplied or consumer-owned equipment. No service fee shall be
imposed on a subscriber for support of a subscriber-provided device
that is not assessed on subscriber use of an operator-provided device.

Comcast DOES NOT bill a uniform price across their footprint for each card. For example, lpwcomp's sheet says that extra cards are $1.10 in a device. My sheet says it's $1.50. And that has nothing to do with what is actually billed, the pricing itself is not uniform. Same with the customer credits - some areas get $2.50 per card, some get $2.99. Some get nothing.

They are not complying with this pricing order, no ifs ands or buts. And it's even worse when you get down to the actual billing, which varies by area and by CSR.
I'll point out that Comcast as a whole is not a cable system, they are a cable company. My cable system is maintained by Comcast of Burlington, which is a "local" entity, even though it's owned by Comcast.
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Old 05-31-2012, 08:08 AM   #8472
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How does the FCC define the term 'cable system'? Locally (e.g. franchise) or nationally? Seems that that's important here. I don't know the answer - but I agree that different Comcast localities have different pricing sheets.
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Old 05-31-2012, 08:21 AM   #8473
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Here's the pertinent section of the FCC orders that Comcast is violating for you:

( 1 ) CableCARD rental fees shall be priced uniformly throughout a
cable system
by such provider without regard to the intended use in
operator-supplied or consumer-owned equipment. No service fee shall be
imposed on a subscriber for support of a subscriber-provided device
that is not assessed on subscriber use of an operator-provided device.
I hate to be the one to rain on your parade, but that paragraph is subject to interpretation. "cable system" may refer to the local system rather than than Comcast as a whole. However, they are inconsistent in the application of the charge even within a locality. My main points were that pdhenry's contention that the "additional outlet Fee" was for the CableCARD is bogus and that the "additional outlet fee" is unjustified.

The last sentence of the FCC order is ... interesting. It could be argued that an "operator-provided device" is a DTA, particularly if they start encrypting everything.
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Old 05-31-2012, 10:01 AM   #8474
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Further illumination from the Comcast website (I have emphasized the last sentence so that pdhenry might actually :

Quote:
How much will I be charged to use a CableCARD?

The first CableCARD in a retail device (e.g., TiVo devices or CableCARD equipped televisions) is free to Comcast customers. If a second CableCARD is needed for the same device (i.e., TiVo Series 3 boxes), the cost is $1.50 per month for the additional card. Again, this ONLY applies to a second CableCARD in the same device.
Notice that there is no mention of an a/o fee.

Then there's this:

Quote:
Will I receive an equipment credit if I bring my own CableCARD compatible retail device?

If you own a CableCARD device (e.g., TiVO or CableCARD equipped television) with an activated CableCARD installed and are subscribing to a Comcast video service that includes equipment as a part of the service, Comcast will begin issuing a monthly Customer Owned Equipment credit to your account.
What this says to me is that the credit only applies if you are using your own equipment in lieu of a Comcast box included in your package. IOW, you should only get this credit if you are not using the included STB. And only 1. By the same token however, even though Comcast calls it a "service", there's no way an a/o actually does meet the definition of a service.
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Old 05-31-2012, 10:20 AM   #8475
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You are flat out wrong. The Comcast published fees for CableCARDs, at least here (Atlanta area), is as follows:



I don't think Comcast STBs use CableCARDs.

The "Additional Digital Outlet Fee" may or may not be a violation of FCC regulations. What it most certainly is not is a CableCARD fee.
My Cisco RNG 100 STB has an M-Card inserted, and a cover over it that is screwed down:

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Old 05-31-2012, 11:26 AM   #8476
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Regardless of how we interpret the FCC rules, the bottom line is that they aren't going to do anything if people don't file complaints about this A/O nonsense. If then. I've done my part and Comcast responded to the FCC saying that they are justified because they charge the same for STBs. I never heard anything from the FCC in response, nor do I expect to.

YMMV.
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Old 05-31-2012, 11:58 AM   #8477
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Regardless of how we interpret the FCC rules, the bottom line is that they aren't going to do anything if people don't file complaints about this A/O nonsense. If then. I've done my part and Comcast responded to the FCC saying that they are justified because they charge the same for STBs. I never heard anything from the FCC in response, nor do I expect to.
Ultimately the solution to unreasonable rates and charges is to "vote with your feet" as they say. The cable companies will eventually pay attention if enough people just say no by canceling their service. The industry's preferred solution to that is to lobby Congress (pay people off) to kill OTA, but maybe legislators will have enough integrity and common sense to resist such a blatant effort.
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Old 05-31-2012, 12:12 PM   #8478
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Of course I can't back up my claims on Comcast A/O pricing because I've always gotten a COE discount on the second outlet that makes my package cheaper than not having the additional outlet.

I think we can agree that Comcast billing is messed up, regardless of whether A/O fees are reasonable or insidious.
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Old 05-31-2012, 01:44 PM   #8479
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My Cisco RNG 100 STB has an M-Card inserted, and a cover over it that is screwed down:

Highslide JS
I stand corrected. I therefore modify my statement to say that not all Comcast STBs use CableCARDs.

Just went round and round with a CSR and her supervisor (need a card for the new TiVo). Both of them tried to tell me that the a/o fee was for the CableCARD and that the digital conversion was mandated by government. I leave to your imagination how I responded to both of those claims. At one point I got a bit of (accidental?) honesty from the supervisor when he stated it was an additional source of revenue. At this point, the supervisor is supposed to be looking at the website to see what it says and is "going to get back to me". I've yet to get a legitimate answer to the question "What additional service are you providing to justify the a/o charge?". It's my equipment and, unless I want to pay yet another fee, I am responsible for all of the inside wiring , which in my case includes all of the splits to the various wall jacks.
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Old 05-31-2012, 05:58 PM   #8480
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Just got off the phone with a Comcast Executive Care representative that gave me the party line. Very frustrating. FCC complaint filed, for whatever good that will do.
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Old 05-31-2012, 07:04 PM   #8481
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I stand corrected. I therefore modify my statement to say that not all Comcast STBs use CableCARDs.
Google 'separable security fcc'.

Previously deployed boxes can have embedded security but new boxes must have separable security (e.g., a cableCard).

http://customer.comcast.com/help-and...able-security/
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Old 05-31-2012, 07:44 PM   #8482
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I think this excerpt from the last pricing sheet I received from Comcast (Boston region) may help explain Comcast's rationale on the "digital additional outlet" pricing. Under the "Basic and Digital Ancillary Services" section this item appears:

Digital Additional Outlet Service Charge (per outlet)
  • With standard definition digital converter $9.95
  • With HD digital converter $9.95
  • With CableCARD $7.45 (footnote 14)
Footnote 14 says "Includes a customer-owned video equipment credit. An additional charge will apply for additional CableCARDs in the same device." (that charge is $1.50 here).

If the DAO service charge INCLUDES a digital converter then I am not being charged EXTRA to use my TiVo instead of Comcast's digital converter - I'm receiving a $2.50 per month customer-owned equipment credit when I use my TiVo in place of Comcast's box.

A somewhat older price sheet that I found went into a bit more detail regarding the DAO service charge; it referred to it as a "Charge for digital content on additional outlets." When I spoke with a Comcast rep who called me after I filed an FCC complaint regarding the DAO service charge the "digital content" line was used several times during their explanation of the charge.

As much as I detest the charge I think Comcast (in the Boston area) is carefully structuring their policy to comply with the letter of the FCC regulations. I do look forward to the day that TiVo starts to sell satellite boxes that can stream from an XL4 - I will say goodbye to the extra CableCARDs and DAO service charges.
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Old 06-01-2012, 06:28 AM   #8483
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Ultimately the solution to unreasonable rates and charges is to "vote with your feet" as they say. The cable companies will eventually pay attention if enough people just say no by canceling their service. The industry's preferred solution to that is to lobby Congress (pay people off) to kill OTA, but maybe legislators will have enough integrity and common sense to resist such a blatant effort.
Well, that would be great if I had another cableCo in town, but I don't. I can get crappy sat service and even crappier U-Verse service, neither of which work with my Tivos or my WMC setup. I love Comcast reliability, channel selection, and pic quality, but I hate their billing practices. So I will not vote with my feet because the alternatives (to me) are even worse.
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Old 06-01-2012, 12:37 PM   #8484
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Originally Posted by jadziedzic View Post
I think this excerpt from the last pricing sheet I received from Comcast (Boston region) may help explain Comcast's rationale on the "digital additional outlet" pricing. Under the "Basic and Digital Ancillary Services" section this item appears:

Digital Additional Outlet Service Charge (per outlet)
  • With standard definition digital converter $9.95
  • With HD digital converter $9.95
  • With CableCARD $7.45 (footnote 14)
Footnote 14 says "Includes a customer-owned video equipment credit. An additional charge will apply for additional CableCARDs in the same device." (that charge is $1.50 here).

If the DAO service charge INCLUDES a digital converter then I am not being charged EXTRA to use my TiVo instead of Comcast's digital converter - I'm receiving a $2.50 per month customer-owned equipment credit when I use my TiVo in place of Comcast's box.

A somewhat older price sheet that I found went into a bit more detail regarding the DAO service charge; it referred to it as a "Charge for digital content on additional outlets." When I spoke with a Comcast rep who called me after I filed an FCC complaint regarding the DAO service charge the "digital content" line was used several times during their explanation of the charge.

As much as I detest the charge I think Comcast (in the Boston area) is carefully structuring their policy to comply with the letter of the FCC regulations. I do look forward to the day that TiVo starts to sell satellite boxes that can stream from an XL4 - I will say goodbye to the extra CableCARDs and DAO service charges.
So the situation is that you can receive some of the digital channels at multiple locations using a free or low cost DTA but if you want to receive all of the channels to which you are entitled at multiple locations, you have to pay an additional fee. How does that jibe with the following from the FCC website


Quote:
Receive all “linear” channels (channels other than “on-demand”) in your subscription package. This includes premium channels and specialty channels. For some channels delivered using a technique called “switched digital video,” you may need a second device called a “tuning adapter.” This device is typically provided at no additional charge to CableCARD customers. FCC Rule 76.1205(b)(4). CableCARD-ready devices currently cannot receive your cable operator’s Video on Demand services.

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Last edited by lpwcomp : 06-02-2012 at 08:19 AM. Reason: correct "gibe" to "jibe"
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Old 06-01-2012, 01:17 PM   #8485
pdhenry
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There's nothing in the FCC rules requiring free additional outlets. If someone who requires equipment from Comcast to view programming has to pay more for more than one outlet, the only thing the FCC requires is that a TiVo owner will pay less for an additional outlet than someone who rents a box. Which they do.
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Old 06-01-2012, 01:49 PM   #8486
lpwcomp
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Quote:
Originally Posted by pdhenry View Post
There's nothing in the FCC rules requiring free additional outlets. If someone who requires equipment from Comcast to view programming has to pay more for more than one outlet, the only thing the FCC requires is that a TiVo owner will pay less for an additional outlet than someone who rents a box. Which they do.
Since you can get a portion of the digital channels at "additional outlets" using a free or low cost DTA, they are not charging for additional outlets - they are charging you to enable the reception of all of the channels to which your package entitles you at those outlets.
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Old 06-01-2012, 03:56 PM   #8487
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On any given individual concept, pdhenry/Comcast have a response to why it is ok, and not technically in violation of the FCC rules for Comcast to charge digital outlet fees for boxes that are not their own. However, when the entire picture is taken as a whole, it seems clear that the rules are NOT being followed.

Comcast
- Pay only for equipment you have: Comcast says you are not paying for equipment, but rather a digital outlet fee.

- Accurate information on the rental cost of a CableCARD from your provider: Comcast says the information is accurate, because they are not charging you for the CableCARD per se, but rather the digital outlet fee.

- Use your own set-top box without extra charge: Comcast says that you are not being charged "extra", because you are paying the same as other subscribers (or less if you get the credit).

- Self-install your CableCARD: This one seems to not be as much of an issue as it used to be.

- Receive the number of CableCARDs you request: Comcast says you can get as many as you want. They just reserve the right to charge you $8.95 or more for each one beyond the first one.

- Receive a multi-stream CableCARD unless you request otherwise: Also seemingly not much of an issue these days, but important for other reasons laid out below.

- Receive all “linear” channels in your subscription package: Comcast says that you can get them if you follow their rules. You also can get most of them through a DTA in SD, but not all of them, and not in HD.

- Get accurate information about services available to CableCARD subscribers: This is more of a catch-all, it seems. If you accept Comcast's premise that their rates are permissible, one might say that they follow this rule.

Take all of the above rights as a whole, however, and it is very clear that this is NOT how it was intended to work. De Facto, Comcast's policy is to charge a fee which is not close to the $2-4 rate suggested the usual rate on the FCC site, and call it something else. Although Comcast argues that the fee is for additional digital outlets, this premise is exceptionally tenuous for so many reasons:

- CableCARDs are something that are necessitated by the nexus of the digital transition and consumer rights. They are intended as a step forward, not backward, allowing people to access high definition programming with their own equipment without being compelled to pay for the cable company's equipment.

- Given that you are entitled to a Multi-stream card, you are entitled to MORE THAN ONE TUNER! The number of tuners that could be on that device could be at least 6 to my knowledge with an HDhomerun Prime 6 tuner model, at least 4 on a single CableCARD, as on the Tivo Premiere XL. In almost all cases, modern devices will have at least 2 tuners. This point is critical, as it means by definition that a "digital outlet" is NOT equivalent to a tuner (or even 2), and neither is it equivalent to televisions or other devices that are capable of viewing digital programming in your home. Therefore, there is only one other remaining possibility as to what a digital outlet IS...the number of devices a consumer has that are capable of receiving all linear digital programming from the cable provider, regardless of what the device does with it. In other words, consumers are being charged a per-device charge, regardless of whether that device is the cable company's device, and it is separate from any explicit charges delineated on the rate sheets as being actual CableCARD fees. This is outright deception. The fact that someone with their own equipment is charged LESS per digital outlet, due to the credit, DOES NOT CHANGE the fact that the consumer IS paying to use their own equipment on a per-device basis.

-The previous point is only underscored by the fact that television providers pay for the content on a per-household basis, not a per-screen/per-tuner/per-person, etc. basis. The cable company CANNOT tie this charge back to any legitimate cost on their own end without acknowledging explicitly that they are charging for their "hassle" and "support" of the cable card process in general, which is not something they are entitled to do. Is CableCARD a burden on the cable companies? Sure, but it was mandated. Can the cable companies charge for the CableCARDs they provide? Yes, but they must charge uniformly, with proper disclosures, and by acknowledging what they are charging for!

- Unlike the analog realm, where the digital transition was mandated by the government to reclaim spectrum, the digital cable transition is all about the cable companies' self-interest in maximizing the number and quality of channels provided and reducing their costs. Once again, they could cash-in even more if the FCC had not mandated CableCARDs at all, but they did. And this was done for the CONSUMER'S benefit. By charging consumers to use their own equipment, as they could do to gain additional "analog outlets", before the analog channels went away, they are doing the exact opposite, by making a cash-grab that has no correlation to any services provided by the cable company (see above, unless they admit it is because they find CableCARDs annoying). To the extent that you want to get even as many channels as the DTAs are capable of providing, you HAVE to pay the digital outlet fee (on anything beyond the first outlet), which amounts to the consumer paying extra for utilizing the capabilities of the device that THEY purchased.

Obviously, this is a rant, and obviously I am not hitting every point, but I just cannot see how anyone can defend this practice as a whole.
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Old 06-01-2012, 04:16 PM   #8488
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tl; dr.

But all I'm doing is observing that the cost of renting multiple cablecards (for multiple TVs) is comparable, and favorable, to the only other method of receiving HD digital content from comcast at multiple TVs, which is by renting two or more boxes. When taken in that context, I didn't consider it unreasonable.

I didn't intend to imply any defense of Comcast charging for multiple cable boxes in a household, but there you are - you're renting multiple boxes. I don't have a strong opinion about their ability to prevent you from viewing most of your channels without needing to rent equipment from Comcast, but I'll observe that DirecTV and Dish also seem to have significant ber-box charges built into their rates, at least when I was looking into dumping Comcast a month or so ago.

I think I've been clear enough that, due what I think is CSRs' inabilty to properly bill my account as Comcast would intend, I actually pay less for two outlets than I would for one - I get $2.50 in Customer-owned equipment discounts for each of two TiVos but I only pay $1.50 for the second setup. This persists even though the Limited Basic tier I'm on doesn't include any "free" Comcast equipment baked into the rate. So maybe I ddon't have enough of a dog in this hunt to have the spitting passion y'all seem to have about the matter.

When I decided Comcast was getting too much of my money I looked into dropping them and going OTA with Cable Internet only. Thanks to those wonderful skilled CSRs and their power over the billing system, I now have Limited Basic plus internet for less than the cost of internet without Cable TV (because they charge more for unbundled Internet access, these two options normally price within about 3 or 4 dollars of each other anyway).
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Old 06-01-2012, 07:25 PM   #8489
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IMNSHO, Comcast is in violation of FCC regulations one way or another. Either the $7.45 net a month is a CableCARD rental fee and the quoted fee of $0 is a lie OR they are charging an additional fee to enable access to all of the channels in your package.
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Old 06-01-2012, 08:12 PM   #8490
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But isn't the additional fee rule in regards to a cable card user vs. a Comcast box user? You don't see it that way, but I read it to mean that Comcast can't charge you more than they charge someone who uses a Comcast set-top box.

E.g., "No service fee shall be imposed on a subscriber for support of a subscriber-provided device that is not assessed on subscriber use of an operator-provided device."
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