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I spent some time this morning going over the comments posted by the CRTC regarding "Review of the regulatory frameworks for broadcasting distribution undertakings and discretionary programming services". I haven't gone into all of the postings, but did hit most of the big cable companies and comments from individuals. Here is my summary of comments: Regarding set-top-boxes: Several people (21 by my count) wrote in regarding their dissatisfaction with the requirement for set top boxes, and their suggestions on changes that the CRTC can make to improve the situation. Most everyone agreed with my position that basic cable be delivered unencrypted, and pay cable be delivered in a way that allows 3rd party devices to watch, record, and play back the content. The big cable companies: In general, the big cable and satellite companies are asking for the following: - Reduction or elimination of regulation on their market
- The ability to carry foreign (ie US) channels like ESPN, Comedy Central, etc.
- The right to insert their own commercials into those foreign channels
- Reduction of Canadian content requirements
- Elimination of linkage rules (ie you subscribe to only the channels you want, not bundles)
- Acceptance of the notion that programming can be delivered in many ways, including Internet distribution (and fear that over-regulation in Canada will cause more people to get their content over the internet from foreign markets.)
Community Channels Besides set-top-box arguments, the other major grassroots issue seems to be around community television and the requirement to carry that programming. Several individuals and groups wrote in on this issue, especially those in Quebec, to reinforce that community television should be kept as a requirement. The knee-slapper award: I'm not a Rogers cable customer, but I think that most of their customers will appreciate the humour in Rogers' recommendation that the CRTC "Refrain from introducing new customer service standards or a new body to oversee them, which would represent an inefficient duplication of efforts and resources given the existence of longstanding and effective cable industry customer service standards." Now I'm not saying that I think that the CRTC needs to regulate this, but I think the notion that Rogers thinks they are running a top-notch customer service organization is laughable. My position: After reading several of the submissions, I'd say that I'm generally in agreement with the overall call for less regulation. I know, that seems odd given that I've been pushing for more regulation in the area of content access. Perhaps a better way to state my position is this; that overall lower regulation on the content provided is warranted and that consumer choice will dictate the market, but that certain regulations should be put in place to prevent distributors from colluding on consumer-unfriendly practices such as price-fixing, device lock-in, and negative billing. Give the cable companies the freedom they desire, but in trade ask (ie require) that they promise to do so in a way that does not hurt consumers.
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Thanks to my fellow Canadian and MVP Jason Tsang for passing along a notice from the CRTC that they've extended the timelines for the upcoming hearing. This means that you now have until October 19 to submit your comments to the CRTC regarding the future of cable and satellite distribution here in Canada. I have templates and links set up at dropthebox.ca which you can use to get started. Here are the new dates: - October 19, 2007 - Submit comments to the broadcasting notice (ie if you have anything to say about the regulatory framework or anything that they've talked about in the broadcast notice itself, do it by October 9).
- November 16, 2007 - Submit replies to the comments (ie if you would like to dispute anything that anyone sent in on October 9, do it by November 5)
- February 4, 2008 - Show up in person if you so wish to address the commission.
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I've had some requests for sample content to make it easier for people to submit letters to the CRTC. While I'd prefer that you use your own words so that the CRTC gets multiple points of view, here is some sample text that you can use to get started. Remember, letters are due in to the CRTC by October 9. I'd like to express my support for Peter Near's proposal to open up the broadcast of digital high definition over Canada's cable networks. I have always valued choice in the products that I purchase, and there is no technical reason why the cable networks should be limiting what I can connect to my digital cable. Specifically, I would like to request that the CRTC consider the following at the upcoming hearing: - That HDTV basic cable broadcasts which are available unencrypted over the air be delivered to my home by the cable companies in their original unencrypted form. This will allow me to connect my TV directly to the cable so that it works with my TV's built-in digital tuner today.
- That premium cable broadcasts be delivered to my home by the cable companies in a way that allows me to choose the device that I use to watch this premium content. This will allow me to choose from multiple devices available on the market that are compatible with premium digital cable. The technology for this already exists in the United States, it's not significantly different from what is already in place here in Canada, and now is the perfect time for the Canadian cable companies to get involved in version 2 of the cablecard technology.
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So, I've written quite a bit about cablecard in Canada over the last few months. I've written a very beurocratic sounding letter to the CRTC, I've written a very newsy sounding press release, and I've written a web page with just the facts and instructions on how to get involved. What I haven't really gotten to yet is just a candid discussion of the issue. So here it is, the "sitting down for a beer with Pete to get his thoughts on Cablecard" post. I'll start with an analogy. Do you remember when VCRs were all the rage? You could go to any electronics store and choose from about fifty different models of VCRs - the four head VCR, the HQ VCR, the black one and the silver one with cool rotating tape graphics. And then came the innovation stage, where they came up with VCR+ to make it easier to record scheduled shows, downloaded guide data encoded in PBS signals, and even the one that set its own clock. The point is this - you could choose your own quality from cheap garbage to over-priced nirvana and manufacturers constantly challenged each other to come up with new features. It was low-tech compared to today's standards, but that was innovation. Wondering where the analogy comes in? Well imagine that someone from the cable company went to the store for you, said "I'll take the cheapest one with the worst features" and then forced you to buy that (for a slight markup of course). Wouldn't that make you mad? Well in a nutshell, that's the problem right now in Canada - we should have choices, we should have competition creating innovation, we should have products that don't suck. Instead, the cable companies are telling us "you can have any colour you want so long as it's black." I suspect that most people put up with it because they don't really know any better. If you want to get high-def, then you get the high-def box from the satellite or cable company. And it seems pretty cool when you see that high-def picture for the first time and the first time you pause live TV, but then you start to notice that it doesn't always work right or you have to spend hours with your parents because they can't figure out the awful interface. It's at that point that most people settle with what they've got thinking that it's really the only option. But it's not the only option. In the United States, they are using the exact same technologies as us to distribute cable and they have choice (and in my opinion, some pretty cool choices too). The difference is that in 1996, the FCC recognized the inherent problem of tying television service to a proprietary set top box and mandated that the cable companies work with third-parties who develop devices that would use their high-definition digital signals. In a compromise that would allow the cable companies to control at least the security aspect of their networks, the cable companies and the FCC eventually settled on a technology called "cablecard". While any device could then work with the digital cable, the cable companies still encrypt or "scramble" the signal and that signal can only be decrypted when you get a special key from the cable company. That key is called a cablecard, and it is only given out to work with hardware that has been tested and proven to maintain the security that the cable company requires. And here we are... So has cablecard been a resounding success in the United States? I would say that no it has not. While the concept is sound, the technology itself has limitations that make it difficult to implement. Additionally, the cable companies themselves have appeared to be reluctant to extend any reasonable amount of goodwill in getting their end of the compromise, the security card, deployed and running in other people's homes. But like I said the concept is sound and with must-have gadgets like the Tivo Series 3 driving demand things are getting better. Am I suggesting that Canada plunge in and adopt Cablecard right away? Actually no, I have specifically asked that the CRTC direct the cable and satellite companies to investigate existing technologies and report back on the best way to meet the goal of allowing third party devices to connect to their networks. In reality, this will take several years and I think that it's perfect timing for the Canadian cable companies to jump in and participate in the latter stages of cablecard version 2, which has the potential to solve many of the issues that were discovered by the early v1 adopters in the United States. But the real win for me in the short term is the other side of my proposal to simply transmit basic cable channels (ie the high definition equivalents of the big broadcast networks) without encryption whatsoever, which alleviates the need for cablecard for the most common cable channels. If I can get an unencrypted signal in high definition using an antenna, then what possible reason would the companies that own the rights to those channels possibly have for encrypting them? The content is already available and will continue to be available in its raw form over the air, so the arguments surrounding piracy of that content via the cable networks are moot. For basic cable, there is absolutely no reason why it can't be sent over the cable in a way that can be displayed on your HDTV today. The technology is called QAM, it's what everyone is using in North America, and if they'd just stop scrambling/encrypting the signals the all of the thousands of TVs with QAM tuners would simply work. Just plug in the cable to the TV, turn it on, and watch TV like you've always done. No set top box, no cablecard, no problems. Why not go all the way and just stop encrypting all of the channels, including the pay channels? While that would certainly make this whole problem much simpler to resolve technically, I don't believe that's a reasonable thing for us to expect. The pay channels provide us content that isn't available anywhere else, and it is unique content that the owners need to protect. The producers of "Gray's Anatomy" have already made a choice to use the public airwaves to broadcast to as many people as possible, make their money on ad revenue, and accept that their content is available without encryption. However, the producers of "The Sopranos" have never made that choice and indeed have a business model that lives and dies by the number of people who are paying a fee directly to HBO through the cable companies. I believe that HBO has a right to protect that content and set the rules by which it is consumed. If you don't like it, don't buy it. I've now laid out my case for what I believe is reasonable and right: - We as consumers should have choice in our consumer electronics and not have it dictated to us by opportunistic cable companies
- We as a society need to continue to foster competition and creativity amongst the makers of these devices
- There is no reason other than opportunism that cable companies would need to encrypt content that is freely available over the air
- We need to respect the need for pay TV content producers to preserve their business model via some form of encryption, namely cablecard or it's future iterations
That's all well and good that I think that, now what am I going to do about it? Well call me old fashioned, but I really do believe in democracy. The government isn't a big faceless organization, it's a bunch of guys like you and me who happened to be chosen to represent the will of the people. They put their pants on one leg at a time, they go to work during the day and they come home in the evening to spend some time with the family and relax in front of the TV. In essence, the people who can make my vision a reality are living pretty much the same life as me. My goal is to connect with those people, let them know that there are options out there, and help them to fight on our behalf against the companies who are doing exactly what they're supposed to - maximizing the profits for their shareholders. There are no bad guys here, just a bunch of people trying to do their jobs the best that they can. If I can help my team (ie my representatives in government) by providing them with good information and reasonable down-to-earth arguments then I really do believe that we can resolve this little policy oversight.
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Milton, Ontario - September 24, 2007 - The cable box sitting on top of your television may not be long for this world if Peter Near has anything to say about it. The United States clamped down on cable companies in 1996 and required them to do away with mandatory set-top boxes. This resulted in a wave of new HDTVs, PVRs, and other gadgets that connect directly to digital cable systems south of the border. This is not the case however in Canada, where television lovers must still buy or rent a digital cable terminal from their provider in order to receive a high-definition picture. The latest crop of digital-cable savvy electronics sport an impressive array of features including the ability to record high-definition TV, transfer recorded TV to an iPod, browse family photos and videos on the big-screen, and rent movies over the internet. As to their availability here in Canada - Microsoft sells their media center products with HD digital cable support disabled in Canada, and Tivo's HD offerings aren't available for sale in this country at all. The Canadian Radio-Television and Telephone Commission (CRTC) is responsible for regulating the cable industry, and has announced that they will be holding hearings in January to review the regulations governing cable distribution in this country. Mr. Near has written to the CRTC formally requesting that they review the issue of set-top-boxes and consider adopting regulations similar to those in the United States which require cable companies to work with third-party consumer electronics. Mr. Near commented, "I can understand why the cable companies wouldn't embrace this concept - if you can only use their box, then it becomes easier to lock you in to extra paid services like video on demand. But without competition there is no incentive to innovate. What we're left with here in Canada are mandatory cable boxes that funnel profits into one spot while failing to be innovative, failing to provide a smooth user experience, and failing to provide us with any real choice. As someone with a passion for high-tech, frankly I'm disappointed." The CRTC has requested that comments regarding this matter be sent in by October 9, 2007 and will be considered at the upcoming hearing. A website has been set up at www.dropthebox.ca which provides additional information, including simple instructions and a template that other concerned citizens can use to submit comments to the CRTC. The website also encourages consumers to contact their local member of parliament to request their support for this initiative. Speaking to the topic of timeframes, Mr. Near stated "There are really two separate types of HDTV signals that we're talking about here - the big broadcast networks that are part of basic cable, and the pay channels that you can only get with premium cable. My proposal requests that just like with basic analog cable, the cable companies send along the broadcast network channels without scrambling them. These channels can be unlocked tomorrow by the cable companies literally with the flip of a switch and most HDTVs will immediately be able to pick them up. The latter category of pay channels will require more work, and I expect it would take several years for Canadian cable companies to implement the technology to encrypt and decrypt these channels without the use of a set-top-box." In the meantime, he offers this suggestion "Be aware of what's already out there. First, never feel that you have to pay your cable company any extra fees to receive the most popular high-definition channels. By law, basic cable includes your local broadcast stations like CBC, CTV and Global TV in full high definition even though they might not advertise that fact. Second, it may be time to reconsider using an antenna. The US and Canadian broadcast networks have all been told that they need to switch to digital antennas, which means that the airwaves are full of completely free, crystal-clear high definition television signals." It remains to be seen if the CRTC will consider regulation of set-top boxes, but the movement has already gathered significant interest on blogs and technical web forums. For the most part, Canadians aren't even aware that there is an alternative to the set top box but perhaps that is about to change. ### For further information: Peter Near, pnear@dropthebox.ca
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With two weeks to go for people to give comments to the CRTC on the future of television broadcasting in Canada, I've launched a new website, dropthebox.ca. This website is a simple attempt to inform Canadians of the issue, and provide an easy way for them to write their own letters to the CRTC expressing their opinion on the subject. So to all of you who have asked me in the past "what can I do to help?" you now have your answer. Visit dropthebox.ca, click on "Write Your Own Letter" and send along your comments to the CRTC. Tell your friends about it, and send an email to your MP. The goal here is to get noticed, and if there's more than just me writing in to the CRTC it is more likely to get noticed. Press releases will be going out today to media outlets.
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I had a cascade of recording failures tonight as MCE rushed to find a channel where it could successfully record "Kid Nation". With each channel it tried, I got a message that it could not be recorded due to restrictions set by the broadcaster. The local broadcaster is CH television in Hamilton, Ontario and the cable carrier is Cogeco. Here in Canada cable operators are forced to do what is called "simsubbing". Basically this means that if any US channels are carrying the same show as a local Canadian broadcaster that the cable company is forced to broadcast the local broadcast on all channels. Long story short - every channel that was showing "Kid Nation" at the time was showing the CH feed. Were you able to record Kid Nation tonight? If yes or no, please let me know where you live, what channel you watched it on, and what cable provider you are using. I have some angry letters to write and would appreciate having your data to back up what I've experienced.
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Many thanks to everyone who contributed edits, suggestions, and comments to the CRTC submission. I have submitted the letter below to the CRTC today. Mr. Robert A. Morin
Secretary General, CRTC
Ottawa, Ontario
K1A ON2 Dear Mr Morin: RE: Broadcasting Notice of Public Hearing CRTC 2007-10, Review of the regulatory frameworks for broadcasting distribution undertakings and discretionary programming services. 1 Per Broadcasting Notice of Public Hearing CRTC 2007-10, I would like to propose an issue for consideration at the public hearing which is related to distribution and linkage. At issue is the delivery of digital signals to consumers, and the additional burden that has been placed on consumers by the technology and business choices of BDUs. 2 Traditionally, using analog technology, consumers had a choice in many aspects of how they accessed and interacted with the content being delivered to them by their service provider. This included the ability to directly connect a cable to a television and browse channels in a simple manner, the ability to connect a VCR of one's choice to record and play back unrestricted content, and the ability to use a DVR such as Tivo to access advanced interactive guide and PVR functionality. 3 However with a shift to digital technology in the Canadian marketplace BDUs have removed, some would argue opportunistically, much of this consumer choice. In order to consume digital content subscribers must pay additional fees to BDUs and connect set-top-boxes to their televisions which limit interactivity to one provider. The majority of digital content delivered to the home is encrypted and not available to be used outside of the BDU's closed set-top-box environment. This practice limits consumer choice and competitive opportunities in an increasingly convergent marketplace that is dominated by large corporations. 4 Technology exists today that allows BDUs to offer consumers choices beyond their limited set-top-box offerings without compromising the security of their network or content , due largely to a 1996 decision by the Federal Communications Commission to "...assure the commercial availability to consumers of multichannel video programming and other services offered over multichannel video programming systems, of converter boxes, interactive communications equipment, and other equipment used by consumers to access multichannel video programming and other services offered over multichannel video programming systems, from manufacturers, retailers, and other vendors not affiliated with any multichannel video programming distributor." (Telecommunications Act of 1996, Section 629). 5 I believe that it is possible for the CRTC to enforce a similar requirement on Canadian BDUs which would fulfill the sentiment of this statement in Public Notice CRTC 2006-23, "...the Commission has sought to achieve the following objectives: encourage the transition to digital and eventually high definition distribution; permit BDUs to take advantage of the flexibility of digital distribution technology, to the benefit of consumers..." 6 If third-party vendors are allowed to participate in the Canadian market, the potential for creative and fulfilling user experiences through convergence abound. However if content is locked into proprietary and quite frankly unexceptional set-top-boxes then I fear that Canada will be left behind. This would certainly not be to the benefit of consumers in this country. 7 With that in mind, I propose the following for discussion: a. Basic cable services including priority over-the-air (OTA) digital signals and other services that the Commission has mandated for basic carriage should be delivered to consumers with security features that do not exceed those found in the original broadcast. Ie. Content that is available OTA without encryption should be freely available to basic subscribers without encryption. This would allow the majority of HDTVs on the market today with QAM tuners to simply connect the digital cable to the television and consume basic cable content. b. Pay and specialty services should be available to subscribers through commercially available equipment from manufacturers, retailers, and other vendors not affiliated with any multichannel video programming distributor. BDUs should evaluate the existing technologies implemented in other jurisdictions (ie CableCards, Satellite CAMs) and report back to the CRTC on how to best provide a separable security access device which could be used by third-party devices to access digital television content in Canada. 8 I strongly believe that consumer choice in service delivery and content interaction will be a benefit to all Canadians. The devices that already exist which can take advantage of this type of technology are light years ahead of the STBs available in Canada in functionality and design creativity. One can only imagine the possibilities that the near future brings if the Commission takes steps now to ensure that competition is alive and well in this space. Sincerely, Peter Near
(my home address omitted in the blog post) Email : peter@thenears.com *** END OF DOCUMENT ***
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Believe it or not, I've never really gotten into the whole MP3 player thing. I've gotten a few as gifts, and promptly regifted them to someone else who could get some use out of it. However after seeing a couple of friends pull out the iPod with a cordless speaker dock while camping this summer I made the decision that I was going to get on the bandwagon finally. I was waiting for the iPod Touch announcement yesterday, and was giddy when I saw it released. It's the perfect device for me - I need something with a big screen since to date my primary use for portable media has been video, and secondarily I want to be able to store a bunch of music on it to use around the home and at the gym. And because it's an iPod, there will be plenty of accessories to come in the market. 
But then I started looking at the realities of it, and while it's an awesome form factor for video that puny 16GB of memory is just not enough. If I hop on an airplane, I need to be able to store enough recorded TV or movies to keep me entertained for the flight out, the flight back, and the inevitable delay at the airport. I just don't think that 16GB will cut it unfortunately. So I'm back to the other options: - Zune 2 which looks like it'll fit my functional needs but I can't help but thinking it's an also-ran. I know that there are going to be pet peeves that MS just won't fix well, because that's what they do. And finding a nice speaker dock for Zune to take camping is going to be near impossible.
- One of the Archos devices, although they look to be overkill for my needs and will have even less accessory support than the Zune.
Sigh... I had such high hopes for the iPod touch.
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I'm preparing to make a submission to the CRTC in response to their request for issues to be discussed in a January 2008 hearing on "Review of the regulatory frameworks for broadcasting distribution undertakings and discretionary programming services". I'd appreciate review and comment from the community on what I've written below - I tried to do my research but I'm relatively new to mining the depths of the FCC and the CRTC. If anything in here is misinformed, incorrect, or just plain wrong I'd rather hear it from all of you first! ;-) ------------------------------------------- Per Broadcasting Notice of Public Hearing CRTC 2007-10, I would like to propose an issue for consideration at the public hearing which is related to distribution and linkage. At issue is the delivery of digital signals to consumers, and the additional burden that has been placed on consumers by the technology and business choices of BDUs. Traditionally, using analog technology, consumers had a choice in many aspects of how they accessed and interacted with the content being delivered to them by their service provider. This included the ability to directly connect a cable to a television and browse channels in a simple manner, the ability to connect a VCR of one's choice to record and play back unrestricted content, and the ability to use a DVR such as Tivo to access advanced interactive guide and PVR functionality. However with a shift to digital technology in the Canadian marketplace BDUs have removed, some would argue opportunistically, much of this consumer choice. In order to consume digital content, subscribers must pay additional fees to BDUs and connect set-top-boxes to their televisions which limit interactivity to one provider. The majority of digital content delivered to the home is encrypted and not available to be used outside of the BDU's set-top-box environment. This practice limits consumer choice and competitive opportunities in an increasingly convergent marketplace that is dominated by large corporations. Technology exists today that would allow BDUs to offer consumers choice without compromising the security of their network or content , due largely to a 1996 decision by the FCC to "...assure the commercial availability to consumers of multichannel video programming and other services offered over multichannel video programming systems, of converter boxes, interactive communications equipment, and other equipment used by consumers to access multichannel video programming and other services offered over multichannel video programming systems, from manufacturers, retailers, and other vendors not affiliated with any multichannel video programming distributor." (Telecommunications Act of 1996, Section 629) I believe that it is possible for the CRTC to enforce a similar requirement on Canadian BDUs which would fulfill the sentiment of this statement in Public Notice CRTC 2006-23, "...the Commission has sought to achieve the following objectives: encourage the transition to digital and eventually high definition distribution; permit BDUs to take advantage of the flexibility of digital distribution technology, to the benefit of consumers..." If third-party vendors are allowed to participate in the Canadian market, the potential for creative and fulfilling user experiences through convergence abound. However if content is locked into proprietary and quite frankly unexceptional set-top-boxes then I fear that Canada will be left behind. This would certainly not be to the benefit of consumers in this country. With that in mind, I propose the following for discussion: · Basic cable services including priority over-the-air (OTA) HD signals and other services that the Commission has mandated for basic carriage should be delivered to consumers with security features that do not exceed those found in the original broadcast. Ie. Content that is available OTA without encryption should be freely available to basic subscribers without encryption. This would allow the majority of HDTVs on the market today with QAM tuners to simply connect the digital cable to the television and consume basic cable content. · Pay and specialty services should be available to subscribers through commercially available equipment from manufacturers, retailers, and other vendors not affiliated with any multichannel video programming distributor. BDUs should evaluate the technologies currently in place in other jurisdictions (ie CableCards, Satellite CAMs) and report back to the CRTC on how to best provide a separable security access device which could be used by third-party devices to access digital television content in Canada. I strongly believe that consumer choice in service delivery and content interaction will be a benefit to all Canadians. The devices that already exist which can take advantage of this type of technology are light years ahead of the STBs available in Canada in functionality and design creativity, one can only imagine the possibilities that the near future brings if the Commission takes steps now to ensure that competition is alive and well in this space. Sincerely, Peter Near
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You'll notice over the next several days some activity in this space. I would expect that MCE users who have read my blog in the past have been frustrated by a couple of things: - the increasingly low ratio of family talk versus technical talk
- all of the broken images and links that happened from the last server move
So here we are, I'm going to pull all of the technical stuff from my personal blog, clean up all of the broken items, and resume technical blogging here at TGB. Thanks to TGB for providing this space, I hope it will prove to be a much more permanent and more focused home for my technical ramblings. 
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This weekend we got very frustrated by the XBox 360 and DVD playback. Once the 360 warms up, it refuses to read my DVD-R collection (which is significant, since I don't want the kids to ruin their original discs). So we get 15 minutes into a movie and all of a sudden the disc becomes unreadable. Frustrating. So we decided to get a new DVD player that would play all of our discs. I trotted off to the local Real Canadian Superstore to spend some of my cache of PC points on a new gadget (feels better when it's funny-money) and looked at the selection. Turns out that the cost of an upconverting name-brand DVD player isn't that much different from the HD-DVD kit for the 360. As an external drive, I figured it wasn't going to be affected by the same heat issues as the 360 itself, so I picked it up. As to the primary need, something that will play my DVD-Rs reliably, it fit the bill. As to the secondary cool factor, the ability to play HD-DVDs, of course that works as well but I was fairly unimpressed with the picture quality of the included King Kong disc versus a regular DVD. I might rent a few more HD-DVDs just to try them out, but until this format war is over I don't think I'll be adding anything to my collection permanently
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The CRTC today announced changes to over the air broadcasting in Canada. I for one am happy to see these changes and look forward to reading into some of the details once I get some time. Analog shutdown in the US has been a real catalyst for over the air HDTV, and I expect it to do the same here. While I get fantastic over-the-air HDTV coverage here in Toronto the same is not true in other communities across Canada. Notably, the Commission has decided to: - remove restrictions on advertising time limits after gradually increasing the amount of advertising allowed;
- establish August 31, 2011, as the date by which television licensees will only broadcast digital signals;
- require English- and French-language broadcasters to caption for the hearing impaired 100 per cent of their programs over the 18-hour broadcast day, with the exception of advertising and promotions; and
- deny a subscriber fee for the carriage of local conventional television stations on cable and satellite as its necessity has not been demonstrated.
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