# FCC's Online media complaint form against Comcast



## buscuitboy (Aug 8, 2005)

I am getting tired of the shenanigans & BS side charges Comcast imposes for additional cable cards for my TiVo. What should be just a straight $1.50 winds up turning into a $10 "outlet fee" and then a $2.50 equipment 'credit' for EACH card. Therefore, the true cost for each cable card is $7.45.

In the end, its bringing the monthly cost of a Tivo (without PLS) up to about the same cost of their crappy DVRs. Maybe its why they are taking advantage of this loophole; have customers try to pay them more instead of giving money to TiVo, but still a loophole and hopefully can be fixed.

I have gone ahead with this, but if anyone is interested in filing an FCC complaint against Comcast, here is a link to the online form to do it.

https://esupport.fcc.gov/ccmsforms/form2000.action?form_type=2000E

Who knows if it will ever truly do anything (probably not), but I have copy/pasted my full complaint into a word document that is saved on my PC and plan to just file this about once per week. Hell, more if possible and time permits


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## slowbiscuit (Sep 19, 2006)

You mean $2.50 equip credit, not fee. Your net cost is correct.

Everyone on Comcast getting A/O's for cards should file complaints with the FCC.


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## buscuitboy (Aug 8, 2005)

Sorry. yea, $2.50 equipment 'credit'. Sorry about that & fixed it above as needed.


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## nrc (Nov 17, 1999)

Yes, if they're not charging that same fee for their own boxes then it's absolutely illegal.


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## generaltso (Nov 4, 2003)

My understanding is that they do charge the same additional outlet fee for their own boxes. Is that not the case?


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## pdhenry (Feb 28, 2005)

Those who are complaining are comparing the fee for a TiVo in an additional outlet to the free SD DTA (or a couple of dollars) that can be obtained for that same outlet.

A TiVo at any outlet will cost you ~$2.50 less than having a full-featured (e.g., HD, PPV) Comcast-owned set-top box at that outlet.

If I'm wrong I'm sure they will clarify.


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## generaltso (Nov 4, 2003)

pdhenry said:


> A TiVo at any outlet will cost you ~$2.50 less than having a full-featured (e.g., HD, PPV) set-top box at that outlet.
> 
> If I'm wrong I'm sure they will clarify.


That's my understanding as well. Although I hate the fact that additional outlet fees exist at all, I don't think it's a violation of the FCC rules.


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## lpwcomp (May 6, 2002)

generaltso said:


> That's my understanding as well. Although I hate the fact that additional outlet fees exist at all, I don't think it's a violation of the FCC rules.


I cannot believe anyone could read bullets 2, 7 & 8 here and still think that Comcast is in compliance. HD doesn't change the rules.


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## generaltso (Nov 4, 2003)

lpwcomp said:


> I cannot believe anyone could read bullets 2, 7 & 8 here and still think that Comcast is in compliance. HD doesn't change the rules.


Are you saying that they're violating one of those bullet points by charging the same additional outlet fee for a cable card as they do for a cable box? I'm not seeing it.


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## nrc (Nov 17, 1999)

Right, they may have other issues but if they're charging that same outlet fee for their own boxes *in addition to a charge for the box itself* then there's nothing wrong with that.


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## lpwcomp (May 6, 2002)

generaltso said:


> Are you saying that they're violating one of those bullet points by charging the same additional outlet fee for a cable card as they do for a cable box? I'm not seeing it.


Their published fee for the first CableCARD in a device is $0/mo. Except for a $1.50/mo for the second card _*in the same device,*_ no other fees are associated with CableCARDs. You can get some of the digital channels with a free or $1.99/mo DTA. Reread the below where I have extracted the relevant portions from the FCC website. Pay particular attention to the sentence in *bold type*. If you can still honestly state that Comcast is in compliance,you really need to give a full explanation because, IMHO, it defies logic.

From the FCC CableCARD: Know Your Rights website:



> Accurate information on the rental cost of a CableCARD from your provider. Your operator must list the cost of a CableCARD rental on its website or billing inserts and on its annual rate notice...
> 
> *Receive all linear channels (channels other than on-demand) in your subscription package.*
> 
> Get accurate information about services available to CableCARD subscribers.


Comcast is perfectly within their rights to charge you more for their equipment that can receive channels beyond the capabilities of the DTA. However, other than the actual fee for the CableCARD(s), they _*cannot*_ charge you to enable that capability on CableCARD using equipment that you own.


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## generaltso (Nov 4, 2003)

Your quote says that Comcast is required to provide all linear channels to cable card customers. They do. Is there a linear channel that's available on a cable box that they won't give you with a cable card? Your quote in bold has nothing to do with pricing. It doesn't say anything about additional outlet fees. Comcast charges an additional outlet fee for the second and any subsequent outlets where you have a cable card OR a cable box. What specifically does this violate? Are you saying that they should not be allowed to charge an additional outlet fee for a cable card on a second outlet even though they charge that fee for a second outlet that has a cable box?

How many cable outlets are you using in your house and what equipment are you using on each outlet? It's quite possible that you're being charged incorrectly, but I can't say if that's the case without knowing what you have.


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## riffjim4069 (Oct 8, 2007)

I filed two complaints regarding this issues...i.e., modest increase in 2nd Cablecard fee while getting hammered with a huge decrease in customer-owned equipment that equates to an almost 50% increase in the total cost of the Cablecard. Seriously, additional Cablecard devices rack-up an additional $7.45 in charges for the Cablecard in the form of the "Additional Digital Outlet" fee, which is almost the cost of renting an HD receiver...and that comes without VOD and PPV. 

Anyway, my local franchise authority didn't want to get involved since "we don't control pricing" and the FCC sends me a form letter directing me back to the LFA; they kowtow to Comcast. Based on the letters I received from the FCC, I don't think they read one word of my complaints. In a nutshell, nobody wants to deal with this issue. Perhaps my next step is to contact the DOJ and file a racketeering complaint. 

Anyway, Comcast basically offered me "good customer" unadvertised special and additional discounts upon each complaint because it was cheaper to placate me than to fix the problem of all Tivo owners getting raked-over-the-coals each month. Sure, I'm paying $79.99 a month for Premier (to inlcude HBO, SHO, MAX, STARZ, Sports, etc.) and 30 Mbps Internet...but I would rather see Comcast fairly price Cablecards. Besides getting Premier/Internet at $99.99 for 12-months, I'm also receiving two $10 "stop whining to the FCC discounts" and my 2nd Cablecard (Additional Digitial Outlet fee) waived for one year.


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## lpwcomp (May 6, 2002)

generaltso said:


> Your quote says that Comcast is required to provide all linear channels to cable card customers. They do. Is there a linear channel that's available on a cable box that they won't give you with a cable card? Your quote in bold has nothing to do with pricing. It doesn't say anything about additional outlet fees. Comcast charges an additional outlet fee for the second and any subsequent outlets where you have a cable card OR a cable box. What specifically does this violate? Are you saying that they should not be allowed to charge an additional outlet fee for a cable card on a second outlet even though they charge that fee for a second outlet that has a cable box?
> 
> How many cable outlets are you using in your house and what equipment are you using on each outlet? It's quite possible that you're being charged incorrectly, but I can't say if that's the case without knowing what you have.


You can't take things in isolation. They have a published price for CableCARDs. They are required to provide access to all linear channels in a package to a CableCARD device. That's _*"in your subscription package"*_. Not "in your subscription package if it's the primary device on the account. Otherwise, they can charge an additional fee".

Comcast has two levels of additional digital outlets - one includes a DTA for $1.99/mo. The other includes a standard definition STB for $9.95/mo. Even if the regulations allow Comcast to charge for additional outlets (that's a bit murky), they do not allow Comcast to charge the higher rate for a CableCARD device simply because it has the same linear channel capabilities as their standard box. Actually, it has more capabilities since it can receive HD channels. By your logic, Comcast would be justified in adding the "HD Technology Fee" if you have any CableCARD devices, even if you only have one and you have none of their boxes.


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## jadziedzic (Apr 20, 2009)

I filed an FCC complaint and received a call from a Comcast representative here in the Boston area. She explained that the "additional outlet fee" is a charge to receive "digital services" (her term) at locations other than the primary outlet. Included in that fee is a Comcast set-top box. If you choose to use your own CableCARD-capable device (TV, TiVo, etc.) at that additional outlet you will receive a "customer-owned equipment credit", which is $2.50 in this area. If my device requires TWO CableCARDS I will be charged an additional $1.00 or so for the second CableCARD for that device. All of this information is clearly provided in the rate sheet that Comcast provided to us with our February bill.

You can complain all you want - and I personally agree that charging for extra outlets really sucks - but based on Comcast's explanation of their charges they believe they do comply with *their interpretation* of the FCC requirements. Yours obviously differs, but until you can convince some government entity to convince Comcast to change *their opinion* you're simply flogging a deceased equine.


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## LegacyCX (Nov 6, 2004)

Comcast removed the $6.95/mo. A/O fee, so I'm not fighting the $2.50 credit since I don't want to open that bag of worms!


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## pdhenry (Feb 28, 2005)

lpwcomp said:


> Comcast is perfectly within their rights to charge you more for their equipment that can receive channels beyond the capabilities of the DTA. However, other than the actual fee for the CableCARD(s), they _*cannot*_ charge you to enable that capability on CableCARD using equipment that you own.


Will you agree that your argument hinges on the difference in cost between a DTA and the CableCard in a TiVo?


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## terpfan1980 (Jan 28, 2002)

Not trying to pot stir here at all, but I find this discussion somewhat humorous since so many people never seemed to be bothered by the additional outlet fees that DirecTV and Dish Network charged their customers -- customers that had little or no choice at all in terms of what equipment to use. Additional outlet fees of $5 or $6 per unit, plus a household fee if any outlet in the home used a DVR, plus the up-front costs of the equipment which is almost all leased rather than owned, plus, well, whatever other charges those companies could find a way to charge their customers for....

Those companies would go out and advertise rates that looked so much less expensive when compared with the big evil cable companies which didn't charge additional outlet fees back in the days of analog cable, but when a customer got signed on and then realized that they needed multiple outlets, the costs would suddenly become much less friendly and back in the same neighborhood that the evil cable co.'s would charge.

Now that everything is digital and boxes are required everywhere the cable companies are back in the mode where they can charge for additional outlets and they are working to maximize their profits wherever possible and some people are getting up in arms over these costs.

As much as I hate the idea of these additional outlet fees, if I pay $X for a cable co. provided box and pay (after credits are applied) the same $X for the use of my own hardware, be it a TiVo box, a Ceton InfiniTV, an HD Homerun box, whatever, then I have no standing. The fee is the fee. The fact that I have to pay TiVo a monthly fee on top of that fee is not the fault of the cable co. As long as the cost per outlet is the same (ignoring any fee paid to a hardware vendor like TiVo), there's no complaint, or at least not one that the FCC is going to do a darned thing about.


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## lpwcomp (May 6, 2002)

jadziedzic said:


> I filed an FCC complaint and received a call from a Comcast representative here in the Boston area. She explained that the "additional outlet fee" is a charge to receive "digital services" (her term) at locations other than the primary outlet. Included in that fee is a Comcast set-top box. If you choose to use your own CableCARD-capable device (TV, TiVo, etc.) at that additional outlet you will receive a "customer-owned equipment credit", which is $2.50 in this area. If my device requires TWO CableCARDS I will be charged an additional $1.00 or so for the second CableCARD for that device. All of this information is clearly provided in the rate sheet that Comcast provided to us with our February bill.


Did you remind them that, based on their own rate sheet, you can get limited "digital services" at "additional outlets" for $1.99/mo? That FCC regulations state that a CableCARD "Receive all linear channels (channels other than on-demand) in your subscription package."? If so, what was their response?



jadziedzic said:


> You can complain all you want - and I personally agree that charging for extra outlets really sucks - but based on Comcast's explanation of their charges they believe they do comply with *their interpretation* of the FCC requirements. Yours obviously differs, but until you can convince some government entity to convince Comcast to change *their opinion* you're simply flogging a deceased equine.


Comcast can spin it however they wish. The fact is that they _*are*_ in violation. But, as I have stated before there is no real enforcement mechanism. The FCC doesn't seem to give a rodent's posterior; I guess they're too busy worrying wardrobe malfunctions and trying to reinstate the idiotic "Fairness Doctrine". And I can't even determine who my LFA is, much less how to contact them.

Comcast counts on people not knowing what the regulations actually are, getting frustrated by the spin, and giving up. IOW, that equine is far from deceased, it's just been heavily doped by Comcast's lies and obfuscation. Miracle Max would have absolutely no problem reviving it.


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## WhiskeyTango (Sep 20, 2006)

lpwcomp said:


> Did you remind them that, based on their own rate sheet, you can get limited "digital services" at "additional outlets" for $1.99/mo? That FCC regulations state that a CableCARD "Receive all linear channels (channels other than on-demand) in your subscription package."? If so, what was their response?


You've posted that 3 times now and it still has nothing to do with an additional outlet fee associated with a cable card. The cable card receives all linear channels so I don't know why you keep bringing that up. It takes the place of a cable box which would also incur the AO fee.



lpwcomp said:


> Comcast can spin it however they wish. The fact is that they _*are*_ in violation. D


That is not a fact. That is your opinion. Nothing you've said has proven otherwise.


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## pdhenry (Feb 28, 2005)

lpwcomp will only be happy when DTAs have the same fee as a set-top box (and then he'll be miserable).


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## lpwcomp (May 6, 2002)

terpfan1980 said:


> Not trying to pot stir here at all, but I find this discussion somewhat humorous since so many people never seemed to be bothered by the additional outlet fees that DirecTV and Dish Network charged their customers -- customers that had little or no choice at all in terms of what equipment to use.


Since satellite companies aren't covered by *Cable*CARD regulations and none of the CableCARD using TiVos will even work on a satellite system, how exactly is this relevant?

In order to be compliant with the FCC regulations and still get the same revenue, Comcast's rate sheet would have to read something like the folllowing:

"First CableCARD in primary outlet $0
First CableCARD in additional outlet $7.45/mo
Second CableCARD in same device $1.50
User Owned Equipment Credit (applies only to primary outlet) $2.50/mo

TiVo probably isn't interested in getting involved. If the true charges for using multiple TiVos on Comcast were known, it would make a TiVo a less attractive option.


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## lpwcomp (May 6, 2002)

pdhenry said:


> lpwcomp will only be happy when DTAs have the same fee as a set-top box (and then he'll be miserable).


 That's the most inane comment you've made on this subject , and that's saying a lot. Apparently you will only be happy when everyone just lies back and enjoys it.


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## pdhenry (Feb 28, 2005)

But if the DTA cost the same as a set-top box, you'd have no argument.

You claim that Comcast thinks they've found a loophole, but others are observing that you are the one who seems to think he has found a loophole.


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## generaltso (Nov 4, 2003)

lpwcomp, what devices do you have in your home and how much is Comcast charging you?


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## lpwcomp (May 6, 2002)

pdhenry said:


> But if the DTA cost the same as a set-top box, you'd have no argument.


Wrong again. The fee differential just makes it more obvious what Comcast is doing and gives you something to throw in their face when arguing with Comcast. It is not the basis for my argument.



pdhenry said:


> You claim that Comcast thinks they've found a loophole,...


 No,buscuitboy said that Comcast found a loophole and I responded they only _*think*_ they found a loophole.



pdhenry said:


> ... but others are observing that you are the one who seems to think he has found a loophole.


You (and the others) have a very odd definition of loophole. I'm not trying to get around anything. I'm trying to prevent Comcast from getting around the regulations.


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## lpwcomp (May 6, 2002)

WhiskeyTango said:


> That is not a fact. That is your opinion. Nothing you've said has proven otherwise.


Ignoring the problem of trying to prove a negative, I have stated my premise ("Comcast is in violation of FCC regulations governing CableCARDs") and have provided supporting arguments based on facts - the official Comcast rate sheet and the relevant FCC regulations as summarized by the CableCARD: Know Your Rights page. In response, all I have gotten is either "This is what Comcast says and there's nothing we can do about it so just shut up" or "That's just your opinion". Neither of those is a valid counter argument.

This is not a criminal prosecution in which there is an assumption of innocence. In the face of the evidence to the contrary, it is supposed to be up to the FCC to make Comcast prove that they are in compliance. Instead, apparently their only response to a complaint is to inform Comcast and then file it in the bitbucket.

Do you really think that the CableCARD charge that the regulations(FCC Rule 76.1205(b)(5), 76.1602(b)) require a cable operator to document isn't supposed to include the ability to actually fully utilize the card as specified in FCC Rule 76.1205(b)(4)?


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## generaltso (Nov 4, 2003)

It's obvious that nothing anyone says will change your view. The fee in question has nothing to do with cable cards. It's a fee that's levied on the second outlet regardless of whether you have a cable card or a cable box. That's why it's not a violation. It's also why the a/o fee is not listed with the cable card fees. 

Have you asked Comcast to limit the channels you receive on your cable card to ONLY the channels that you would receive with a DTA? If they did that, I could see your argument that you shouldn't pay the a/o fee because you wouldn't have to with a DTA. However, if your cable cards are getting all the channels that a cable box would get, you're going to pay the same a/o fee that a cable box would require and there's no regulation against that.

Do you have two TiVos? A TiVo and a cable box? A different mix?


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## lpwcomp (May 6, 2002)

generaltso said:


> lpwcomp, what devices do you have in your home and how much is Comcast charging you?


I have a DCT2000 from Comcast connected to(a/v(composite)) and controlled by(serial) a TiVo 2. That is my primary outlet. I also have a THD and 2 Premieres. The second Premiere doesn't currently have a CableCARD but I plan to pick one up next Tuesday(6/12) (assuming I still consider it worth the effort after discussing my treatment options at the VAMC) and install and activate it on the following Friday(6/15) since I won't be back home until late Thursday night.

Currently, I have the following items on my bill:

Digital Starter 62.95

Digital Service 19.90
Qty 2 @ $9.95 each

Customer Owned Equipment -2.50
Adjustment

Customer Owned Equipment -2.50
Adjustment

Franchise Fees 2.64

Federal Regulatory Fee 0.08

State and Local Taxes 0.14


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## generaltso (Nov 4, 2003)

lpwcomp said:


> I have a DCT2000 from Comcast connected to(a/v(composite)) and controlled by(serial) a TiVo 2. That is my primary outlet. I also have a THD and 2 Premieres.


What if you switched one of your TiVos to be your primary outlet? Then one of your a/o fees would move to the DCT2000 box. Would you see that as a violation of FCC rules?


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## generaltso (Nov 4, 2003)

generaltso said:


> Have you asked Comcast to limit the channels you receive on your cable card to ONLY the channels that you would receive with a DTA? If they did that, I could see your argument that you shouldn't pay the a/o fee because you wouldn't have to with a DTA.


Actually, your own quote may prevent Comcast from even being allowed to do this.

*Receive all linear channels (channels other than on-demand) in your subscription package.*

They can give you a DTA that receives less than all of your linear channels, but it doesn't look like they're allowed to limit a cable card the same way, which could potentially get around the a/o fee.


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## WhiskeyTango (Sep 20, 2006)

lpwcomp said:


> Ignoring the problem of trying to prove a negative, I have stated my premise ("Comcast is in violation of FCC regulations governing CableCARDs") and have provided supporting arguments based on facts - the official Comcast rate sheet and the relevant FCC regulations as summarized by the CableCARD: Know Your Rights page. In response, all I have gotten is either "This is what Comcast says and there's nothing we can do about it so just shut up" or "That's just your opinion". Neither of those is a valid counter argument.
> 
> This is not a criminal prosecution in which there is an assumption of innocence. In the face of the evidence to the contrary, it is supposed to be up to the FCC to make Comcast prove that they are in compliance. Instead, apparently their only response to a complaint is to inform Comcast and then file it in the bitbucket.
> 
> Do you really think that the CableCARD charge that the regulations(FCC Rule 76.1205(b)(5), 76.1602(b)) require a cable operator to document isn't supposed to include the ability to actually fully utilize the card as specified in FCC Rule 76.1205(b)(4)?


None of your evidence supports the idea that charging an AO for a cable card is against any regulations. I've read through the regulations you linked and I don't see how any of them are being violated by the AO fee. You just keep asking about full use of the card, how is the AO fee limiting your use of a cable card?


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## cherry ghost (Sep 13, 2005)

The only violation I see on my bills is that they don't list the cost of the cablecards separately.

Digital Access Fee - $26.85
Includes: Cable card and Digital Access
3 @ $8.95 each

Cusomer owned equipment adjustment - 3 @ -$2.50 each


I could complain, but I doubt the overall price would change.


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## generaltso (Nov 4, 2003)

cherry ghost said:


> The only violation I see on my bills is that they don't list the cost of the cablecards separately.
> 
> Digital Access Fee - $26.85
> Includes: Cable card and Digital Access
> ...


How many TiVos do you have? Assuming the "Digital Access" on your bill is the A/O fee, shouldn't you only have 2 of those since the first outlet wouldn't have this fee?


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## cherry ghost (Sep 13, 2005)

generaltso said:


> How many TiVos do you have? Assuming the "Digital Access" on your bill is the A/O fee, shouldn't you only have 2 of those since the first outlet wouldn't have this fee?


I have 4. The $2.50 credit should be 4, not 3.


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## generaltso (Nov 4, 2003)

cherry ghost said:


> I have 4. The $2.50 credit should be 4, not 3.


Well, I guess that's one thing to complain about. They owe you another $2.50 a month.


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## cherry ghost (Sep 13, 2005)

generaltso said:


> Well, I guess that's one thing to complain about. They owe you another $2.50 a month.


No, my bill does say 4, I mistyped.


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## generaltso (Nov 4, 2003)

cherry ghost said:


> No, my bill does say 4, I mistyped.


Ah, okay.


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## lpwcomp (May 6, 2002)

generaltso said:


> It's obvious that nothing anyone says will change your view. The fee in question has nothing to do with cable cards. It's a fee that's levied on the second outlet regardless of whether you have a cable card or a cable box. That's why it's not a violation. It's also why the a/o fee is not listed with the cable card fees.
> 
> Have you asked Comcast to limit the channels you receive on your cable card to ONLY the channels that you would receive with a DTA? If they did that, I could see your argument that you shouldn't pay the a/o fee because you wouldn't have to with a DTA. However, if your cable cards are getting all the channels that a cable box would get, you're going to pay the same a/o fee that a cable box would require and there's no regulation against that.
> 
> Do you have two TiVos? A TiVo and a cable box? A different mix?


Do you not understand that the regulations require them to explicitly provide via the rate sheet "Accurate information on the rental cost of a CableCARD."? Do you not understand that it would be ridiculous to assume that this does not have to reflect the full cost for actually using a CableCARD or that it refers to the primary outlet only? Do you not understand that $7.45/mo is the true cost of using a CableCARD in other than the primary device rather than the $0 reflected in their rate sheet? Do you not understand that the DTA fee differential is a minor point and that if you wish to proceed, you should actually address the main points of my argument rather than ignoring them.

The above questions are rhetorical as it is quite obvious that you in fact do not understand.

One other point that I haven't made here but have made to Comcast - beyond providing the CableCARD, pairing, and authorizing it, Comcast has zero responsibility for maintenance of the various outlets. The splits are all internal (built-in as far as the wall outlet) and Comcast does not maintain internal wiring unless you pay extra.


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## generaltso (Nov 4, 2003)

lpwcomp said:


> Do you not understand that the regulations require them to explicitly provide via the rate sheet "Accurate information on the rental cost of a CableCARD."? Do you not understand that it would be ridiculous to assume that this does not have to reflect the full cost for actually using a CableCARD or that it refers to the primary outlet only?


I completely understand the regulations. The rental cost of a Cable Card is accurately reflected on the rate sheet. The same rate sheet also lists the additional outlet fee. This fee is not included in the Cable Card section, because it doesn't only apply to Cable Cards. Why would they list the additional outlet fee in the Cable Card section, the DVR section, and the cable box sections? Doesn't it accomplish the same thing to list the additional outlet fee in one place since it applies to all devices.

You can repeat the same information as often as you'd like. It won't change the fact that the a/o fee does not violate the FCC Cable Card rules as long as the same fee is levied against the Comcast cable boxes.

If one of the a/o fees on your bill was on your cable box instead of a cable card, would you be satisfied that it isn't violating the rules? If so, just call Comcast and have them change one of you cable cards to the primary outlet. It won't change the amount of your bill, but it would be one less violation in your eyes, right?


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## jadziedzic (Apr 20, 2009)

Your rate sheet must differ from mine. Under the "Basic and Digital Ancillary Services" section (Boston region) it lists the following:

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)

Digital Adapter Additional Outlet Service Charge (per outlet)

(1st and 2nd additional outlet) $0.00
(3rd, 4th, 5th, etc. additional outlets) $1.99

Footnote 14: Includes a customer-owned video equipment credit. An additional charge will apply for additional CableCARDs in the same device.

Under the "Video Equipment" section it lists the following:

CableCARD (first card in device) $0.00
CableCARD (second card in device) $1.50
Customer-owned Video Equipment Credit $2.50

That looks pretty darn accurate to me; it exactly matches what I see on my monthly bill. I am not being charged MORE for using my TiVo on a secondary outlet than I would be for using a Comcast-provided *comparable* device - and the DTA is definitely NOT comparable to either my TiVo or a Comcast-provided SD or HD digital converter.


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## pdhenry (Feb 28, 2005)

lpwcomp said:


> Do you not understand that the regulations require them to explicitly provide via the rate sheet "Accurate information on the rental cost of a CableCARD."? Do you not understand that it would be ridiculous to assume that this does not have to reflect the full cost for actually using a CableCARD or that it refers to the primary outlet only? Do you not understand that $7.45/mo is the true cost of using a CableCARD in other than the primary device rather than the $0 reflected in their rate sheet? Do you not understand that the DTA fee differential is a minor point and that if you wish to proceed, you should actually address the main points of my argument rather than ignoring them.


So this is all about changing the rate sheet, then.

You certainly are expending a lot of energy and emotion on this.


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## lpwcomp (May 6, 2002)

generaltso said:


> What if you switched one of your TiVos to be your primary outlet? Then one of your a/o fees would move to the DCT2000 box. Would you see that as a violation of FCC rules?


That's completely irrelevant to the question at hand. Even though I think it is sleazy and might argue with Comcast about it if I were in that position, I'm not questioning the ADO fee in general at this time. I will say one thing on the subject though - cable companies used to charge for each outlet, then they stopped, I thought due to the FCC or possibly congressional action. I found this on the FCC website, part of which says:



> Q: Can the cable company charge for additional outlets?
> 
> A: Operators may charge you a monthly fee to recover the cost of the wiring and parts installed and the estimated cost to maintain the outlet. This monthly fee generally will be quite low.
> 
> ...


hmm. Anyone want to reconsider their stance vis-à-vis the legitimacy of the ADO fee?


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## generaltso (Nov 4, 2003)

lpwcomp said:


> Anyone want to reconsider their stance vis-à-vis the legitimacy of the ADO fee?


Based on a document from 1994? No.

If what you're saying is true, Comcast should not charge anything for any outlets with Cable Cards. But you'd still get a $2.50 credit per TiVo. If that's the case, I'll just install 25 outlets in my house, order 25 free cable cards, get a credit of $2.50 per card, and have free cable for life. Or maybe I'll install even more outlets so Comcast has to pay me every month. I'm starting to like your logic


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## lpwcomp (May 6, 2002)

generaltso said:


> Based on a document from 1994? No.


Unless the Cable Television Consumer Protection and Competition Act of 1992 has been repealed or superseded (at least the relevant portion thereof), it is still in force.



generaltso said:


> If what you're saying is true, Comcast should not charge anything for any outlets with Cable Cards. But you'd still get a $2.50 credit per TiVo. If that's the case, I'll just install 25 outlets in my house, order 25 free cable cards, get a credit of $2.50 per card, and have free cable for life. Or maybe I'll install even more outlets so Comcast has to pay me every month. I'm starting to like your logic


No, in my opinion, if they were not charging the ADO fee then the customer owned equipment credit would only apply to the primary outlet as that would be the only time you are not using equipment for which you are being charged. And even then, it would only apply if your package included an STB. An ADO is not a package. The relevant portion from the know your rights page reads:


> Pay only for equipment you have. Your operator must give you a discount on any packages that include the price of a set-top box if you choose to use your own CableCARD-enabled device. FCC Rule 76.1205(b)(5).


You would only be eligible for multiple discounts if your package included multiple STBs.

Strangely enough, pdhenry reported that exact situation. He isn't being charged any ADO fees but is getting 2 "Customer Owned Equipment" credits. This is with limited basic which, AFAICT, includes 0 STBs.


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## generaltso (Nov 4, 2003)

Now this is just getting tedious. Good luck with your fight against Comcast.


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## WhiskeyTango (Sep 20, 2006)

lpwcomp, I think you are one of the better posters here but at this point, I'm not sure what your argument is. It started off about something to do with the linear channels but that has morphed into an argument about the lack of a clear pricing system. That has been addressed by generatso and jadziezic rendering that point moot. You, yourself, said the following a few months ago:



lpwcomp said:


> While I abhor the "additional outlet fee", I don't think it is a violation of the regulation you cited. You are not actually paying for the CableCARD per se. You are paying for "Digital Additional Outlet Service with HD Converter". You are getting a CableCARD in lieu of an HD converter and a credit for the difference in monthly cost for a card vs. a box.
> 
> With Comcast, the only time an actual separate charge for a CableCARD would apply would be if you had more than one card installed in the same device. The only TiVo that needs that is the TiVo 3 OLED.


That is the same regulation you are now saying Comcast is in violation of, 76.1205.

From 76.1205 (B) (1):



> ( 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.*


Additionally, from 76.923(h):


> (h) Additional connection charges. The costs of installation and
> monthly use of additional connections shall be recovered as charges
> associated with the installation and equipment cost categories, and at
> rate levels determined by the actual cost methodology presented in the
> ...


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## lpwcomp (May 6, 2002)

generaltso said:


> Now this is just getting tedious. Good luck with your fight against Comcast.


I never understood why you naysayers got involved in this particular thread in the first place. There are at least two other threads where this discussion was ongoing and I thought this particular thread was for people who wanted to talk about specific complaints to the FCC.


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## lpwcomp (May 6, 2002)

WhiskeyTango said:


> lpwcomp, I think you are one of the better posters here but at this point, I'm not sure what your argument is. It started off about something to do with the linear channels but that has morphed into an argument about the lack of a clear pricing system.


It hasn't morphed. It's all part and parcel of the same argument. The only thing that I recently added was the bits based on the FCC's "FREQUENTLY ASKED QUESTIONS REGARDING CABLE TELEVISION REGULATIONS"



WhiskeyTango said:


> That has been addressed by generatso and jadziezic rendering that point moot.


I respectfully disagree.



WhiskeyTango said:


> You, yourself, said the following a few months ago:


That was before I did additional research. I freely admit that I was wrong.



> (h) Additional connection charges. The costs of installation and
> monthly use of additional connections shall be recovered as charges
> associated with the installation and equipment cost categories, and at
> rate levels determined by the actual cost methodology presented in the
> ...


 a. The outlets were put in when the condo was built and there is only one line going into the unit, all of the splits being internal and therefore Comcast takes no responsibility for their maintenance absent an additional "inside wiring maintenance" fee

and

b. they pay content providers per subscriber, not per outlet.

Conclusion: there are no costs associated with the additional outlets for them to recover, therefore any A/O fee, D or otherwise, is invalid.

While the above applies only to me and anyone else in a similar situation, unless Comcast can show an ongoing cost associated with the use or maintenance of additional outlets, any permanent A/O fee is invalid. And yes, I include in that the $7.45/mo you pay in excess of their quoted equipment rental fee when using one of their own boxes. I also consider the $10/mo "HD Technology" fee (which I have never been assessed, having none of their HD boxes) to be invalid. Some people have reportedly been assessed the HD Technology fee even if all they have are TiVos. Do you consider that valid?

Since the ADO fee is only assessed if you have one of their STBs or a CableCARD device and they change nothing either externally or internally, how can Comcast claim that the fee is a recovery of ongoing costs associated with the maintenance or use of the outlet?


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## slowbiscuit (Sep 19, 2006)

lpwcomp said:


> In order to be compliant with the FCC regulations and still get the same revenue, Comcast's rate sheet would have to read something like the folllowing:
> 
> "First CableCARD in primary outlet $0
> First CableCARD in additional outlet $7.45/mo
> ...


This is exactly why they are not in compliance.


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## slowbiscuit (Sep 19, 2006)

jadziedzic said:


> Your rate sheet must differ from mine. Under the "Basic and Digital Ancillary Services" section (Boston region) it lists the following:
> 
> Digital Additional Outlet Service Charge (per outlet)
> 
> ...


This is what they need to change all the rate sheets to for compliance. Ours does not have this info for cards.

The A/O fee is just a money grab if you don't have their box, but in some areas there is a way around it - you can get Comcast to charge $1.50 for a second card even if it's not in the same box, with no A/O fee. In my area they won't do this (I think) for more than one extra card though, the third or more card(s) get the fee.


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## buscuitboy (Aug 8, 2005)

slowbiscuit said:


> in some areas there is a way around it - you can get Comcast to charge $1.50 for a second card even if it's not in the same box, with no A/O fee. In my area they won't do this (I think) for more than one extra card though, the third or more card(s) get the fee.


This is what I have basically done to avoid these nonsense "digital outlet" fees. I have two M-Cards, but they are in two totally different Premiere units hooked up to 2 HDTVs. Therefore, will be getting charged just a $1.50 since I told them they are both in a Series 3 TiVo (& they took my word for it).

In order to do this, I had to also turn in my Atlanta Scientific SD digital box. So currently I don't have access to Comcast OnDemand services. However, I never used it anyway so I figured no big loss (for now).

Plus, I am waiting for Comcast OnDemand access for TiVo Premiere to come to my area (Atlanta). Hopefully in the next few months so will possibly get it back anyway. Either that, or I am looking to get an Xbox 360 and can then get Comcast OnDemand access this way as well.


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## pdhenry (Feb 28, 2005)

I had the CC installed in my first TiVo in the family room (I don't think they keep track but the family room is probably the typical primary outlet location). When I got my second TiVo I moved the first one upstairs and had the CC installed on the new TiVo in the family room. Maybe this helped me avoid the A/O fee? 

Not that I expect them to be consistent but I sometimes wonder how Comcast would treat 2 TiVos connected to one TV. Same outlet? Additional outlet?


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## lpwcomp (May 6, 2002)

pdhenry said:


> I had the CC installed in my first TiVo in the family room (I don't think they keep track but the family room is probably the typical primary outlet location). When I got my second TiVo I moved the first one upstairs and had the CC installed on the new TiVo in the family room. Maybe this helped me avoid the A/O fee?
> 
> Not that I expect them to be consistent but I sometimes wonder how Comcast would treat 2 TiVos connected to one TV. Same outlet? Additional outlet?


Absent a physical inspection of your premises, Comcast has no way of knowing to what wall outlet a device is connected. Every device that they know about on an account, either because it needs CableCARD(s) or is one of their boxes, is treated as a separate outlet. The only reason they know you have a TiVo at all is because you need a CableCARD. This explains the real reason behind Comcast's desire to encrypt everything. They claim it is to prevent cable theft when in reality it is an effort to start charging the bogus ADO fee to subscribers who have multiple digital devices connected that are only accessing the clear QAM channels, such as digital TVs and non-CableCARDed TiVos. I guess they consider "theft" to be anything that reduces their potential revenue.

Ya know, I'm not generally in favor of class action suits of this type because it's usually only the attorneys (on both sides) who profit, but in this case I have to say that I think that the discovery process would be very...interesting.


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## MichaelK (Jan 10, 2002)

generaltso said:


> That's my understanding as well. Although I hate the fact that additional outlet fees exist at all, I don't think it's a violation of the FCC rules.


additional outlet fees are not at all a violation in fact the rules were specifically made to allow it.

basically cable noticed that Directv and Dish charged "mirroring fees" or whatever they call them now a days and complained that they could not.

pay the right campaign contributions and presto chango additional outlet fees for DIGITAL content are legal.


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## MichaelK (Jan 10, 2002)

lpwcomp said:


> Since satellite companies aren't covered by *Cable*CARD regulations and none of the CableCARD using TiVos will even work on a satellite system, how exactly is this relevant?
> 
> In order to be compliant with the FCC regulations and still get the same revenue, Comcast's rate sheet would have to read something like the folllowing:
> 
> ...


first up the credit is for each piece of equipment not jsut the primary (in fact their system is so confused they give me a credit for EACH cabelcard even though 2 are in one S3 and i only pay a dollar each)

second- take a minute and think. Then stop reading FAQ's and spend some times in the actual regulations like some of us have earlier when this all started with the S3 years ago- and read the actual law and regulations so you understand the FACTS. After all that if you still think you are so much smarter then the hundreds of other people that have looked into it, the people that work at the FCC, comcast's lawyers, the various PUC's, and congressional aids that have looked at it- then by all means try to get an audience with the pope or the president or whomever you think is going to make everyone else see your point of view .


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## MichaelK (Jan 10, 2002)

lpwcomp said:


> Do you not understand that the regulations require them to explicitly provide via the rate sheet "Accurate information on the rental cost of a CableCARD."? Do you not understand that it would be ridiculous to assume that this does not have to reflect the full cost for actually using a CableCARD or that it refers to the primary outlet only? Do you not understand that $7.45/mo is the true cost of using a CableCARD in other than the primary device rather than the $0 reflected in their rate sheet? Do you not understand that the DTA fee differential is a minor point and that if you wish to proceed, you should actually address the main points of my argument rather than ignoring them.
> 
> The above questions are rhetorical as it is quite obvious that you in fact do not understand.
> ....


if anything you are probably right that they should be more clear- and so perhaps your complaints will result in Comcast spending whatever it costs to make their billing system more clear by separating out the charges in a more consistent manner. (hopefully it's not too much becasue i'd rather not have my rates go up because some people can't understand the billing even when 10 people in a thread try to explain it to them)

But the fact is they are not charging anything that is not legally allowed.



lpwcomp said:


> ...
> 
> One other point that I haven't made here but have made to Comcast - beyond providing the CableCARD, pairing, and authorizing it, Comcast has zero responsibility for maintenance of the various outlets. The splits are all internal (built-in as far as the wall outlet) and Comcast does not maintain internal wiring unless you pay extra.


nor do they have anythign to do with the additonal outlet that their boxes are connected to and charge for. Nor does satellite maintain the wiring for their mirrored boxes. In fact many times the consumer provides the original wiring. yet the FCC has decided that digital mirroring fees are permissible. go figure- politicians taking care of us. 

I don't KNOW but i suspect the premise is that with digital devices that get "authorized" HBO et al can ask comcast "hey exactly how many tv's are subscribed to HBO?" And therefore HBO can charge by tv and not just account. So sat and cable argue their programming costs can go up for addtional tv's.


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## MichaelK (Jan 10, 2002)

lpwcomp said:


> That's completely irrelevant to the question at hand. Even though I think it is sleazy and might argue with Comcast about it if I were in that position, I'm not questioning the ADO fee in general at this time. I will say one thing on the subject though - cable companies used to charge for each outlet, then they stopped, I thought due to the FCC or possibly congressional action. I found this on the FCC website, part of which says:
> 
> hmm. Anyone want to reconsider their stance vis-à-vis the legitimacy of the ADO fee?





generaltso said:


> Based on a document from 1994? No.
> ..





lpwcomp said:


> Unless the Cable Television Consumer Protection and Competition Act of 1992 has been repealed or superseded (at least the relevant portion thereof), it is still in force.
> ....


it's actually the telecommunications act of 1996 that changed it.

the same thing that invented the whole concept of cablecards in teh first place.

start your reading of the actual law and regulations that implement the law here:
http://transition.fcc.gov/telecom.html

then come back and see what you think.

they can charge additional outlet fees on DIGITAL outlets

if you read the law prior to that then there was zero provision for cablecards.


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## lpwcomp (May 6, 2002)

MichaelK said:


> additional outlet fees are not at all a violation in fact the rules were specifically made to allow it.


According to whom? Show me where the rules summarized in the part of the FCC FAQ I quoted in post #43 have been repealed or superseded. Either that or show me something detailing Comcast's monthly costs to support the additional outlets. Show me where the rules regarding the requirement to provide clear and explicit information to customers regarding the monthly fee to rent a CableCARD and what channels are available have been modified since no reasonable interpretation can draw a distinction between rental and use.


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## MichaelK (Jan 10, 2002)

lpwcomp said:


> According to whom? Show me where the rules summarized in the part of the FCC FAQ I quoted in post #43 have been repealed or superseded. Either that or show me something detailing Comcast's monthly costs to support the additional outlets. Show me where the rules regarding the requirement to provide clear and explicit information to customers regarding the monthly fee to rent a CableCARD and what channels are available have been modified since no reasonable interpretation can draw a distinction between rental and use.


stop with the stupid FAQ and read the actual law and enabling regulations and then tell me what the facts are. I gave you the pointer.

personally I dont currently have the time to search it out and post you the link, but i can tell you that several times since the S3 came out and this issue came up that i personally have read the law and enabling regulations and come to the conclusion. (maybe if i have time later i will do YOUR homework for you and get the link again).

But assuming you were quoting from regs you already wrote it in your post # 49 above:

"an operator may recover additional programming costs"

do you really think that it illegal but all of a sudden ALL the cable providers got together after 1996 and decided to blow off the law and then for the past 15 years the FCC has ignored it and allowed them all to get away with it?


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## lpwcomp (May 6, 2002)

MichaelK said:


> stop with the stupid FAQ and read the actual law and enabling regulations and then tell me what the facts are. I gave you the pointer.
> 
> personally I dont currently have the time to search it out and post you the link, but i can tell you that several times since the S3 came out and this issue came up that i personally have read the law and enabling regulations and come to the conclusion. (maybe if i have time later i will do YOUR homework for you and get the link again).


GMAB. I just started looking through the damn thing. In this area, the FCC regulations that implement the law are just as relevant.



MichaelK said:


> But assuming you were quoting from regs you already wrote it in your post # 49 above:
> 
> "an operator may recover additional programming costs"


What additional programming costs? They pay per subscriber, not per "outlet".

I put "outlet" in quotes because that's not what the charge is really for. Think about it. Some Comcast systems still have a few analog channels. You have a TiVo 2 attached, happily using those channels since you only have an analog TV. Then you decide to replace everything with a new HDTV and a new TiVo and install a CableCARD in the TiVo. *poof*, the same physical outlet is magically transformed into a digital outlet for which Comcast can now charge you an additional fee.


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## MichaelK (Jan 10, 2002)

just started poking around- and while i can't find anything besides - "an operator may recover additional programming costs" , i found an early attempt (in 1995-1996) ate a class action lawsuit about additional outlet fees based on the 1992 law.

http://caselaw.findlaw.com/us-3rd-circuit/1343569.html

as the peanut gallery would assume the plantiff's lost. Premise was that first they didn't have the right to sue. Second that the local authority had to decide to regulate the fees and it wasn't up to the cable company to do anything in particular. (Not sure if the same premise(s) apply under the 1996 law.)


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## MichaelK (Jan 10, 2002)

lpwcomp said:


> GMAB. I just started looking through the damn thing. In this area, the FCC regulations that implement the law are just as relevant.
> 
> What additional programming costs? They pay per subscriber, not per "outlet".
> 
> I put "outlet" in quotes because that's not what the charge is really for. Think about it. Some Comcast systems still have a few analog channels. You have a TiVo 2 attached, happily using those channels since you only have an analog TV. Then you decide to replace everything with a new HDTV and a new TiVo and install a CableCARD in the TiVo. *poof*, the same physical outlet is magically transformed into a digital outlet for which Comcast can now charge you an additional fee.


You have access to the contracts that comcast has with HBO et al?

Assuming that there are no addtional fees and that you are right- these charges are illegal- the large cable companies (all of them) have all been breaking the law to the tune of Millions of dollars each month for 15+ years and YOU are the genius that discovered it and will fix this. Thank you so much for correcting this. I can't wait to get my rebate check.

I think the real answer is someone needs to read the entire section and see the scope- but it seems possible that the fee's are only regulated for basic cable and since the digital tier is above basic cable then they can charge more. Again, i dont have time at the moment to read the whole thing but just looking at it as a whole i find it hard to believe the FCC, a million class action lawyers, and thousands of congress critters (since 1996) have all missed this. Common sense just seems to point out that it can't be a GROSS violation. (i think there are some fringe messes- like the bills and rate sheets and all are truthfully NOT always clear)

Sarcasm aside. Why not put in a complaint to the FCC that very directly takes issue with additional outlet fees and then see what the FCC says? maybe they will say "wow, thanks for pointing it out to us. We'll get right on this clear violation of the law". My opinion, (and I'm on the internet so it's not worht much- lol) is that they will tell you that there is no violation and thanks for taking the time to write.


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## MichaelK (Jan 10, 2002)

actually i think the bottom line is in fact that nothing beyond the basic tier is regulated for pricing.
law is for regulation of rates is here:
http://www.gpo.gov/fdsys/pkg/USCODE...9-title47-chap5-subchapV-A-partIII-sec543.htm

enabling regulations are here:
http://ecfr.gpoaccess.gov/cgi/t/tex...ode=47:4.0.1.1.4&idno=47#47:4.0.1.1.4.14.3.14
see subpart P for rate regulation - nothing beyond basic tier regulations that i see. (and even then there are limits to the regs)

Subpart N has cablecard rules

i see nothing in there about maximum pricing.

§ 76.1205(b)(5) talks about being transparent about pricing for cablecard but notice there's not even a rule about how much cable cards should cost (i do recall commissioners warning that if pricing was 'unreasonable' they would regulate a maximum cost)


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## jadziedzic (Apr 20, 2009)

MichaelK said:


> Sarcasm aside. Why not put in a complaint to the FCC that very directly takes issue with additional outlet fees and then see what the FCC says?


In my experience the FCC does not directly respond to these complaints; the complaints are sent to the provider (Comcast) who investigates the issue and responds to the FCC. I don't know if it always happens this way, but after I filed a complaint *specifically about additional outlet fees* a Comcast representative called me and personally discussed the complaint, offered their explanation, etc. I must say that the Comcast representative was very polite and really did seem to make an effort to be sure they understood my concern. Obviously they didn't agree with my viewpoint, but that wasn't at all surprising.

That call was followed up by *a letter from Comcast to the FCC Consumer Inquiries and Complaints Division*, with a copy also sent to me. I won't quote the entire letter here, but here's the pertinent part:

"I contacted Mr. Dziedzic to discuss his concerns. I provided an explanation regarding additional digital outlet charges. We discussed the fact that any customer who has *digital service* active to an outlet beyond the first and regardless of the end equipment used, is assessed a monthly digital access/additional outlet fee for each of those outlets." (My emphasis on "digital service".)

*It seems pretty clear (to me) that if Comcast is violating some law then the FCC is fully aware of it, and chooses to do nothing. The alternative is that Comcast is NOT violating some law - and that's the more likely explanation.* It's not like Comcast is going out of their way to avoid sharing their interpretation of the law with the FCC ...


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## lpwcomp (May 6, 2002)

MichaelK said:


> You have access to the contracts that comcast has with HBO et al?


No, but neither do you so my assumption is at least as valid as yours. Has Comcast ever claimed that they are paying additional fees per outlet? Prior to digital cable, there was flat out no way for them to know how many devices were connected to the cable at any particular location. Sometimes they didn't even scramble _*premium*_ channels but instead used filters to control access. Even now, all they know is how many of their boxes and/or CableCARDs you have. They have no idea how many clear QAM capable devices you have installed, including TiVo 3's and 4's with no CableCARD. Thus the request for a waiver so that they can encrypt everything, forcing you to get CableCARDs or one of their boxes and incur the associated ADO fees. As a bonus, if you don't have a TiVo or other similar device and you want to continue to watch in HD, you'll need one of their HD boxes so that they can now add an "HD Technology" fee to your bill. BTW, since the ADO fee applies even if you have no premium channels, HBO is not a valid example.



MichaelK said:


> Assuming that there are no addtional fees and that you are right- these charges are illegal- the large cable companies (all of them) have all been breaking the law to the tune of Millions of dollars each month for 15+ years and YOU are the genius that discovered it and will fix this. Thank you so much for correcting this. I can't wait to get my rebate check.


15+ years? What year is it where you are? It's 2012 where I am and Comcast for one only instituted this charge a couple of years ago. As recently as 2004, I had 1 cable box, 4 TiVos and 3 TVs(1 with 2 dual tuners) spread about the house at 3 different wall outlets. Beyond the normal price for the particular tier I had, do you kinow how many additional fees I was paying - zero, zilch, nada, none. And this was in a house where the splitter was outside and had a Comcast or AT&T installed amp (don't remember if the swap happened prior to its installation). In 2008, I was in a different location and was down to two TiVos and purchased a THD and had a CableCARD installed. They added a $1.50/mo fee to my account. It stayed like that until February last year when I added a Premiere and had a CableCARD installed in it. Suddenly I was hit with 2 "Additional outlet fees" (their box counts as my primary). I got no customer owned equipment credits until I called up and requested them. Well, it started out as a request but fairly quickly turned into a demand when they did not want to give them to me.



MichaelK said:


> I think the real answer is someone needs to read the entire section and see the scope- but it seems possible that the fee's are only regulated for basic cable and since the digital tier is above basic cable then they can charge more. Again, i dont have time at the moment to read the whole thing but just looking at it as a whole i find it hard to believe the FCC, a million class action lawyers, and thousands of congress critters (since 1996) have all missed this. Common sense just seems to point out that it can't be a GROSS violation. (i think there are some fringe messes- like the bills and rate sheets and all are truthfully NOT always clear)


As noted above, the additional outlet fee is a fairly recent phenomena. Even today, not all of the cable companies have them and none of them, not even Comcast, have been charging for outlets all that long.



MichaelK said:


> Sarcasm aside. Why not put in a complaint to the FCC that very directly takes issue with additional outlet fees and then see what the FCC says? maybe they will say "wow, thanks for pointing it out to us. We'll get right on this clear violation of the law". My opinion, (and I'm on the internet so it's not worht much- lol) is that they will tell you that there is no violation and thanks for taking the time to write.


Based on the experience documented above by jadziedzic, I suspect the FCC would more likely just forward the complaint to Comcast for them to deal with as they see fit.

Being from the future and all, are you here to warn us not to waste our time in a futile effort? That the ADO fees are still in place and that they have been further augmented by technology that allows them to determine how many people are watching each screen and charging per viewer? That this has made HBO ecstatic as now it really is like having a box office in every home? That filling up your TiVo and jumping into a kiddie pool with works as a time travel mechanism? I guess it's good news in one regard - at least we now know that the world _*doesn't *_ end this year.

Have the debating rules changed in the future? Currently, it isn't the responsibility for one party in a debate to examine a set of arcane and complex documents full of mostly irrelevant information, looking for the few nuggets that support the other sides position. In other words, it's _*not my*_ homework.

See, I can be as sarcastic as you.

Seriously though, I do plan to at least try to examine the referenced material, if only so I have all my ducks in a row if and when I do decide to argue with Comcast again, file a complaint with the FCC, or even *shudder* contact *shudder* my *ack* congresscritter. Or, if I find what you say I'll find, I'll give it up and catch up on my TV viewing. Rather ironic that I'm spending so much time on this and am not actually watching much TV. Part of the problem is that I am not a very good typist and only a mediocre at best and very slow writer.


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## lpwcomp (May 6, 2002)

MichaelK said:


> actually i think the bottom line is in fact that nothing beyond the basic tier is regulated for pricing.
> law is for regulation of rates is here:
> http://www.gpo.gov/fdsys/pkg/USCODE...9-title47-chap5-subchapV-A-partIII-sec543.htm
> 
> ...


Where, at any point have I said that there was a maximum price?



MichaelK said:


> § 76.1205(b)(5) talks about being transparent about pricing for cablecard but notice there's not even a rule about how much cable cards should cost (i do recall commissioners warning that if pricing was 'unreasonable' they would regulate a maximum cost)


And that is precisely the point - they aren't transparent. Comcast says that the rental cost for the first CableCARD in a device is $0/mo. Nowhere in their information about CableCARDs is it stated or even implied that there is an ADO fee incurred unless it is for your "Primary Outlet"

If Comcast's CableCARD pricing is transparent to you, then you must be able to leap tall buildings in a single bound 'cause you sure as heck have x-ray vision.


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## MichaelK (Jan 10, 2002)

lpwcomp said:


> ...
> 
> And that is precisely the point - they aren't transparent. Comcast says that the rental cost for the first CableCARD in a device is $0/mo. Nowhere in their information about CableCARDs is it stated or even implied that there is an ADO fee incurred unless it is for your "Primary Outlet"
> 
> If Comcast's CableCARD pricing is transparent to you, then you must be able to leap tall buildings in a single bound 'cause you sure as heck have x-ray vision.


acting like a grown up this morning- sorry for being silly yesterday- got into the heat of the moment.

I've agreed with you all along on the above point. Basically comcast has cobbled together a pile of desperate (sp?) systems and the net result is a confusing mess. I do think they could do better to be more clear and consistent. But i dont think at all charging an additional outlet fee on digital cable is illegal. Nor do i think they charge it only on TiVo's (and other 3rd party devices). I just think their bills are totally unclear and so it makes this confusion that pisses people off.

***although honestly I suspect their inconsistency and confusion and messed up systems benefits plenty of consumers. I moved to cable from sat when the S3 came out. Originally my local provider was a small independent company. Comcast purchased them ~2007 and since then my bill has changed over and again with comcast trying to make our system match their policies. I've also thrown monkey wrenches at them using S3's (2 cards), S2's (analog) , DTA's, and premiers (1 card) . Currently I have an S3 and 2 premiers on my account. Somehow they are not currently charging me any additional outlet fees (although they have in the past), my 4 cablecards are each a dollar, but they credit me 2.50 for each card (not each device since the S3 uses 2). Net result is that I pay for my package and then actually get a credit for having multiple devices on the account.

In short it's a mess.


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## lessd (Jan 23, 2005)

lpwcomp said:


> Where, at any point have I said that there was a maximum price?
> 
> And that is precisely the point - they aren't transparent. Comcast says that the rental cost for the first CableCARD in a device is $0/mo. Nowhere in their information about CableCARDs is it stated or even implied that there is an ADO fee incurred unless it is for your "Primary Outlet"
> 
> If Comcast's CableCARD pricing is transparent to you, then you must be able to leap tall buildings in a single bound 'cause you sure as heck have x-ray vision.


Without any notice Comcast just lowered my 4 cable cards cost from $1.50/card to $1.15/card, I have never paid any A/O charge, but the A/O line is on my bill at $0. I do have an old Cable box from Comcast I don't use but I don't want to wake a sleeping dog by returning that box. I am in the Hartford CT area


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## slowbiscuit (Sep 19, 2006)

This inconsistency with A/O and card fees in different areas is exactly why the FCC should get involved, IMO. Fat chance.


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## slowbiscuit (Sep 19, 2006)

MichaelK said:


> Basically comcast has cobbled together a pile of desperate (sp?) systems and the net result is a confusing mess.


These disparate systems are the problem, and Comcast has had years to get it fixed but nothing happens.

There's no logical reason I can see that a few areas get hit with the bogus 'HD tech fee' with Cablecards, nor why some areas get cards for free, some pay a small charge, and some pay full outlets, other than that Comcast doesn't care about going with a single billing system and set of policies.


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## lpwcomp (May 6, 2002)

MichaelK said:


> I've agreed with you all along on the above point. Basically comcast has cobbled together a pile of desperate (sp?) systems and the net result is a confusing mess. I do think they could do better to be more clear and consistent. But i dont think at all charging an additional outlet fee on digital cable is illegal. Nor do i think they charge it only on TiVo's (and other 3rd party devices). I just think their bills are totally unclear and so it makes this confusion that pisses people off.


Whether or not the ADO fee is legal has always been a side issue. The cost isn't the issue either. It's about the CableCARD regulations and whether or not they are in compliance. They quote one price for CableCARD rental when in reality the true cost is something else. Why it is like that is only relevant to the extent of understanding the difficulty in getting it resolved.

I've been saying for a while now that one of Comcast's problems is that it isn't one tightly integrated corporation. It is a loose confederation of individual fiefdoms. However, this should not resolve them of any responsibility to comply with FCC regulations.


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## lpwcomp (May 6, 2002)

Any new posts I make on the subject of the general legality of the ADO fee will be here. Unless I receive specific authorization from the poster, I will neither quote nor directly refer to any existing posts made in this thread. I will attempt to keep even indirect references to a minimum.

If any _*new*_ posts on the subject are made in this thread, I shall feel free to respond to them in the other thread.

I am not trying dictate the the terms of the discussion in this thread, I am simply doing what I can to return it to its originally intended purpose and use the other, already existing thread (created 04-03-2012, 02:38 PM) for the discussion of the ADO fee in general.


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## pdhenry (Feb 28, 2005)

Except that the OP in that thread is just trying to get the $2.50 COE discount. She doesn't seem to have a problem with the AO fee (post #48 in that thread, for example).


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## lpwcomp (May 6, 2002)

pdhenry said:


> Except that the OP in that thread is just trying to get the $2.50 COE discount. She doesn't seem to have a problem with the AO fee (post #48 in that thread, for example).


Hmm, yeah, looks like she ended up settling for that. And even though the initial post is seeking a total removal of the ADO fee, it was only in relation to a TiVo w/CableCARD.

I'd rather have the two discussions separate and the other thread's title alone seems to make it a better fit for the general ADO fee discussion. Plus I've already received a couple of responses to my latest post. Unless someone strenuously objects over there ( I will ask), I will continue with my semi-hijack in lieu of starting a new thread.


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## MichaelK (Jan 10, 2002)

lpwcomp said:


> Whether or not the ADO fee is legal has always been a side issue. The cost isn't the issue either. It's about the CableCARD regulations and whether or not they are in compliance. They quote one price for CableCARD rental when in reality the true cost is something else. Why it is like that is only relevant to the extent of understanding the difficulty in getting it resolved.
> 
> I've been saying for a while now that one of Comcast's problems is that it isn't one tightly integrated corporation. It is a loose confederation of individual fiefdoms. However, this should not resolve them of any responsibility to comply with FCC regulations.


OK so ADO fee is a side issue.

What exactly is the issue you have if with then and the regs ? The inconsistency?

Since there's plenty of examples of then not charging as much as their own policies would allow I, in my humble opinion, chalk the inconsistancy to incompetence and nothing nefarious.
If the FCC were to 'crack down' on that the end game would be what? Ensuring everyone pays the ADO fees and the corporate charge rates for the cablecards?

As an aside I can chime in that my cobbled up system gets more and more consistant to the party line each year with the annual rate change... at least on paper...


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## lpwcomp (May 6, 2002)

MichaelK said:


> OK so ADO fee is a side issue.
> 
> What exactly is the issue you have if with then and the regs ?


Yes the regs and whether Comcast is in compliance. You yourself said that the monthly cost to use a CableCARD must be transparent. It isn't.


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## Stormspace (Apr 13, 2004)

MichaelK said:


> additional outlet fees are not at all a violation in fact the rules were specifically made to allow it.
> 
> basically cable noticed that Directv and Dish charged "mirroring fees" or whatever they call them now a days and complained that they could not.
> 
> pay the right campaign contributions and presto chango additional outlet fees for DIGITAL content are legal.


Dish based systems can only handle a limited number of streams simultaneously to a residence. Whether this is a technological limitation or other, it in effect forces the customer to purchase additional equipment to connect outlets beyond what the original equipment supports. Cable is different.

From the FCC.gov website



> Under this rule, customers may select who will install their home wiring (e.g., themselves, the cable operator or a commercial contractor). In addition, customers may connect additional wiring, splitters or other equipment to the cable operator's wiring, or redirect or reroute the home wiring, so long as no electronic or physical harm is caused to the cable system and the physical integrity of the cable operator's wiring remains intact.


I'm not a fan of the AO fee and think that it is a scam perpetrated on us by the cable companies because they control the feed of digital information, not because it costs them more to deliver the AO to you.


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## slowbiscuit (Sep 19, 2006)

I don't have a problem with the fee if it covers the box rental, but in Comcast's case it's clearly more of a money grab. It certainly has nothing to do with what they pay the providers for programming, which is a per-subscriber cost.


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## morac (Mar 14, 2003)

While I do think that Comcast uses the AO fee as a work around for the cableCARD laws, I don't think they are violating the rules as written.

Comcast is definitely using the AO fee a work around is because of the pricing restructuring that's been going on the past few years. Originally Comcast charged a per box fee without an outlet fee. This charge was around $4 per SD box, $9 per HD box, $16 per DVR and about 80 cents per remote. At some point Comcast switched to an outlet service fees which included the SD, HD or DVR box and remote equipment rental fees. The later were originally priced at about $2, $5 and $9 respectively. Every year or so Comcast lowers the rental fee for the HD/DVR box and remote. Currently according to my latest bill the rental fee for any Comcast box (SD, HD or DVR) is $2.15 and the remote is 20 cents. So the total equipment charge is $2.35 per box regardless of what that box is. I doubt a SD converter costs Comcast the same as a HD converter costs the same as a DVR, but they charge the same rental price for them. The customer owned device credit is based off of Comcast's equipment rental fees so the current credit in my area is $2.50 per customer owned box (I'm not sure where the extra 15 cents comes from).

At this point in my area the service fees per outlet are $9.25 for HD and $16.25 for DVR Service. Both of those require a HD Technology Fee of $9.25 according to my latest bill which I'll attach. So basically Comcast moved the fees from equipment rental to service. The net price for someone renting boxes from Comcast is the same, but the price goes up for anyone who has their own box. That's basically equivalent of Disney lowering their food pass rates and raising their park entrance fees.

There's nothing in the regulations that says Comcast can't set their service fees to whatever they want, only that they have to show the equipment rental charges on their rate sheet (they are) and they can't charge customers extra for using their own devices as opposed to equivalent Comcast rented boxes (they aren't). The DTA is not the same as a CableCARD since the DTA only gets a limited subset of channels. If Comcast ever deploys a HD DTA (which they want to do but are currently prohibited from doing so by the FCC), then that argument might change depending on how much Comcast charges for it.

Personally, I'm not paying any outlet fees. There weren't any when I originally signed up in my area and they never added any to my account. One additional outlet fee was added to my account about two years ago because of an automatic audit, but I managed to get it removed because of the wording of the price sheet which at the time called the charge a Additional Digital Converter Outlet Fee. I told them I had no digital converters and they removed the fee. Even now I think I could argue away the fees since my bill states the Digital Additional Outlet Service fee requires an HD Technology Fee and that fee requires a digital converter according to the rate sheet.


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## lpwcomp (May 6, 2002)

morac said:


> While I do think that Comcast uses the AO fee as a work around for the cableCARD laws, I don't think they are violating the rules as written.


The rules require that the monthly CableCARD rental cost be accurate. In order for you to think that Comcast is in compliance, you have to believe that it is valid for Comcast to separate rental cost from use cost or that it is obvious that a consumer will incur both costs.


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## morac (Mar 14, 2003)

lpwcomp said:


> The rules require that the monthly CableCARD rental cost be accurate. In order for you to think that Comcast is in compliance, you have to believe that it is valid for Comcast to separate rental cost from use cost or that it is obvious that a consumer will incur both costs.


As you can see from my posted rate sheet, Comcast breaks apart the equipment charges from the service charges. If someone doesn't bother to read the rate sheet, I don't see how Comcast can be blamed for that. I don't agree with the charges (as I mentioned above the equipment charges are too low and the service charge is too high), but Comcast is listing them.


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## lpwcomp (May 6, 2002)

morac said:


> As you can see from my posted rate sheet, Comcast breaks apart the equipment charges from the service charges. If someone doesn't bother to read the rate sheet, I don't see how Comcast can be blamed for that. I don't agree with the charges (as I mentioned above the equipment charges are too low and the service charge is too high), but Comcast is listing them.


So you're saying the average consumer is supposed to know that:

1. the CableCARD rental fee does not include the full cost of actually using it;

2. despite the name, it is not really an additional digital outlet but simply authorizes the use of your own or rented equipment at an existing outlet;

3. a CableCARD device that is not the primary device on the account will specifically require the payment of the additional digital outlet fee despite the fact that the only time this fee is mentioned on the rate card is in conjunction with the rental of one of their boxes;

and that this thereby meets the requirement that the CableCARD rental fee be accurate (the notes from the hearings indicate that it is also supposed to be transparent)?

Further, do you really think that the rental costs for their STBs and DVRs quoted on the rate card accurately reflect the true cost to Comcast of providing that equipment (also a requirement)?


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