Consumers, Big Media companies, and the K Street elite are flooding the FCC with comments today ahead of its deadline for people to weigh in on its important — and controversial — effort to promote competition for TV set-top boxes. The agency has already received nearly 25,800 comments over the last 30 days.

What distinguishes today’s filings is the passion behind the arguments. The FCC is considering a rule that would require cable and satellite companies to come up with at least one form of downloadable security software and license it to others on “reasonable and non-discriminatory terms.”

Supporters say that consumers would benefit from lower prices, easier ways to access Internet-delivered programming as well as traditional pay TV, and innovative interfaces. Opponents warn that independent manufacturers might violate copyrights, degrade the consumer experience (for example by overlaying their own ads), and open opportunities for piracy.

Earlier today the MPAA and other Hollywood groups registered their opposition to the FCC’s consumer initiative. Here’s a sample of other comments filed before the deadline:

Writers Guild of America, West

[The FCC proposal]  would even the playing field between content affiliated with the current gatekeepers and independent sources, promoting competition in programming and enhancing offerings to consumers. …Only a few of the hundreds of networks [that cable and satellite companies] offer serve diverse communities or incorporate programming that is produced with a staff that is as diverse as the American TV audience. By lowering the barriers to accessing television viewers, set-top box competition would increase the ability of diverse content to reach a wider audience.

Incompas (trade association for Internet providers including Amazon, Facebook, and Google)

In the absence of competition, [pay TV distributors] have used [their] monopolistic power to stifle innovation and require their customers to pay an exorbitant monthly fee to rent a device that only evolves as and when they choose….[Cable] customers are currently forced to lease their set-top boxes (at an average cost of $7.43 per box per month), even after the cable systems have recovered the cost of the device.

21st Century Fox, A&E Television Networks, CBS, Scripps Networks Interactive, Time Warner, Viacom, Walt Disney

[The FCC proposal} would require that content provided today to existing distributors under detailed licensing agreements be distributed to a new group of both device manufacturers and app developers, none of which would be bound by any commitments to protect and secure content. By inviting third parties to aggressively seek to profit from the Content Companies’ investments without incurring any of the obligations that effectively safeguard and thereby promote the creation of valuable programming today, the Commission’s proposal reduces the incentives to continue to create the great programming that consumers enjoy.

Dish Network

Today, when a Dish subscriber seeks help with a technical issue, Dish knows exactly what set-top box equipment the subscriber has and can efficiently walk through an appropriate diagnostic regime to resolve the problem. Dish will not be able to support a proliferating range of navigation devices from manufacturers with which, by definition, it has no relationship. Yet, most consumers will likely call their [pay TV provider], and not the third-party manufacturer, when problems occur.

Comcast/NBCUniversal

Faced with fierce competition, providers are intent on giving consumers the flexibility they demand to access video programming on the devices of their choice, and delivering more value to customers. Comcast is responding to this dynamic marketplace in a number of ways, including with its innovative award-winning Xfinity TV platform and enabling access to that platform on a growing array of devices….This trend is bound to accelerate – in the absence of any government regulation – as consumers and the marketplace continue to drive this apps-based revolution.

Grover Norquist, Americans for Tax Reform

The marketplace for video devices and services is already functioning well, and the goal of increasing consumers’ choice for video devices is already being realized in the marketplace. There is simply no need or justification for an anti-competitive mandate
such as the one the Commission is considering.