SCTE member since 1980

Title: Attorney and Counselor at Law, Kramer Telecom Law Firm, and principal, Kramer.Firm Inc.

Broadband Background: Kramer has been involved with the cable TV industry for nearly 30 years, beginning his career in engineering operations, but transitioning to consulting in 1984. Kramer and his team serve as technical advisors and cable system inspectors for nearly 600 governments. Kramer was elevated to the status of SCTE Senior Member in 1993, and he’s an elected Fellow of the UK’s SCTE. He’s a member of the SCTE’s Loyal Order of the 704. He served as the government co-chair of the Joint Task Force on Technical Standards, which helped the FCC develop the current cable technology standards governing analog cable TV delivery. Earning a Juris Doctor degree (with honors) in 2001, he was admitted to the State Bar of California in 2006.

You’ve heard from quite a few people about your bonding article in CT’s October issue. Were you surprised by the response?

Not really. Bonding is one of the reoccurring core issues in our business. It seems like such a simple thing, yet ‘doing it right’ requires a level of craft-skill and knowledge of the NEC that takes many months, or longer, to truly master. Once mastered, it takes a corporate and personal commitment, coupled with a conscientious effort to continue to focus on proper bonding, to protect the public and the plant.

Your article contains numerous examples of poor (or no) grounding. How common a problem is this?

My staff of inspectors (headed by Steve Allen) and I have evaluated plant in more than 30 states and on behalf of more than 500 governments over the past 23 years. Bonding to the Code requirements, including all of the elements that go beyond simply connecting two ends of a wire, has been a significant issue. Even today, the majority of large and small systems we inspect rarely exceed 50 percent compliance. It’s interesting to note that a condition of some of the Adelphia/Comcast/Time Warner transfers in Southern California was that Time Warner brings its purchased plant into at least 90 percent compliance with the NEC. They proved it can be done. It takes commitment and focus, but the payoff is in enhanced safety (which the defense lawyers and cable installers and techs like), and better quality and more reliable plant (which cable managers and the subscribers like).
Do violations seem to be increasing or decreasing? How has the advent of cable telephony (with its attendant high voltages) affected this?

We’re not really seeing increases in non-compliance, but we’re not seen any dramatic decreases either. This is a continuing problem in most systems.

When you do find violations, what seems to be the root cause? Insufficient training or supervision? Laziness? Something else?

Insufficient training as to all of the Code requirements is clearly at the heart of the problem. A lack of route time to deal with bonding issues is a close second. While many systems have moved away from the concept of ’32 unit’ days, there still doesn’t seem to be enough time to deal with non-compliant or non-existent bonding.

In reference to your article, we heard one VP of tech ops wondering out loud whether countries with less stringent codes actually have any more electrical incidents than we do in the U nited States. Any evidence there? (Are we over-regulated?)

Are we ‘too safe?’ No. Some countries don’t reference their electrical systems to ground, so in some cases common bonding isn’t necessary or even safe. And gauging relative safety by the number of reported electrical incidents is misleading. In regard to cable TV, the NEC has been repeatedly revised and expanded over the past 50 years to respond to changes in technology and to deal with newly uncovered safety hazards. The NEC is a product of a very independent engineering committee subjected to an open and transparent process. In many ways, the refinement of the NEC over the decades is far superior to the ‘sausage making’ that is a hallmark of how laws are usually created.

Back to franchises, has the telco entry into video really changed the landscape there? What do you see three to five years out from the regulatory front?

Telco entry into video is a direct response to cable’s move into dial tone over a decade ago. The conservative telcos took a long to come to the video party, but now that they have, they face a bet-the-technology choice: ‘To Fiber, or Not to Fiber, that is the question;’ (with apologies to Mr. Shakespeare). Verizon’s FiOS system, with its fully passive FTTH architecture, is technically elegant but expensive. AT&T’s Project Lightspeed/Uverse offering is akin to putting a supercharged engine in a jalopy, hoping that the wheels won’t fall off from all that friction. Cheaper only in the short run, but technical limitations make it obsolete from day 1. Even AT&T seems to realize that their copper should be retired given that they will only serve new "greenfield" developments with FTTH. Somewhere in between FTTH and twisted-pair is cable’s nimble fiber-to-the-node architecture.

But the real 5-year zinger out there isn’t the plant; it’s switched video and menu-driven channel selection. Switched video will become the standard transmission scheme because it effectively offers unlimited channel capacity. If you can get a channel to the headend, you can get it to any subscriber regardless of the underlying system bandwidth. On-screen layered menu systems for channel selection are absolutely necessity for switched video systems. These two elements together open the door to what I call ‘Everycasting.’ I expect the FCC to step in and require all multi-channel video providers to go all digital within two or three years and the market to standardize on switched video menu-driven offerings. Channel numbers will be history. Set-top boxes will be de rigueur. And the hot ticket will be placement of your channel on the first levels of the menu system.

Finally, local franchising will be dead within five years. This only helps the telcos and hurts consumers by moving the oversight of video services to a remote government bureaucracy. 

There are folks on the operator side who resent your work on behalf of franchises. Do you think you’ve gone to the dark side?

Those who do fail to grasp the most basic of concepts, summed-up in the old saying: "People do what you inspect, not what you expect." I’m nearing my 30th anniversary in cable engineering. My cable carrier started on the industry side and has included working for both MSOs and mom-and-pop operations. I worked my way up to being a regional engineer before going to what I simply call ‘the other side.’  When I was in system and regional operations, I had some of my systems inspected by government consultants who were barely qualified to operate a set-top remote control, much less competently evaluate the technical and plant operations of my systems.

Working as a government inspector over the past 23 years, and now as a telecom attorney for governments, I’ve always remembered that you have to know what you’re inspecting and that the honorable end game is to strive for steady improvements and mutual understanding rather than a scorched earth outcome.

What trends are you following on the wireless side of the aisle?

The telecom industry was once marked by sharp edges of demarcation. Telcos provided dial tone; cable provided video; cellular provided mobile phone services. Today, the sharp edges are gone, and we all live on the surface of a gentle curve. Where one service segment ends and another begins is difficult to spot. Wireless is a great example of this grand blurring.

Wireless carriers are now installing nano-cell technology in individual homes using cable modems and DSL to provide backhaul. Cable is partnering with cellular and PCS carriers to offer quad-plays and provide fiber connectively to macrocell sites. The next big thing for cable will be providing WiFi and WiMax services using the existing outside plant for backhaul. And the truly smart cable operators will coordinate their activities with their traditional partners, local governments.

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