There is an interesting debate unfolding at the FCC surrounding the definition of video service provider, or as the FCC officially labels them, multichannel video programming distributors (MVPDs). The debate is being ignited over the FCC’s Allvid inquiry, which aims to stimulate competition between the growing stable of retail video set-top-boxes like Boxee and Roku, and traditional MVPDs, including cable, IPTV, and DBS.

Specifically the FCC wants to “…explore the potential for allowing any electronics manufacturer to offer smart video devices at retail that can be used with the services of any MVPD and without the need to coordinate or negotiate with MVPDs.” In other words, one goal of the Allvid vision is to allow consumers to buy set-top-boxes or home gateways at retail from any manufacturer and have that STB/gateway ‘plug and play’ compatible with any MVPD provider.

Interestingly enough, DirecTV is posing provocative questions as a result. In a letter to the FCC, DirecTV’s counsel specifically cites Roku, the OTT STB provider, and suggests that Roku might be considered a MVPD, subject to all of the regulations that MVPDs currently adhere to both now, and in any future Allvid ruling.

“If the Commission required MVPDs to make their content available to all AllVid devices on a disaggregated basis, would device manufacturers be given access to Roku’s content from Netflix, Hulu, and Amazon to present any way those manufacturers saw fit? If the Commission formulated an AllVid technology standard, would Roku be required to design a compliant AllVid gateway device capable of passing content through to third-party devices?,” the letter asks.

DirecTV’s stance is indeed interesting. As OTT providers like Netflix and Hulu, and the manufacturers whose equipment delivers their feeds like Roku and Boxee, continue to grow in programming access and popularity, the lines between OTT video and MVPD get blurrier and blurrier every day. Should they be regulated in the same way?

In conclusion, DirecTV asks the FCC to clearly define what an MVPD is before making any Allvid ruling. Such a decision could have significant implications on the competitive landscape as OTT providers and MVPDs are increasingly battling each other for the all important monthly subscription revenue prize.