I have some concerns with this and redefining MPVD. First and foremost, regulation equals cost. This extra cost could defeat the purpose of doing this on the internet, or at least make it way more expensive than it is now. If costs are too high you eliminate the innovation, creativity and options available since you knock small startups and independents out of the game before it starts.
What is a MPVD? 1 channel? 2? 20? Private systems too? How does the designation help or hurt each size range? Does the designation become a requirement and if so what are the criteria?
What is going to happen is that internet MPVD's and channels become "regulated". Dish, DirecTV, Comcast and other traditional providers then say, "we have to comply with all sorts of regulations and requirements because we are MPVD. All the little guys need to as well. So this leads to closed captioning requirements, minimum E/I content hours, must carry etc.In the end this could be so heavially regulated that everyone is pushed out of the business except Dish, Direct, Comcast and the other traditional big names.
This whole proposal is a slippery slope. It might start out looking ok and well intentioned but it won't end that way. It is going to be bad for small business, independent artists/channels/content and the consumer. The government needs to keep their hands off the damn internet!!!!