condominiums, neighborhoods, and other homeowner associations tightly restricted their use, except in areas where such restrictions were illegal. These restrictions were altered in 1986 when the Federal Communications Commission ruled all of them illegal. A municipality could require a property owner to relocate the dish if it violated other zoning restrictions, such as a setback requirement, but could not outlaw their use. The necessity of these restrictions would slowly decline as the dishes got smaller. Originally, all channels were broadcast in the clear (ITC) because the equipment necessary to receive the programming was too expensive for consumers. With the growing number of TVRO systems, the program providers and broadcasters had to scramble their signal and develop subscription systems. In October 1984, the U.S. Congress passed the Cable Communications Policy Act of 1984, which gave those using TVRO systems the right to receive signals for free unless they were scrambled, and required those who did scramble to make their signals available for a reasonable fee. Since cable channels could prevent reception by big dishes, other companies had an incentive to offer competition. In January 1986, HBO began using the now-obsolete VideoCipher II system to encrypt their channels. Other channels uses less secure television encryption systems. The scrambling of HBO was met with much protest from owners of big-dish systems, most of which had no other option at the time for receiving such channels, claiming that clear signals from cable channels would be difficult to receive. Eventually HBO allowed dish owners to subscribe directly to their service for $12.95 per month, a price equal to or higher than what cable subscribers were paying, and required a descrambler to be purchased for $395. This led to the attack on HBO's transponder Galaxy 1 by John R. MacDougall in April 1986. One by one, all commercial channels followed HBO's lead and began scrambling their channels. The Satellite Broadcasting and Communications Association SBCA was founded on December 2, 1986, as the result of a merger between SPACE and the Direct Broadcast Satellite Association (DBSA). Videocipher II used analog scrambling on its video signal and Data Encryption Standard based encryption on its audio signal. VideoCipher II was defeated, and there was a black market for descrambler devices, which were initially sold as "test" devices. Late 1980s and 1990s to present By 1987, nine channels were scrambled, but 99 others were available free-to-air. While HBO initially charged