A story in Bloomberg this week indicates that Comcast is looking to build out its own NBC standalone app, following on the relative success of other networks standalone apps like CBS All Access and HBO Now.We’re of two mind about this—on the one hand, it could help improve the quality of content NBC has on offer and the new service will only add viewers, not cannibalize existing ones for NBC and its affiliate networks like SyFy and Bravo.On the other hand, launching a standalone service gets tougher with each new entrant into the market and a standalone NBC service seems like a good way to undermine NBC’s considerable investment in Hulu.Standalone Apps Need To Be “Must-See” TVLet’s start with the basic premise of a standalone service: people are going to want to watch what it’s showing enough to actually pony up money for a subscription. And for a broadcast network, that means there are going to be ads, so potential subscribers are going to have to really want to see that programming if you want them to sign up.That means NBC is going to need to step up their game and invest in some “must-see TV” so that what’s on the app is at the same level of “I need to see it”-ness as an HBO or Showtime is and that will require a major investment on NBC’s part. (NB: Adding in shows from SyFy and Bravo is not the answer.)NBC Has Limited Experience Building An Audience From ScratchThat leads to dilemma number two: NBC’s only experience launching a service and growing its subscriber base has been Seeso, their comedy SVOD channel, which benefitted from some big name comedy acts, a low price, and the fact that it had a rather unique content offering.NBC’s new app won’t have any of those advantages. But more than that, NBC is going to have to work that much harder to convince consumers to part with an extra five to ten dollars a month when, for just $6/month, they can get a subscription to Hulu and get all off NBC’s programming, plus ABC’s, Fox’s and Time Warner’s programming, plus originals.What About Hulu?It’s going to be interesting to watch and see just how NBC deals with Hulu once they launch their own standalone app, given that said app will be competing directly with Hulu, which NBC owns jointly with ABC, Fox and Time Warner. If it starts to pull subscribers from Hulu, that would seem to be a good way to really piss the other three networks off.And since $11/month gets you ad-free Hulu, we’re wondering how NBC handles that as well—will they pull NBC’s programs from Hulu once they launch the new app? Lengthen the window before they’re available on Hulu? Hope that enough people subscribe to their app for the exclusive content so as not to interfere with Hulu?One thing CBS had going for them is they are not a part of Hulu, so their shows were not available anywhere else. NBC will need to figure out how to handle that conflict, and explain it to their partner networks if they want both to succeed.Did NBC Miss Out On First Mover Advantage?Our other concern with the NBC app though is that they’re coming in too late and will need a product that makes the extra investment worth it. Cord cutters/nevers have already likely invested money in HBO Now, Showtime, Netflix, Amazon, Hulu, CBS All Access and NBC’s Seeso. Add all those together and you’re paying something close to what you’d pay for the top-tier pay-TV package. And, since much of the NBC content is already available via Hulu, getting people to pay extra for a new NBC app is a big ask.TV Everywhere And Skinny BundlesThen there’s the fact that the MVPDs are all busy pushing out both TV Everywhere apps for their subscribers and standalone skinny bundle apps for everyone else, both of which allow users to watch NBC’s current programming, most of which also provide DVR service. (Users in areas where the NBC station is an affiliate rather than an O&O will not be able to watch NBC live via the skinny bundle OTT services, so there may be an opening for NBC there … if the app can provide live broadcasts.)The Comcast IssueFinally, there's the Comcast issue—it's unclear what exactly the rules are here for Comcast to launch this sort of app, what's allowed, what's prohibited. While Ajit Pai's FCC appears to be pretty laissez-faire about these sorts of conflicts, the other networks will surely object and the various legalities will have to be figured out, which can easily delay the launch.NBC has some significant hurdles in front of it if it wants to make a standalone app work, and we’re waiting to see if they make some smart moves (like high quality exclusive programming) that will make people want to take that leap. It’s a big hill to climb for NBC as they’re arriving late at the party, but with the right mix of marketing and programming, success is not impossible. Though at this point, it seems improbable.