|19||The 10th Annual Independent Show|
|3||Quarterly Telecommunications Reporting Worksheet - Form 499A|
|31||Copyright Statement of Accounts|
|1||Local Telephone Competition and Broadband Reporting - Form 477|
|30||Annual EEO Report - Form 396-C|
ACA's filing made a number of important proposals to reduce the administrative burdens on cable systems with 20,000 subscribers or fewer from some of the more onerous aspects of the FCC's survey, which is seeking annual data from three years ago that many small cable companies simply may not possess.
"The FCC should exempt small cable companies from elements of this far-reaching, industry wide survey because it exacts too high a compliance cost," ACA President and CEO Matthew M. Polka said.
The FCC's survey would, for instance, require all cable operators to submit business data for years 2006 and 2007. ACA called on the FCC to focus on the collection of the most recently available information.
"Many, many ACA members are small businesses that simply do not maintain historical records on the data sought by the FCC, particularly the number of housing units they pass," Polka explained.
If the FCC insists on collecting historical data, ACA said the Commission should be willing to accept "best estimates" of homes-passed totals from cable systems with 20,000 subscribers or fewer.
ACA's filing also urged the agency to reject a proposal by consumer group Free Press that all survey data be made public, including competitively sensitive information that small cable companies do not routinely share with others.
"If the FCC released an ACA member's penetration rate in a certain market, pay-TV competitors could better facilitate targeted promotional offerings in that ACA member's service area," Polka said.
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About the American Cable Association
Based in Pittsburgh, the American Cable Association is a trade organization representing more than 900 smaller and medium-sized, independent cable companies who provide broadband services for more than 7 million cable subscribers primarily located in rural and smaller suburban markets across America. Through active participation in the regulatory and legislative process in Washington, D.C., ACA's members work together to advance the interests of their customers and ensure the future competitiveness and viability of their business. For more information, visit www.americancable.org.
|031609 FCC modification.pdf||52.89 KB|
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