In response to the Commission's proposed changes to its regulatory fee amounts and process, ACA submits these Comments to suggest the regulatory fee process accommodate the unique needs of small cable companies.  For many ACA members, increasing regulatory fees and keeping pace with the deadlines for the many filings and fees imposed under the Commission's regulations results in substantial administrative burdens and costs.  Accordingly, ACA recommends that the Commission:  

• Maintain FY 2008's regulatory fees for cable operators with 5,000 or fewer subscribers;

• Provide notice via email to CARS and Earth Station licensees when pre-bills are loaded into Fee Filer for viewing; and

• Provide cable operators with 5,000 or fewer subscribers a 180-day grace period for FY 2009 CARS and Earth Station regulatory fee payments.