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FCC Comments in Support of Mediacom Communications Corporation

Submission Date: 

I. Introduction.

The American Cable Association ("ACA") submits these Comments in support of Mediacom Communications Corporation's ("Mediacom") Retransmission Consent Complaint and Petition for an Emergency Order Granting Interim Carriage Rights against Sinclair Broadcast Group, Inc. ("Sinclair,,).1 To protect the interests of consumers and ensure the continued viability of small and medium-sized cable operators, ACA recommends that:

• The Commission permit cable operators to carry a broadcast station while a retransmission consent complaint is pending.

• The Commission examine broadcasters' use of LMAs and similar agreements on retransmission consent negotiations.

In these comments, ACA also briefly addresses Sinclair's Opposition. American Cable Association. ACA has a substantial interest in this matter. ACA represents more than 900 independent cable companies, including Mediacom. ACA's membership includes a variety of businesses -family-owned companies serving small towns and villages, multiple system operators serving predominantly rural markets in several states, and hundreds of companies in between. ACA members have invested heavily in rural and small town America, building or acquiring their systems to serve the unique needs of customers in these markets. More than half of ACA's members serve fewer than 1,000 subscribers and typical density for most of the ACA members' markets is 20 homes per mile, compared to hundreds of homes per mile in urban areas. ACA's members do not have significant market-share in anyone designated market area (DMA), and they are not affiliated with any satellite-delivered programming.

ACA comments in support of Mediacom Retransmission Consent Complaint 091118.pdf217.55 KB

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