I. Introduction and Summary.
ACA submits these Comments to recommend that the regulatory fee process accommodates the unique needs of smaller cable companies. For many smaller cable companies, 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 supports the following Commission proposals:
Continuing these policies will help small and medium-sized cable operators keep administrative burdens and costs low. Moreover, to better accommodate the unique needs of various small cable operators, ACA proposes that the Commission send fee ssessment letters via surface mail to cable operators that serve fewer than 5,000 ubscribers.3
The American Cable Association. ACA represents nearly 1,100 independent cable businesses serving nearly 7.5 million cable subscribers primarily in smaller markets and rural areas. ACA member systems are located in all 50 states and in virtually every congressional district. ACA members range from family-run cable businesses serving a single town to multiple system operators that focus on smaller systems and smaller markets. About half of ACA's members serve less than 1,000 subscribers.
For many of ACA's members, keeping up with the numerous filings and fees imposed under the Commission's regulations results in substantial administrative burdens and costs. By adopting the above proposals, the Commission can ease some of the administrative
burdens on smaller cable operators.
1 In the Matter of Assessment and Collection of Regulatory Fees for Fiscal Year 2008, Notice of Proposed ulemaking, MD Docket No. 08-65, ¶ 28 (rel. May 8, 2008) ("NPRM").
2 NPRM, ¶ 29.3 ACA advanced this argument in last year’s regulatory fees proceeding. See In the Matter of Assessment and Collection of Regulatory Fees for Fiscal Year 2007, Notice of Proposed Rulemaking, MD Docket No. 07-81, Reply Comments of the American Cable Association at 3-4 (filed May 11, 2007) (“ACA 2007 Regulatory Fee Reply”).
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