I. Introduction
ACA opposes the Commission’s proposal to raise the pole attachment rate for broadband services provided over a cable television system.1 Raising the cable broadband attachment will accomplish nothing more than raising costs for smallermarket and rural consumers and impeding broadband deployment in their communities. Moreover, there is no valid statutory or policy basis for raising the cable broadband attachment rate. For these reasons, ACA strongly supports the comments filed by the National Cable & Telecommunications Association (“NCTA”), Charter Communications, Inc., the Mississippi Cable Telecommunications Association, and the State Cable Associations.

About ACA. ACA represents nearly 1,100 small and medium-sized cable companies that serve more than 7 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. The companies range from family-run cable businesses serving a single town to multiple system operators that focus on serving smaller markets. More than half of ACA's members serve fewer than 1,000 subscribers. All ACA members face the challenges of upgrading and operating broadband networks in lower-density markets.