I.                   Introduction.

ACA submits theseComments in support of Trust Cable TV, Inc. and Trust Cable of Mississippi,Inc.'s ("Trust") Retransmission Consent Complaint and Request for Stay("Complaint").

Broadcasters use theirmarket power and bad faith bargaining tactics to extract unreasonableretransmission consent terms and conditions from small cable operators. And ifsmall and medium-sized cable operators want to bring a complaint over thisbroadcaster behavior, no mechanism exists to permit the cable operator tocontinue carriage during the pending complaint. ACA has consistently documentedthis problem at the Commission. To protect the continued viability of small andmedium-size cable operators, ACA recommends that:

• The Commission permit cable operators to carry a broadcast station during a pending complaint, and grant Trust's Request for Stay; and

• The Commission enforce its objective standards of good faith, and grant Trust's Complaint.

American Cable Association. ACA represents nearly 1,100 independent cable companies that serve more than 8 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.

Attachment	Size
081016 ACA Comments in Support of Trust.pdf	145.32 KB