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OMB Paperwork Reducation Act Comments re: Leased Access

Submission Date: 
05/28/2008
I. Introduction

In February 2008, the FCC released an order mandating new and highly
burdensome information collection requirements for commercial leased access ("New
Requirements").1 The New Requirements violate the Paperwork Reduction Act ("PRA")
and the OMB's regulations2 for a number of reasons, including:

• The FCC did not make efforts to reduce the burden of the New Requirements
for small business concerns; and
• The FCC grossly underestimates the burden of the New Requirements on
small and medium-sized cable operators.

Accordingly, the American Cable Association ("ACA") requests that the OMB
disapprove the New Requirements. In addition, ACA strongly supports the comments of
the National Cable & Telecommunications Association ("NCTA") and Comcast
Corporation ("Comcast") filed earlier in this docket. 3
AttachmentSize
ACA OMB leased access comments 052808 final.pdf49.16 KB

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