"Providing the historical data being sought by the Commission will be impossible for many smaller cable systems, and very expensive and time consuming for others," said ACA President and CEO Matthew M. Polka. "ACA and its members urge the Commission to permit smaller systems that do not maintain historical subscriber and homes passed data to provide current data, and allow systems that do not track homes passed data at all, to submit their best estimates. Small and medium sized operators are not opposed to submitting data and information that the FCC deems necessary, but urge the Commission to consider alternative methodologies to avoid requiring systems to provide data that is impossible to supply, or would require financial and administrative resources that are just not available."
In yesterday's filing, ACA specifically calls on the Commission to carefully reconsider the burdensome reporting requirements that are imposed on smaller cable systems through the proposed"70/70" cable subscribership survey. As a less onerous alternative, ACA suggests permitting systems with 20,000 or less subscribers to submit current data for homes served and passed, and best estimates for homes passed for systems that do not track this information. ACA also asks the Commission to exempt systems of this size from having to account for unoccupied homes passed and unoccupied units in bulk billed multiple dwelling units (MDUs).
The proposed cable
subscribership survey, outlined by the Commission in a Notice of
Proposed Rulemaking (NPRM) released
on January 16, 2009, would require cable operators to provide the following
information for the years 2006 and 2007:
- Total number of homes the cable operator currently passes;
- Total number of homes the cable operator currently passes with 36 or more activated channels;
- Total number of actual subscribers, including all subscribers in Multiple Dwelling Units (MDUs); and;
- Total number of subscribers with 36 or more activated channels.
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About the American Cable Association
Based in Pittsburgh, the American Cable Association is a trade organization representing 1,100 smaller and medium-sized, independent cable companies who provide broadband services for more than 7 million cable subscribers primarily located in rural and smaller suburban markets across America. Through active participation in the regulatory and legislative process in Washington, D.C., ACA's members work together to advance the interests of their customers and ensure the future competitiveness and viability of their business. For more information, visit www.americancable.org.
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