The American Cable Association submits these comments to stress the burden that the Commission’s proposed 70/70 reporting requirements will have on small and medium-sized operators, and to suggest alternatives means of collecting and submitting this data. The Commission’s proposed reporting requirements – especially those requiring historical data for subscribers served and homes passed, and an accounting of homes receiving services under a bulk rate – will impose significant financial and administrative burdens on ACA’s members who serve smaller markets and rural areas. Accordingly, the Commission should carefully consider whether there are less onerous ways for small and medium-sized cable operators to provide the data. To that end, ACA suggests the following revisions to the 70/70 reporting requirements:
(i) The Commission should permit systems with 20,000 or less subscribers to provide current data on customers served and homes passed, and best estimates on homes passed when necessary.
(ii) The Commission should exempt systems with 20,000 or less subscribers from collecting data on unoccupied homes and bulk units.
Attachment:090217 ACA Comments MB Dkt No 07-269 FINAL