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March 14, 2009

FCC Reply Comments regarding the "70/70" Cable Subscribership Survey

I. Introduction

ACA members, especially those serving small and rural markets, face significant burdens to complete the Commission’s proposed 70/70 reporting form. ACA files this Reply to highlight the overwhelming support on the record for reducing the reporting burdens for small and medium-sized cable operators. Nearly all commenters recognize that the Commission must decrease its reporting burdens. Moreover, in this Reply:

(i) ACA supports proposals on the record that the Commission should collect only current data.

(ii) ACA opposes Free Press’ overreaching request to require cable operators to submit telephone, digital, and cable modem data.

Attachment:ACA Reply MB Dkt No 07-269 031309 final