The American Cable Association ("ACA") hereby responds to the Media Bureau's Public Notice seeking suggestions for additional studies in the media ownership proceeding. As the Commission begins its comprehensive assessment of the efficacy of its
media ownership rules to achieve the core policy goals of competition, diversity and localism, it must take into account the impact of retransmission consent negotiations on local markets.

     As part of its media ownership proceeding, ACA urges the Commission to study: (i) to what extent the level of competition in a broadcast television market is reduced when one broadcast station jointly negotiates retransmission consent on behalf of another station in the same market; (ii) the impact this reduced competition has on both the quality and quantity of local programming produced in the market; and (iii) the fees charged to cable and satellite TV operators to retransmit broadcast signals to consumers. In particular, the Commission must examine:

• The present number of instances, and historical trends of broadcasters negotiating retransmission consent on behalf of another station in the same DMA, including the number of instances involving two or more of the four national broadcast ("Big 4") networks.
• The prevalence of joint retransmission consent negotiating arrangements through:
  • Sharing agreements (i.e. , one station controls another station in the same market, such as through a Shared Services Agreement ("SSA") or Local Marketing Agreement ("LMA");
  • Duopolies (i.e., one entity owns more than one station in the same market); and
  • Multicast Duopolies (i.e., one station broadcasts one Big 4 network on its primary video stream and another Big 4 network on its multicast stream).
• The impact of joint negotiations for retransmission consent among broadcasters in a single DMA on the quality and quantity of local programming offered in the market, including an analysis of the local programming offered by broadcasters both before and after entering into such arrangements.
• The impact of broadcasters negotiating retransmission consent on behalf of another station in the same DMA on the prices charged to multichannel video programming distributors ("MVPDs") for retransmission consent rights.