The American Cable Association ("ACA") submits these Comments in response to the Notices of Proposed Rulemaking seeking comment on proposed amendments to the Commission's ex parte, procedural, and other rules.

ACA commends the Commission for initiating rulemakings that seek to "make the Commission's decisionmaking processes more open, transparent, and effective," and intended to "increase efficiency and modernize [the Commission's] procedures, enhance the openness and transparency of Commission proceedings, and clarify certain procedural rules." In order to better ensure openness, transparency, and increased efficiency in Commission proceedings, ACA recommends that the Commission amend its ex parte and procedural rules by:

• Providing parties two business days to submit ex parte notices after conducting an oral ex parte presentation, except the agency should maintain the one business day requirement in rulemaking proceedings after the reply comment deadline expires;
• Narrowing the Sunshine period exception to prohibit an outside party from soliciting a request from staff for an ex parte presentation "for the clarification or adduction of evidence, or for the resolution of issues"; and
• Generally requiring electronic filing of written ex parte presentations in docketed proceedings, as well as enhancing the role of ECFS in Commission proceedings.