I. Introduction

ACA recommends that the Commission adopt an exemption from the requirement to carry broadcast signals in digital format post-DTV transition for cable systems with (i) 5,000 or fewer subscribers, or (ii) less than 552 MHz capacity. These systems should be able to comply with must-carry obligations by converting must-carry signals to analog and distributing them to all basic subscribers. In support of the requested relief, ACA provides the Commission with additional information on the cost for small cable operators to comply with the digital carriage requirement, and the related capacity constraints. ACA also responds to the Commission’s inquiry on the applicability of its material degradation rules to retransmission consent stations. In short, the material degradation rules should not be applied to retransmission consent stations.

About the American Cable Association. ACA represents nearly 1,100 small and medium-sized cable companies that serve more than seven million cable subscribers, primarily in smaller markets and rural areas. ACA member systems are located in all 50 states, and in virtually every congressional district. The companies range from family-run cable businesses serving a single town to multiple system operators with small systems in small markets. More than half of ACA's members serve fewer than 1,000 subscribers. All ACA members face the challenges of upgrading and operating broadband networks in lower-density markets.

Attachment	Size
Carriage of Digital Television Broadcast Signals Amendment to Part 76 of the Commission's Rules 030208.pdf	966.63 KB