I. Introduction
The American Cable Association (“ACA”) files these comments in response to
the FNPRM in the above-referenced docket.1 ACA strongly supports the Commission’s
efforts to obtain accurate broadband deployment data. That said, additional reporting
obligations add to the challenges that ACA’s members face in bringing affordable
advanced services to smaller markets and rural areas. The Commission’s proposed
reporting requirements – especially those involving census tract and address-by-
address information – will significantly add to the cost of serving subscribers in these
low-density areas. Accordingly, ACA files these comments to bring to the Commission’s
attention the burden and accuracy issues related to the Commission’s proposed
reporting requirements. The Commission should carefully consider whether the
anticipated benefits of its proposed reporting requirements outweigh the potential for
these obligations to impede broadband deployment in hard-to-serve areas, and if so,
whether there are less onerous ways for small and medium-sized cable operators to
provide the data that the Commission seeks.

About ACA. ACA represents nearly 1,000 independent cable companies that
serve about 7.5 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.