I. Introduction

ACA submits these reply comments in support of the National Cable & Telecommunications Association's ("NCTA") Comments in this proceeding.  As explained in NCTA's Comments:[1]

No basis exists to require cable operators to report each multicast stream separately on each Statement of Account.

No basis exists to accord a different status to multicast streams where the analog signal is permitted, significantly viewed or grandfathered.

No basis exists for the Copyright Office to eliminate a station's signal strength as a method for determining whether a station is local.

Moreover, the Copyright Office's proposals would require additional payment for the same stations cable operators already carry, add multiple layers of complexity, and impose new and expansive reporting burdens.[2]  As explained in NCTA's Comments, the overriding goal of the Copyright Office should instead be to adopt rules and policies that facilitate a smooth transition to digital by preserving the status quo to the greatest extent possible.  Accordingly, the Copyright Office must discard these proposals.

American Cable Association.  ACA represents nearly 1,100 small and medium-sized cable companies that serve about 7 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

[1] Digital Signals NPRM, Comments of NCTA at 6 (filed July 31, 2008) ("NCTA Comments").

[2] The Copyright Office has continually recommended that Congress should simplify the cable compulsory license and reduce administrative burdens.  See Review of the Copyright Licensing Regimes Covering Retransmission of Broadcast Signals, A Report of the Register of Copyrights, August 1, 1997, at 41; Satellite Home Viewer Extension and Reauthorization Act, Section 109 Report, A Report of the Register of Copyrights, June 30, 2008, at 106.