I.     Introduction

            The American Cable Association ("ACA") submits these Reply Comments in support of the Comments filed in this Docket by the National Cable & Telecommunications Association ("NCTA").  The Commission should impose a uniform subscriber-based regulatory fee on all MVPDs, including DBS providers.

American Cable Association.  ACA represents nearly 1,100 independent cable companies that serve more than 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 businesses serving a single town to multiple system operators that focus on serving small markets and rural areas.  More than half of ACA's members serve fewer than 1,000 subscribers.