I. Introduction.

In numerous filings, ACA has shown the critical need for low-cost set-top boxes to be available to small and medium-sized cable operators.  Such devices would allow these independent video distributors to upgrade their systems to all-digital platforms and deliver advanced services to their customers. such as more high definition ("HD") programming choices, and broadband speeds with the potential to approach 100 Mbps.

For the reasons set forth below. ACA strongly supports Cable ONE's novel Request for Waiver of 47 C.F.R. §76.1204(a)(1) to deploy low-cost, one-way, integrated HO-capable all-digital devices ("HD ADDs") in its Dyersburg, Tennessee area cable system, and urges the granting of Cable ONE's Request for Waiver on an expedited basis.

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 nearly every congressional district. The companies range from family-run cable businesses serving a single town to multiple-system operators that focus on serving smaller 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.

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ACA Comments in Support of Cable ONE's Request for Waiver.pdf	131.13 KB