I. Introduction and Summary.

The American Cable Association ("ACA") and its members oppose placing new Automated Reporting Management Information System (ARMIS) reporting requirements on competitive phone and broadband providers, particularly small and medium-sized cable providers. The Commission already collects substantial amounts of data from telecommunications and broadband providers, and has failed to show the need for imposing these additional reporting requirements on these operators.

For small and medium-sized cable operators, the additional reporting obligations proposed in the Notice of Proposed Rulemaking ("NPRM") would add to their challenges in providing affordable advanced services - including phone and broadband with speeds that could reach 100 Mbps - to the smaller markets and rural areas they serve. ACA urges the Commission to carefully consider whether the anticipated benefits of its new reporting requirements outweigh the potential for these obligations to impede the deployment of these vital services to unserved and underserved areas, and if so, whether there are less onerous ways to collect the data sought from these operators.

The market for telecommunications and broadband services is very competitive. As such, any information collected pursuant to new ARMIS reporting obligations must be kept confidential by the Commission.

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ACA ARMIS File 121508.pdf	41.28 KB