I am a leased access programmer and I believe the FCC should address various issues of the Leased Access rules.

During my negotiations with the two cable systems my company is own, the negotiation process was absolutely one sided. Neither of the cable systems budged until I quoted chapter and verse of FCC rules and then backed them up with rulings from over the years, I did have items such as administrative fees removed from the agreement.

In addition, there is a ''gag'' order in both of my agreements. I am comfortable with discussing the things I was successful in removing from the agreement, but nothing else.

In one ''negotiation'' it took almost three months to get an agreement. This is wrong, again, I say, wrong. The cable giants use stall tactics in hope programmers will get tired and quit. The FCC should standardize agreements, require rates and subscriber base to be in the public file. This is basic information that should be public knowledge, however, I've never been given a subscriber base total, never!

My equipment, in one cable system, is required to be in the kitchen, the kitchen. Can anyone believe that? We were told we could not place our equipment in a rack in the headend, wow! When I think about it, it still amazes me.

There are many areas in which improvements could be made concerning leased access, such as channel placement. Why would a cable system put the leased access channel on 99 and their local origination channel on 18 next to the public access channel. Could it be its about the revenue. Leased access is competing along side the cable system's, money making local origination channel. The cable industry has been screaming about a ''Level Playing Field'' for some time. How about the same ''Level Playing Field'' for the independent programmer using leased access?

Chris Folsom

Currently contracts between cable companies and Lease access
programers are not public record. This allows the cable companies to
enter into dubious relationships and is ripe for abuse. All contracts
need to be of public record to prevent the cable monopoly from using
there monopoly to stifle competition. All lease access agreements
need to be available to Freedom of Information Act requests. The FCC
should produce a standard contract for all lease access agreements.
This will prevent abuse by the cable companies.

The cable companies currently have entered into contracts with
certain Low Power Television stations that prevent them from
transmitting any ads from local sources in exchange for lower lease
access rates. This is currently being done in the Jacksonville Comcast
system. This is a gross abuse of the marketplace and should not be
allowed. A cable company should not be allowed to dictate who can
advertise on any lease access programmer. If a cable company is
allowed to do this, then it can prevent any Class A station or Low
Power station from being able to compete for local advertising
dollars. This is absurd. The new rules need to address this
anticompetitive abuse of the Cable franchise monopoly.

Cable companies need to be prevented from any ownership
relationship with any lease access programmer.

The time has come to break the cable companies ability to control
who and what content is allowed on their cable systems. Just like the
concept of "Net Neutrality" is the basis for the internet, open access to
any independent video programmer, or Television station as long as it
does not violate any current FCC content regulations like decency,
needs to be mandated. Cable companies must not be allowed to
control a Lease access programers source of ad revenue.

Finnally the current practice of Cable companies from moving the
lease access channels to the digital tier needs to be addressed. Lease
access needs to be on the lower tier of channels. Moving Lease
access channels to remote areas of a cable systems channel
placement, needs to be regulated. In addition if a local television
station is forced to use Lease Access to get carried then they must be
in a location near the other broadcast channels from the local area. A
level playing field should be enjoyed for all TV channels whether must
carry or lease access an any cable system.


J Marcus Campbell

The obstruction of lease access programming by the cable industry
has succeeded to the point where less than 1% of leased access
channels available for use in America are currently used. While the
reasons for such a low use of this form of programming are many,
the remedy to fix this situation need to be extensive. It is not just the
"Rate" charged to the Lease access programmers that needs to be
addressed. The whole process needs to be addressed.

The delivery of content over the internet needs to be mandated.
Each cable system must be able to receive programming via the
Internet in MPEG 4 format in addition to TV broadcast signal delivery.
Each cable system must have a server available to receive Lease access
programming and store it for delivery. The cost to deliver the
program would be up to the Lease access programmer. The estimated
cost of this per cable system or system "segment" is under $2000 for
the hardware.

One topic of urgent concern is the definition of what is a "Cable
system" is needs to be addressed. Currently through consolidation
"Cable systems" have grown to such a large dimension that a Cable
system can cross state lines, and combine two DMA's into one cable
system creating a subscriber base that is in excess of 1,000,000
subscribers. Based on the new proposed rates, it will still cost
$1,200,000 to lease an entire channel for one year on one of these
combined "Mega" cable systems.

These new mega cable systems owned by Comcast, Brighthouse, and
Time Warner refuse to provide lease access to a "Segment" of the new
Mega cable systems. Yet they will sell you an ad package for a
targeted "Segment" and will provide local PEG channels to "Segments"
of the Mega cable system. However if you want to provide a lease
access channel to one of those segments you will have to pay for and
transmit your programming to the entire Mega Cable system. This is
absurd and must stop.

In these new rules the commission needs to address the Mega cable
systems. Failure to do this will lead to a rate structure that prices out
local programmers. Mega cable systems must provide Lease Access
programming to any "Segment" that the mega cable systems can sell
a targeted ad package too, like Comcast Spotlight. In addition if a
mega cable system provides PEG channels to a "Segment" it needs to
offer the lease access programmer, access to that same "Segment". If
a cable system can deliver ad's to a "segment" they can provide Lease
access channels to that "segment". If a mega cable system can provide
a PEG channel, they can provide lease access channels on that same
segment also . It is as simple as that. No more bull crap from the
Mega cable system about how this is impossible or that there is not
enough bandwidth. Unless this is done in the new rules, Lease access
programming possibilities will never be used in any Mega cable
system. Medium sized communities near large communities.