The American Cable Association, which represents smaller and mid-sized cable operators, Friday officially asked the FCC to collect only current data in its proposed new 70/70 reporting form, and not to require cable operators to report telephone, digital or cable modem information for the form.
That came in comments to the FCC on its proposal to make changes to the data-collection form it uses to determine whether cable has reached a threshold for possible new regulation.
The FCC last month concluded the 70/70 test had not been met (70% penetration, 70% subscribership), but that was in the long-delayed report based on 2006 data.
The commission then decided last month to play catch-up by combining the 2007, 2008 and 2009 "annual" reports into a single document. The commission is considering a raft of new reporting requirements to help it better determine cable's penetration of the multichannel video market.
ACA says that requiring its members to collect data from 2006 and 2007 would extract too high a compliance cost, particularly historical data on housing units passed. If the FCC has to collect historical data, ACA says, it should accept "best estimates" of that figure from systems serving 20,000 or fewer subs. ACA also asked that the FCC not make the information public, particularly "competitively sensitive" information. "If the FCC released an ACA member's penetration rate in a certain market, pay-TV competitors could better facilitate targeted promotional offerings in that ACA member's service area," ACA President Matt Polka argues.
The group also wants an exemption for smaller systems from collecting data on unoccupied homes and bulk units as a burdensome requirement on his members, many of whom do not collect the historical records the FCC seeks.
ACA had previously seconded the National Cable & Telecommunications Association's comments that new reporting requirements would be an unnecessary burden on smaller cable operators while yielding the same results as the FCC's 2006 report (released in January of this year), that: "a variety of competitors have substantially eroded and continue to erode - the share of the video distribution marketplace that traditional cable operators serve."