HomeMy WebLinkAboutRPT 6 CABLE TV REG 08-16-93AGE N DA -
REPORTS NO. 6
· -8-16-93
AUGUST 16, 1993
Inter-C.om
TO' WILLIAM A. HUSTON, CITY MANAGER
FROM. PUBLIC WORKS DEPARTMENT/ENGINEERING DIVISION
SUBJECT: CABLE TELEVISION REGULATION UPDATE
RECOMMENDATION
It is recommended that the City Council direct staff to apply to the
Federal Communications Commission (FCC) for certification to regulate
cable television rates after September 1, 1993.
FISCAL IMPACT
There is no direct impact on the City of Tustin; however, there is a
potential for residents of Tustin to ultimately save money on cable
rates.
BACKGROUND
The Federal government recently enacted the Cable Television Consumer
Protection and Competition Act of 1992 (Act). The impetus behind the
rate regulation provisions of the Act is the FCC finding that cable
rates have grown three times as fast as the Consumer Price Index since
rate deregulation. FCC studies found that rates in areas with effective
competition average 10% below those areas where cable operators are not
subject to effective competition, such as Tustin. In those markets in
which penetration of any single cable operator did not exceed 30%, the
rates averaged 30% below those areas which do not have effective
competition.
DISCUSSION
The Act permits franchising authorities to regulate rates for basic
cable service only. This includes both charges for the basic service
tier and for equipment utilized in providing the basic service tier.
However, because the same benchmark formula is used for regulating the
rates of other tiers, the franchising authority may, to some degree,
regulate the rates of all tiers.
In order to assert jurisdiction over the basic service tier and
equipment rates, the City must be certified by the Federal
Communications Commission (FCC). The final forms for franchising
authority certification will be available October 1, 1993. It is
expected to be a fairly simple form which will require the City to
certify in writing to the FCC that:
®
It will adopt and administer rules with respect to rates that
are consistent with FCC regulations.
·
It has the legal authority to adopt the regulations and the
personnel to administer the regulations. If a franchise fee
is charged, as in Tustin, there is a presumption that
personnel will be available to administer the regulations.
·
That procedural laws and rules governing rate regulation
proceedings by the City provide a reasonable opportunity for
consideration of the Views of interested parties. Essentiall~,
this involves adequate notice of a public hearing at which al~
interested parties can testify. Provision for written
comments should also be made.
The certification becomes effective 30 days after filing unless the FCC
finds that one of the three criteria has not been met. If the
certification is disapproved, the FCC will notify the City of any
necessary modifications. If the FCC either disapproves or revokes the
certification, the FCC must exercise the City's regulating jurisdiction
until the City becomes qualified. The FCC will not regulate where the
City simply does not apply for certification. The city can request the
FCC to regulate, but it must show that it cannot meet certification
standards. Any franchise agreement which prohibits rate regulation is
null and void to that extent.
The City must serve copies of the certification request on the cable
operators by first class mail on or before the date the certification is
filed with the FCC. Two or more communities served by the same cable
system can file a joint certification and exercise joint regulating
jurisdiction even if the areas covered do not have uniform rates. For
example, Dimension Cable Services provides service to East Tustin,
Irvine, and Newport Beach.
There is no deadline for~seeking certification. The City will have 120
days from the date' th~ certification becomes effective to adopt
regulations which are consistent with the FCC's and to promulgate rule~.
providing a reasonable opportunity for views of interested parties. The
City will be required to notify the cable operators that it has been
certified and that it has adopted regulations before it can begin
regulating rates and, if necessary, drdering refunds.
A cable operator may file a petition for reconsideration of the City's
certification. This petition must be filed within 30 days from the
effective date of the certification. A petition to revoke the
certification can be filed at any time. Revocation would be proper if
the City's regulations do not conform to FCC regulations. All petitions
opposing rate regulation must be served on the City, which has 30 days
to file an opposition.
RATE REGULATION PROCEDURES
The cable operators will be required to file rate schedules for the~
basic service tier and accompanying equipment with the City within 30
days after receiving notice that the City has been certified by the FCC.
All supporting materials as to how the rates conform to FCC rate
standards must be submitted. If the City then determines that the cable
operator's current rates for the basic .tier service and accompanying
equipment are reasonable~under FCC standards or the cable operator has
agreed to reduce such r~tes to FCC standards, they go into effect 30
days after filing with the City. If the City is unable to make such a
determination based on t~e material submitted or if the cable operator:~
have submitted a cost-of-service showing, the City may toll the
effective date of the.proposed rates up to 90 days in the first instance
and 120 days in the s~cond. To do so, the City must issue a brief order
TREATMENT OF EXTERNAL COSTS
Cable operators may pass through~s~~xternal co~ts without a cost-of-
service showing even if the re~~'~'?~tes exceed the benchmark.· Cable
operatorS must also reduce rates if there is a cost reduction in these
categories· Costs which may be passed through directly include:
1. Retransmission consent fees. These are fees paid by cable
operators to broadcasters for the right to carry the broadcast
signal. However, such fees cannot be passed through until
October 6, 1994, and this pass-through only applies to new or
additional retransmission consent fees incurred after that
date.
·
·
Other programming costs. These are fees paid by cable
operators to obtain programming. Increases can be passed
through on a going forward basis.
Taxes, franchise fees and costs of satisfying 'franchise
requirements for local and PEG access channels.
REGULATING RATES FOR EQUIPMENT
The Act directs the FCC to' establish standards for equipment rate
regulation on the basis of actual cost plus reasonable profit for
installation and lease of equipment used by subscribers to receive the
basic service tier. Equipment to be regulated includes converter boxes,
remote control units, connections for additional TV receivers and
wiring. The Act requires the cable operator to unbundle the costs for
equipment. Cable operators cannot include the cost of promotions as
part of equipment charges. This must be included in the general
overhead, if the cable operator sells such equipment, the price cannot
be set at a rate higher than'necessary to recover the cable operator's
costs.
REMEDIES AND APPEALS
The City will be able to disapprove of rates proposed by the cable
operators. Further, the City will be able to impose a prospective rate
reduction to meet the benchmark if it determines that the rates exceed
the standard. The City will be able to prescribe a reasonable rate in
lieu of the cable operator's proposed rate.
The City will be able to order refunds of basic service tier rates. The
city would utilize this if the cable operator failed to comply with the
rate decision 'of the City or as part of review of the initial rates.
Prior to doing so, the franchising authority must provide notice to the
cable operator and allow rebuttal. Refunds should include interest
at the Internal Revenue Service rate for refunds. The City cannot
impose fines or penalties for unreasonable rates and the Act preempts
any state law which allows such punishment.
The FCC is the sole forum for appeals of franchising authority rate
decisions. Decisions can be appealed by either the cable operator or
other interested parties. The standard of review is whether there was
a reasonable basis for the franchising authority decision.
within the initial 30-day period stating the reasons for the extension.
During this extension, the City can solicit additional information from
the cable operators and hear from interested parties. If no action is
taken during these time periods, then the cable operators proposed rates
go into effect, subject to refund orders. The franchising authority can
still issue a written decision after this time ordering refunds.
While the Act does not require formal rate hearings, the City must issue
a written decision and provide public notice of the decision. Although
no specific notice requirements are contained in the Act, FCC
suggestions include placing notice on the cable system or in a
newspaper. At a minimum, the City should comply with Brown Act notice
requirements. The written decision must state the reasons the City is
approving or disapproving the rates. No written decision is necessary
if the franchising authority has approved the cable operator's proposed
rates in their entirety and no one has objected.
The cable operators must notify subscribers in writing of any proposed
increases in rates for the basic service tier and accompanying equipment
at the billing cycle which is at least 30 days before any proposed
increase is effective.
REGULATIONS OF BASIC GROUP TIERS
The basic service tier Cable operators must offer includes at least:
·
·
Ail local commercial and non-commercial educational television
and qualified low-power station signals carried to meet the
carriage obligations of Sections 614 and 615 of the Act.
All public, educational and government ("PEG") programming
which is actually used for PEG programming.
·
Ail television broadcast stations (such as ABC, CBS and NBC)
offered by the cable operator, unless it is a secondarily
transmitted by a satellite beyond the local service area of
such a station (such as ~TBS out of Atlanta and WGN out of
Chicago).
4. The cable operator can include other channels.
The franchising authority can require that the PEG channels be carried
on non-basic service tiers.
By completing the FCC forms, the cable operator determines whether or
not its rates are below the FCC benchmark. The basis of the benchmark
formula is three characteristics the FCC found to have the most
significant impact on rates: (1) the number of channels offered; (2) the
number of subscribers served; and (3) the number of satellite-delivered
signals. The benchmark formula is applied by inserting these three
characteristics into a mathematical equation. The benchmark rate is
based on a September 30, 1992, FCC study. Those systems below the
benchmark will have rates capped at that level. Those systems which
have rates greater than the benchmark will be required to reduce them to
the lesser of the benchmark or 10%.
CONCLUSION
As stated in this report, in order to regulate rates the City must first
apply for certification to the FCC. The effective date for regulation
is September 1, 1993. Staff has been informed by the FCC that the forms
for certification will not be available until October, 1993. At that
time, should the City Council wish to proceed with a request to the FCC
for certification staff will prepare the required documents.
Robert S. Led&ndecke~/
Director of Public Works/City Engineer
Katie~P~t~~ ---
Administrative Assistant II
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