12.07.12 FCC Ex Parte - NTCA and OPASTCO File Letter re Media Ownership re MB 09-182 et al

2010 Quadrennial Regulatory Review -- Review of the Commission's Broadcast Ownership Rules and Other Rules Adopted Pursuant to Section 202 of the Telecommunications Act of 1996, MB Docket No. 09-182; Amendment of the Commission’s Rules Related to Retransmission Consent, MB Docket No. 10-71; and Inquiry Concerning the Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, and Possible Steps To Accelerate Such Deployment Pursuant to Section 706 of the Telecommunications Act of 1996, as Amended by the Broadband Data Improvement Act, GN Docket No. 12-228

The Organization for the Promotion and Advancement of Small Telecommunications Companies (OPASTCO) and the National Telecommunications Cooperative Association (NTCA)(the Associations) share the concerns recently expressed by representatives of the American Cable Association, Time Warner Cable, and DISH Network (ACA et. al.).The Associations agree with ACA et. al. that coordinated retransmission consent negotiations by separately owned, same-market television stations is a media ownership issue directly implicating local television competition that must be addressed by the Commission in its quadrennial media ownership review. Specifically, the Commission should recognize that the coordination of retransmission consent negotiations by separately owned same-market television stations gives rise to an attributable ownership interest under the Commission’s rules.

12.07.12 FCC Ex Parte - NTCA and OPASTCO File Letter re Media Ownership re MB 09-182 et al