FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON
OFFICE OF
THE CHAIRMAN
June 16,2015
The Honorable Mike Doyle
U.S. House of Representatives
239 Cannon House Office Building
Washington, D.C. 20515
Dear Congressman Doyle:
Thank you for your letter urging the Commission to take prompt action on its pending
Further Notice of Proposed Rulemaking regarding our program access rules. I appreciate
hearing your views.
As you note, the Commission sought comment in 2012 on a variety of issues related to
our program access rules, including whether to modify the current definition of "buying group."
The National Cable Television Cooperative (NCTC) sought the change because its existing
practice excludes it from the definition, and thus, NCTC claims it is unable to avail itself of the
complaint process under our rules.
Although the Commission made a tentative conclusion to potentially modify the "buying
group" definition in the Further Notice, the record in the proceeding indicates that a rule change
is not necessary for NCTC to qualify as a buying group, and it appears that this is more of a
dispute over ultimate liability than a regulatory issue. NCTC previously complied with the
requirements of the existing definition; past and recent filings have not demonstrated that it is
burdensome to satisfy these requirements, should NCTC choose to do so.
IfNCTC has information that might shed new light on this conclusion, I invite them to
add that analysis to the record and to share their findings with Bureau staff.
I hope this information is helpful. Your letter will be made part of the record of the
proceeding.
Sincerely, -4~?-
~eler
FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON
OFFICE OF
THE CHAIRMAN
June 16,2015
The Honorable Ben Ray Lujan
U.S. House of Representatives
2446 Rayburn House Office Building
Washington, D.C. 20515
Dear Congressman Lujan:
Thank you for your letter urging the Commission to take prompt action on its pending
Further Notice of Proposed Rulemaking regarding our program access rules. I appreciate
hearing your views.
As you note, the Commission sought comment in 2012 on a variety of issues related to
our program access rules, including whether to modify the current definition of "buying group."
The National Cable Television Cooperative (NCTC) sought the change because its existing
practice excludes it from the definition, and thus, NCTC claims it is unable to avail itself of the
complaint process under our rules.
Although the Commission made a tentative conclusion to potentially modify the "buying
group" definition in the Further Notice, the record in the proceeding indicates that a rule change
is not necessary for NCTC to qualify as a buying group, and it appears that this is more of a
dispute over ultimate liability than a regulatory issue. NCTC previously complied with the
requirements of the existing definition; past and recent filings have not demonstrated that it is
burdensome to satisfy these requirements, should NCTC choose to do so.
IfNCTC has information that might shed new light on this conclusion, I invite them to
add that analysis to the record and to share their findings with Bureau staff.
I hope this information is helpful. Your letter will be made part of the record of the
proceeding.
Sincerely,
~T~~
FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON
OFFICE OF
THE CHAIRMAN
June 16,2015
The Honorable Bob Latta
U.S. House of Representatives
2448 Rayburn House Office Building
Washington, D.C. 20515
Dear Congressman Latta:
Thank you for your letter urging the Commission to take prompt action on its pending
Further Notice of Proposed Rulemaking regarding our program access rules. I appreciate
hearing your views.
As you note, the Commission sought comment in 2012 on a variety of issues related to
our program access rules, including whether to modify the current definition of "buying group."
The National Cable Television Cooperative (NCTC) sought the change because its existing
practice excludes it from the definition, and thus, NCTC claims it is unable to avail itself ofthe
complaint process under our rules.
Although the Commission made a tentative conclusion to potentially modify the "buying
group" definition in the Further Notice, the record in the proceeding indicates that a rule change
is not necessary for NCTC to qualify as a buying group, and it appears that this is more of a
dispute over ultimate liability than a regulatory issue. NCTC previously complied with the
requirements of the existing definition; past and recent filings have not demonstrated that it is
burdensome to satisfy these requirements, should NCTC choose to do so.
IfNCTC has information that might shed new light on this conclusion, I invite them to
add that analysis to the record and to share their findings with Bureau staff.
I hope this information is helpful. Your letter will be made part of the record of the
proceeding.
Sincerely,
------
FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON
OFFICE OF
THE CHAIRMAN
June 16,2015
The Honorable Bill Johnson
U.S. House of Representatives
1710 Longworth House Office Building
Washington, D.C. 20515
Dear Congressman Johnson:
Thank you for your letter urging the Commission to take prompt action on its pending
Further Notice of Proposed Rulemaking regarding our program access rules. I appreciate
hearing your views.
As you note, the Commission sought comment in 2012 on a variety of issues related to
our program access rules, including whether to modify the current definition of "buying group."
The National Cable Television Cooperative (NCTC) sought the change because its existing
practice excludes it from the definition, and thus, NCTC claims it is unable to avail itself of the
complaint process under our rules.
Although the Commission made a tentative conclusion to potentially modify the "buying
group" definition in the Further Notice, the record in the proceeding indicates that a rule change
is not necessary for NCTC to qualify as a buying group, and it appears that this is more of a
dispute over ultimate liability than a regulatory issue. NCTC previously complied with the
requirements of the existing definition; past and recent filings have not demonstrated that it is
burdensome to satisfy these requirements, should NCTC choose to do so.
IfNCTC has information that might shed new light on this conclusion, I invite them to
add that analysis to the record and to share their findings with Bureau staff.
I hope this information is helpful. Your letter will be made part of the record ofthe
proceeding.