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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
| Address1 | ONE PARKWAY CENTER, #212 |
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| City | PITTSBURGH |
State | PA |
Zip Code | 15220 |
Country | USA |
3. Principal place of business (if different than line 2)
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5. Senate ID# 54528-12
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6. House ID# 349900000
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| TYPE OF REPORT | 8. Year | 2010 |
Q1 (1/1 - 3/31) | Q2 (4/1 - 6/30) | Q3 (7/1 - 9/30) | Q4 (10/1 - 12/31) |
9. Check if this filing amends a previously filed version of this report
| 10. Check if this is a Termination Report | Termination Date | |
11. No Lobbying Issue Activity |
| INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 | |||||||||
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| 12. Lobbying | 13. Organizations | ||||||||
| INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
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| Provide a good faith estimate, rounded to the nearest $10,000, of all lobbying related income for the client (including all payments to the registrant by any other entity for lobbying activities on behalf of the client). | 14. REPORTING Check box to indicate expense accounting method. See instructions for description of options. | ||||||||
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Method A.
Reporting amounts using LDA definitions only
Method B. Reporting amounts under section 6033(b)(8) of the Internal Revenue Code Method C. Reporting amounts under section 162(e) of the Internal Revenue Code |
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| Signature | Digitally Signed By: Matthew M. Polka, President and CEO |
Date | 07/20/2010 |
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code COM
16. Specific lobbying issues
Please see the addendum attached for the full text of COM issues covered.
ACA informed members of Congress know that the ACA filed comments with the FCC regarding the proposed combination of NBC Universals programming assets with Comcasts programming and distribution assets (MB Docket No. 10-56) The association explained that as a result of this joint venture, Comcast-NBCU will gain significant additional market power, providing it with the incentive and ability to charge supra-competitive prices or otherwise exercise their market power to harm competition and consumers. As part of its advocacy, ACA told Congress that adequate remedies must be imposed before approving the deal, and why existing program access rules and previous merger conditions imposed on pay television providers and programmers in the past are an inadequate to address the harms of this deal.
ACA notified Congress that it joined a large and diverse coalition of companies and organizations to call upon the FCC to start a rulemaking on retransmission consent, or otherwise address the issue. ACA also explained to members of Congress its belief that broadcasters engage in rampant price discrimination against smaller operators by charging significantly higher per subscriber rates than larger operators in the same market. Later, ACA let Congress know that the association filed comments in the Commissions proceeding regarding the Petition for Rulemaking to Amend the Commissions Rules Governing Retransmission Consent (MB Docket No. 10-71). In its filing, the ACA specifically urged the Commission to consider and address the following two aspects of the current retransmission consent regime: (1) price discrimination against smaller MVPDs; and (2) joint negotiations involving multiple Big 4 affiliates in a single market.
ACA informed lawmakers know that the group sent a letter to FCC Chairman Genachowski urging the Commission to promptly place Evolution Broadbands petition for wavier of the Commissions separable security rule for a low-cost, one-way, limited-function HD device, on public notice. (GN Docket Nos. 09-47, 09-51, 09-137; CS Docket No. 97-80). ACA also told members of Congress of its meetings with the staff of FCC Commissioners in which it supported the inclusion of a set-top box integration ban exemption for small cable systems in any forthcoming Notice of Proposed Rulemaking. Later ACA let Congress know that it filed comments in support of the FCCs proposed modification of its rules to allow cable operators to place into service new one-way navigation devices that process HD signals and perform both conditional access and other functions in a single integrated device. The comments were filed as part of the Commissions Fourth Further Notice of Proposed Rulemaking seeking comment on proposed fixes to the CableCARD regime, as well as changes to the Commissions rules that are intended to encourage cable operators digital transition (CS Docket No. 97-80, PP Docket No. 00-67).
ACA notified Congress that it agrees with the State Cable Associations who wrote the FCC on March 18, 2010 about the need to end the pole attachment regulation exemption for cooperative and municipally owned utilities (GN Docket Nos. 09-47, 09-51, and 09-137; WC Docket No. 07-245). ACA also told lawmakers that it applauded the FCC for moving to establish new rules that will set the stage for more timely and affordable access to utility poles by small cable operators.
ACA told members of Congress that it has worries about the Commissions idea about regulating broadband access providers as common carriers under a streamlined version of rules that have generally applied to telephone providers for many decades. ACA also expressed a willingness to work with the agency on determining how best to mitigate harms to smaller operators, if the Commission moves ahead.
Lawmakers were informed by the ACA that its Chairman Steve Friedman testified before the Senate Committee on Small Business and Entrepreneurship on April 27 urging the federal government to initiate a number of vital policy reforms including more focused investment in middle-mile infrastructure and stable utility pole attachment fees to provide small cable operators with key incentives to continue providing broadband access services to millions of Americans residing in rural communities.
Regarding the FCCs request for comment on proposed amendments to the Commissions ex parte, procedural, and other rules, ACA let Congress know that it urged the FCC to adopt several procedural reforms, including changes to the ex parte rules, in order to make the agencys decision-making more open and transparent as well as more efficient and modern. (GC Docket Nos. 10-43 and 10-44)
ACA informed Congress that it encouraged the FCC to adopt several procedural reforms designed to better inform small cable operators that they must pay their annual regulatory fees online. (MD Docket No. 10-87)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE,
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Ross |
Lieberman |
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Matthew |
Polka |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
Information Update Page - Complete ONLY where registration information has changed.
20. Client new address
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21. Client new principal place of business (if different than line 20)
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22. New General description of client’s business or activities
LOBBYIST UPDATE
23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client
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ISSUE UPDATE
24. General lobbying issue that no longer pertains
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AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
Internet Address:
| Name | Address |
Principal Place of Business (city and state or country) |
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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
| 1 | 3 | 5 |
| 2 | 4 | 6 |
FOREIGN ENTITIES
27. Add the following foreign entities:
| Name | Address |
Principal place of business (city and state or country) |
Amount of contribution for lobbying activities | Ownership percentage in client | ||||||||||
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28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization
| 1 | 5 | 9 |
| 2 | 6 | 10 |
| 3 | 7 | 11 |
| 4 | 8 | 12 |