10 FCC Red No. 23 Federal Communications Commission Record DA 95-2253 Before the Federal Communications Commission Washington, D.C. 20554 CUID No. OK0063 (Bartlesville) In the Matter of Donrey Cablevision, A General Partnership Benchmark Filing to Support Cable Programming Service Price MEMORANDUM OPINION AND ORDER Adopted: October 30,1995; Released: November 8, 1995 By the Chief, Cable Services Bureau: 1. Here we consider complaints about the price that the above-captioned operator ("Operator") was charging for its cable programming service ("CPS") tier in the community referenced above. Operator has chosen to attempt to justify its price through a benchmark showing on FCC Form 393. This Order addresses the reasonableness of Operator's price only through May 14, 1994. At a later date we will issue a separate order addressing the reasonableness of the price after that date. 1 2. Under the Cable Television Consumer Protection and Competition Act of 1992,2 and our rules implementing it, 47 C.F.R. Part 76, Subpart N, the Commission must review CPS prices upon the filing of a valid complaint. The filing of a valid complaint triggers an obligation on behalf of the cable operator to file a justification of its CPS prices.3 Un der our rules, an operator may attempt to justify its prices through either a benchmark showing or a cost-of-service showing.4 In either case, the operator has the burden of demonstrating that its CPS prices are not unreasonable.5 3. The Commission's original rate regulations took effect on September 1, 1993.6 The Commission subsequently re vised its rate regulations effective May 15, 1994.7 Operators with valid CPS complaints filed against them prior to May 15, 1994 must demonstrate that their CPS prices were in compliance with the Commission's initial rules from the time the complaint was filed through May 14, 1994, and that their prices were in compliance with the revised rules from May 15, 1994 forward.8 Operators attempting to jus tify their prices for the period prior to May 15, 1994 through a benchmark showing must complete and file FCC Form 393.9 Generally, to justify their prices for the period beginning May 15, 1994 through a benchmark showing, operators must use the FCC Form 1200 series. 10 4. The first valid complaint in the franchise area which is the subject of this Order was completed and served on Operator on October 8, 1993 and received by the Commis sion on October 14, 1993. Operator filed FCC Form 393 in response; Operator has also filed amended and supplemen tal Form 393 filings, most recently on June 24, 1994. 5. Operator asserts that its monthly CPS tier price of $13.35 (plus franchise fee) is justified by its benchmark filing because its price is equal to or lower than the maxi mum permitted charge of $14.00 per month (plus franchise fee), as calculated in the filing. Upon review of Operator's Form 393 filing, we have found that it has not correctly calculated its maximum permitted price, and it is therefore appropriate to make the following adjustment to Operator's calculations in Form 393: Operator's Form 393, Part II, Worksheet 1, Line 104 entry does not represent its current monthly equipment revenue as of the initial date of regula tion. Since Operator restructured its rates, including its equipment rates, on September 1, 1993, the monthly equip ment cost figure it entered on Line 34 of Step G of Part III should have been close or identical to its Line 104 entry. 11 However, Operator's entry on Line 104 differed substan tially from its entry on Line 34. We therefore adjust Line 104 to equal the amount entered on Line 34, which results in a change in Line 110 from 0.616 to 0.575. 6. Upon review of the record herein, and having incor porated the adjustment discussed above, we conclude that Operator has failed to justify the rate it was charging during the period in question. Operator's showing justifies a maximum reasonable CPS tier price of $13.00 per month (plus franchise fee) for the period from October 14, 1993 to May 14, 1994. 12 1 The findings in this Order do not in any way prejudge the reasonableness of the price for CPS service after May 14, 1994 under our new rate regulations. However, to the extent Oper ator has sought to take advantage of the refund deferral period under the Second Order on Reconsideration, Fourth Report and Order, and Fifth Notice of Proposed Rulemaking, MM Docket No. 92-266, FCC 94-38, 9 FCC Red 4119 (1994) ("Second Order on Reconsideration"), the maximum permitted CPS price determined herein might also apply from May 15, 1994 until the date on which Operator implemented its CPS price under the new regulations. See para. 3, infra. Further, to the extent that the price as of March 31, 1994 is found to be excessive, a reduction in Operator's price for the period after May 14, 1994 may be required to reflect the fact that Operator's price during the earlier period, which is used as the starting point to cal culate its price for the prospective period, was unreasonable. See 47 C.F.R. § 76.922(b)(4)(C). 2 Pub. L. No. 102-385, 106 Stat. 1460 (1992); Communications Act, § 623(c), as amended, 47 U.S.C. § 543(c) (1993). 3 47 C.F.R. § 76.956. 4 47 C.F.R. § 76.956(b). 5 Id. 6 Order in MM Docket No. 92-266, Implementation of Sections of the Cable Television Consumer Protection and Competition Act of 1992: Rate Regulation, FCC 93-372, 58 Fed. Reg. 41042 (Aug. 2, 1993). ' 47 C.F.R. § 76.922(b). 8 See Second Order on Reconsideration, 9 FCC Red at 4190, paras. 150-152. ' Id. 10 47 C.F.R. § 76.922(b)(6); see also Second Order on Reconsi deration, 9 FCC Red at 4189 n.195. 11 See Questions and Answers on Completion of FCC Form 393 and Associated Filing Requirements, Question and Answer No. 7 (released Nov. 10, 1993) ("where operators have restructured equipment rates as of September 1, 1993 in accor dance with our regulations ... operators will enter on Line 104 the same, or nearly the same number as on Line 301."). 12 This finding is based solely on the representations of Oper ator and the modifications described herein. Should information 12191 DA 95-2253 Federal Communications Commission Record 10 FCC Red No. 23 7. Accordingly, IT IS ORDERED, pursuant to Section 0.321 of the Commission's Rules, 47 C.F.R. § 0.321, that the complaint referenced herein against the cable program ming service price charged by Operator in the franchise area referenced in the caption, and all other complaints in this franchise related to the same price, ARE GRANTED TO THE EXTENT INDICATED HEREIN. 8. IT IS FURTHER ORDERED, pursuant to Section 76.961 of the Commission's Rules, 47 C.F.R. § 76.961, that Operator shall refund to subscribers in the franchise area referenced in the caption that portion of the amount paid for cable programming service for the period from October 14, 1993" to May 14, 1994 which exceeded the maximum price of $13.00 per month (plus franchise fee), plus interest to the date of the refund. 9. IT IS FURTHER ORDERED that Operator shall promptly determine the overcharges to CPS subscribers for the stated period, and shall within 30 days of the release of this Order file a report with the Chief, Cable Services Bureau, stating the cumulative refund amount so deter mined (including franchise fees and interest), describing the calculation thereof, and describing its plan to imple ment the refund within 60 days of Commission approval of the plan. 10. IT IS FURTHER ORDERED, pursuant to Section 76.922(b)(4)(C) of the Commission's Rules, 47 C.F.R. § 76.922(b)(4)(C), that Operator shall, within 30 days of the release of this Order, revise its Form 1200 filing with respect to the franchise area referenced in the caption, for the period beginning May 15, 1994, to reduce the monthly charge per tier as of March 31, 1994 for Tier 2 (Line A6b) to equal the maximum permitted price of $13.00 (plus franchise fee). 14 11. IT IS FURTHER ORDERED that Operator shall place into effect, within 30 days after its submission of the revised Form 1200 filing required above, a price that re flects the reduction in the CPS rate determined in this Order. FEDERAL COMMUNICATIONS COMMISSION Meredith J. Jones Chief, Cable Services Bureau come to our attention that these representations were materially inaccurate, we reserve the right to take appropriate action. This Order is not to be construed as a finding that we have accepted as correct any specific entry, explanation or argument made by any party to this proceeding not specifically addressed herein. 13 Our jurisdiction to order a refund dates from the earliest date a valid complaint is filed with the Commission. 47 C.F.R. § 76.96 l(b). 14 We reserve the right to make further adjustments to Oper ator's price for the period after May 14, 1994, upon completion of our review of Operator's Form 1200 filing. 12192