DA 95-2275 Federal Communications Commission Record 10 FCC Red No. 23 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of TCI CABLEVISION OF THE METROPLEX, INC. Appeal of Local Rate Order of Garland, Texas TX0554 MEMORANDUM OPINION AND ORDER Adopted: October 30,1995; Released: November 9,1995 By the Chief, Cable Services Bureau: I. INTRODUCTION 1. On February 23, 1995, TCI Cablevision of the Metroplex, Inc. ("TCI"), filed an appeal of a local rate order of the City of Garland, Texas (the "City"), dated January 24, 1995. The City filed an opposition to Cablevision's appeal on March 9, 1995. Cablevision filed a reply to the City's opposition on March 20, 1995. In the local rate order, the City denied a proposed rate increase for basic cable service. 1 2. The City rejected the proposed rate increase because TCI failed to provide any supporting documentation for the increase which was based on claimed increased pro gramming costs. In its appeal, TCI contends that a franchis ing authority is only entitled to request information that is reasonably necessary for it to review an operator's rates and to prepare a local rate order, and that the City's request for supporting documentation is neither reasonable nor neces sary. TCI states that the supporting documentation request ed by the City is in its programming contracts. TCI contends that the City's request for the information in the programming contracts is not reasonable because the re quested information is confidential, and that making the information available to individual franchising authorities 1 Under the Cable Television Consumer Protection and Com petition Act of 1992, and the Commission's implementing regu lations, local franchising authorities may regulate rates for basic cable service, associated equipment, and installations. See Cable Television Consumer Protection and Competition Act, Pub. L. No. 102-385, 106 Stat. 1460 (1992); Communications Act, § 623(b), 47 U.S.C. § 543(b). 2 TCI also indicates a willingness to have the Commission review the contracts in camera if the City is dissatisfied with an independent accountant's review, arguing that: (1) the likeli hood of leaks of confidential information would be reduced if only one federal agency reviews the contracts, rather than a number of franchising authorities; (2) since most programming is MSO-wide, the Commission's review of one contract could apply to potentially thousands of franchises; (3) the Commission could review the same material in the context of CPS rate reviews, reducing duplication of local and federal efforts; (4) the Commission is better equipped to deal with the complexities of the pricing structures involved; (5) franchising authorities would save money on consultants' fees; (6) knowing that Corn- will ensure that the information will become public at some point. TCI also argues that review of programming costs by local franchising authorities is not necessary to ensure the validity of TCI's cost increases because an in dependent accounting firm retained by TCI could review the contracts and verify the cost increases.2 3. In its opposition, the City argues that in order to review the merits of a rate increase filing, the City must have documentation supporting the basis for the rate in crease. The City states that it told TCI that if the only source of the supporting documentation is TCI's program ming contracts, TCI need not identity its programmers to the City. In addition, the City has expressed its intent .to maintain the confidentiality of TCI's programming con tracts.3 However, the City contends that TCI cannot simply refuse to provide any documentation for its rate increase on grounds that an employee of the City might disclose the information. Finally, the City observes that TCI's argument is focused on to whom TCI should be required to submit its contracts for review and not on whether review of the programming contracts is reasonably necessary to deter mine the merits of the rate justification. The City argues that the Commission has already identified the franchising authority as the proper reviewing body. 4. In its reply, TCI concedes that the City is correct in asserting that TCI wants a party other than the City to review programming contracts, but that the City fails to identify any compelling reason why it should be the re viewing party. 5. Under the Commission's rules, appeals of franchising authorities' local rate orders are reviewed by the Commis sion.4 In ruling on an appeal of a local rate order, the Commission will not conduct a de novo review, but instead will sustain the franchising authority's decision as long as there is a reasonable basis for that decision.5 The Commis sion will reverse a franchising authority's decision only if it determines that the franchising authority acted unreason ably in applying the Commission's rules in rendering a local rate order. If the Commission reverses a franchising authority's decision, it will not substitute its own decision but instead will remand the issue to the franchising author ity with instructions to resolve the case consistent with the Commission's decision on appeal.7 mission review was available, franchising authorities would rec ognize that operators would have no incentive to misrepresent their programming costs; and (7) the Commission's authority to impose refunds and sanctions on a national basis for inaccurate rate justifications would ensure that such inaccuracies would not occur. 3 City's Opposition at 5-6. See also, Exhibit C of the City's Opposition which contains the City's rules for maintaining confidentiality of proprietary information. 4 47 C.F.R. §76.944. 5 See Report and Order and Further Notice of Proposed Rulemaking in MM Docket 92-266, 8 FCC Red 5631, 5731(1993) ("Report and Order"); Third Order on Reconsideration in MM Docket 92-266, 9 FCC Red 4316, 4346 (1994) ("Third Recon. Order"). 6 Id.7 Id. 12210 10 FCC Red No. 23 Federal Communications Commission Record DA 95-2275 II. DISCUSSION 6. FCC Form 1200 is the official form used to determine whether an operator's initial regulated programming rates are reasonable under the revised benchmark rules which apply to operators beginning May 15, 1994 or upon the expiration of the deferral period provided under our rules for operators to comply with the revisions to our rules. 8 In the Form 1200, an operator calculates its provisional rates and its full reduction rates. An operator uses FCC Form 1210 to justify adjustments to the initial rates it computed on its FCC Form 1200.9 An operator may adjust its rates to reflect changes in certain external costs, including pro gramming costs, channel additions anddeletions, and infla tion. 7. TCI filed a Form 1210 to reflect an increase in programming costs it alleged it incurred between April 1, 1994 and June 30, 1994. The City requested that TCI supply documentation supporting the increase in program ming costs. The City rejected the rate increase because TCI failed to provide any supporting documentation for the claimed increase in programming costs. 8. A cable operator that wishes to increase its basic service tier rate has the burden of demonstrating that the increase is in conformance with our rules. 10 In determining whether the operator's increase is in conformance with our rules, a franchising authority has the right to collect addi tional information from the operator." Where appropriate, the franchising authority, in reviewing a rate justification, may require that the operator provide proprietary informa tion. 12 In so doing, the franchising authority should state the justification for each item of information requested, and should state the section of the form to which the request relates. 13 9. In response to a request for clarification we received,14 we recently addressed the issue of whether operators are required to provide franchising authorities with copies of programming contracts, which the operators maintain are confidential, to support rate increases based on increases in programming costs. We stated that our rules require that upon proper request by the franchising authority, an oper ator must disclose to the franchising authority material, even proprietary information, determined by the franchis ing authority to be reasonably necessary in making a deter mination regarding the operator's maximum permitted rates.16 At that time, we declined to address the merits of an alternative proposal contained in the request which is the same as the request presented by TCI in the present appeal.17 We concluded that we could not change those rules in the absence of a rulemaking proceeding.18 10. In the instant case, we believe it reasonable to con clude that programming contracts, which TCI maintains are confidential, may be "reasonably necessary" for the review of a rate increase based on increases in program ming costs reflected in those contracts. Indeed, in its reply, TCI does not contest that review of supporting documenta tion from its programming contracts is necessary.19 Its ob jection lies with whether a franchising authority is the proper party to review such programming contracts. As stated in our recent letter discussed above, we have con cluded that a franchising authority is, in fact, an appro priate party to review those contracts.20 We again emphasize, however, that franchising authorities should "be judicious in their requests for programming contracts, to make sure that the information is needed, and to narrow their requests, if appropriate, to permit cable operators to submit only the specific information requested."21 In this case, the City intends to maintain the confidentiality of TCI's programming contracts and has advised TCI that it need not identify the programmers in those contracts sub ject to the City's review. Accordingly, we conclude that the City acted reasonably in its request. 11. For the above-stated reasons, we also find that the City acted reasonably in denying the rate increase. How ever, TCI may resubmit to the City the underlying data in support of its proposed rate increase as long as it has not already made an adjustment in its rates for this or any subsequent period. Our rules state that a proposed rate increase that is due to changes in external costs, must fully reflect all changes in external costs, inflation and the num ber of channels that occurred "from the end of the last quarter for which an adjustment was previously made" through the end of the quarter that has most recently closed.23 Accordingly, if TCI has made no further adjust ments to its rates following the City's denial of its proposed rate increase, our rules permit TCI to incorporate the cost increases that were the basis of the proposed increase that was denied by the City into a subsequent rate increase proposal. Little may come of a decision by an operator to resubmit a proposed increase to a local franchising author ity that had been denied on the merits, but where, as here, the increase was denied because of the refusal of TCI to supply necessary supporting data, and TCI subsequently 8 See Second Order on Reconsideration, Fourth Report and Order, Fifth Notice of Proposed Rulemaking in MM Docket 92-266, 9 FCC Red 4119 (1994) ("Second Recon. Order"). 9 See Second Order on Reconsideration, Fourth Report and Order, and Fifth Notice of Proposed Rulemaking in MM Docket No. 92-266, FCC 94-38, 9 FCC Red 4119 (1994) ("Second Re consideration Order"). 10 47 C.F.R. § 76.937(a). 11 Rate Order, 8 FCC Red at 5718-19.' 12 Id.; Third Recon. Order, 9 FCC Red at 4343-45; 47 C.F.R. § 76.938. 13 47 C.F.R. § 76.938. 14 Letters from Wesley R. Heppler, Esq. and Paul Glist, Esq., Cole, Raywid & Braverman, to Meredith Jones, Chief, Cable Services Bureau (Aug. 8, Sept. 19, and Oct. 28, 1994). 15 See Letter from Meredith Jones, Chief, Cable Services Bu reau, to Wesley R. Heppler, Esq. and Paul Glist, Esq., DA 95-1175 (May 26, 1995) ("Letter"). 16 The franchising authority must state clearly the reason for the request, and to which portion on the FCC form the re quested information specifically relates. Letter at 4; Third Recon. Order, 9 FCC Red at 4344. Here, TCI does not challenge whether the City properly submitted its request. 17 Id. at 4. As set forth in paragraph 2 and footnote 2, supra, the proposal involves review of the relevant confidential pro gramming contracts by an independent accounting firm re tained by the operator. In the event that the franchising authority is dissatisfied with such a review, it could request that the Commission review the contracts in camera. 18 Letter at 4-5. 19 Reply at 2. 20 Letter at 4. 21 Id. at 5. 22 TCI has made no argument that the City does not have the legal authority to keep the contracts confidential. 23 47 C.F.R. § 76.922(d)(3)(iii). 12211 DA 95-2275 Federal Communications Commission Record 10 FCC Red NO. 23 supplies that data, the City could approve the previously denied increase as part of a rate increase proposal submit ted subsequently. III. ORDERING CLAUSE 12. Accordingly, IT IS ORDERED that the appeal by TCI Cablevision of the City of Garland's local rate order, regarding the City's requirement that TCI make its pro gramming contracts available as part of the rate review process, is DENIED. 13. This action is taken by the Chief, Cable Services Bureau, pursuant to authority delegated by Section 0.321 of the Commission's rules. 47 C.F.R. §0.321. FEDERAL COMMUNICATIONS COMMISSION Meredith J. Jones Chief, Cable Services Bureau 12212