In the Matter of Federal Communications Commission Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) DA 96-2071 Maryland Cable Partners, L.P. ) CUID No. MD0172 (Prince George's County) ) Complaints Regarding Cable Programming Services Tier Rate Increase Adopted: December 9, 1996 By the Chief, Cable Services Bureau: ) ) ) ) ORDER Released: December 9, 1996 1. In this Order we consider complaints concerning the rate increases of Mary land Cable Partners, L.P. ("Maryland Cable") for its cable programming services tier ("CPST") in Prince George's County, CUID No. MDOl 72. This Order addresses only the reasonableness of Maryland Cable's rates after May 14, 1994. We have already issued a separate order addressing the reasonableness of Maryland Cable's CPST rate in effect prior to that date. 1 Maryland Cable has attempted to justify its CPST rates through benchmark showings on FCC Form 1200, FCC Forms 1210 and FCC Form 1240. We conclude, for the reasons discussed below, that the rates charged by Mary land Cable are unreasonable. 2. The Communications Act2 authorizes the Federal Communications Commission ("Commission") to review the CPST rates of cable systems not subject to effective competition to ensure that rates charged are not unreasonable. The Cable Television and Consumer Protection and Competition Act of 1992, 3 (" 1992 Cable Act") required the Commission to review CPST ' See Maryland Cable Partners, 11 FCC Red 2406 (1996), Erratum, 11 FCC Red 2406 (1996). (In this Order and its subsequent Erratum, the Commission determined that Maryland Cable' CPST rates in effect from September 1993 to May 14, 1994 were reasonable. In a Memorandum Opinion and Order 10 FCC Red 2119 (1994), the Commission determined that an a la carte package which Maryland Cable had created in September 1993 could be treated as an New Product Tier (NPT). The channels associated with the NPT are not at issue in this case. We note, however, that Prince George's County, the Local franchise authority, has filed an Application for Review of the Commission Memorandum Opinion and Order regarding the a la carte issue and the treatment of the NPT. The decision in this case does not affect or prejudice the outcome of that proceeding, and is subject to the Commission's final determination in that case.) 2 Section 623(c), as amended, 47 U.S.C. Section 543(c)(3) (1996). ' Pub. L. No. 102-385, 106 Stat 1460 (1992). 20890 Federal Communications Commission DA 96-2071 rates upon the filing of a valid complaint by a subscriber. The Telecommunications Act of 19964 (" 1996 Act") and our rules implementing the new legislation, 5 require that complaints against the CPST rates be filed with the Commission by a local franchising authority ("LFA") that has received subscriber complaints. An LFA may not file a CPST rate complaint unless it receives more than one subscriber complaint within 90 days after such increase becomes effective. The filing of a valid complaint triggers an obligation on behalf of the cable operator to file a justification of its CPST rates.6 If the Commission finds the rate to be unreasonable, it shall determine the correct rate and any refund liability.7 3. The Commission's original rate regulations took effect on September 1, 1993.8 The Commission revised its rate regulations effective May 15, 1994.9 Cable operators that have valid CPST complaints filed against them prior to May 15, 1994 must demonstrate that their CPST rates were in compliance with the Commission's initial rules from the time the complaint was filed through May 14, 1994. Cable operators must also demonstrate that their rates were in compliance with the revised rules from May 15, 1994 forward. 1° Cable operators attempting to justify their rates for the period beginning May 15, 1994 by a benchmark showing must use the FCC Form 1200 series. 11 Cable operators may also justify rate increases based on the addition and deletion of channels, changes in certain external costs, and inflation, by filing FCC Form 1210.12 FCC Form 1210 must be filed at least 30 days before new rates are scheduled to go into effect when the Commission has found the cable programming service rate to be unreasonable less than one year prior to the filing. In addition, FCC Form 1210 may be filed where there is a pending complaint against the CPST rate. 13 • Pub. L. No. 104-104, 110 Stat 56 (February 8, 1996). ' See Implementation of Cable Act Reform Provisions of the Telecommunications Act of 1996, 11 FCC Red 5937 (1996) ("Interim Rules"). • 47 C.F.R. Section 76.956. ' See 47 C.F.R. Section 76.957. ' Order in MM Docket No. 92-266, Implementation of Sections of the Cable Consumer Protection and Competition Act of 1992: Rate Regulation, FCC 93-372, 58 Fed. Reg. 41042 (Aug. 2, 1993). • 47 C.F.R. Section 76.922(b); see also 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, 4190 (1994) ("Second Order on Reconsideration"). lo Id. 11 47 C.F.R. Section 76.922(b)(F)(6)(ii). 12 47 C.F.R. Section 76.922(d). 13 47 C.F.R. Section 76.960; supra note 12. 20891 Federal Communications Commission DA 96-2071 4. Operators may justify adjustments to their rates on an annual basis using FCC Form 1240 to reflect reasonably certain and quantifiable changes in external costs, inflation and the number of regulated channels that are projected for the twelve months following the rate change. 14 Any incurred cost that is not projected may be accrued with interest and added to rates at a later time. 15 If actual and projected costs are different during the rate year a "true-up" mechanism is available to correct estimated costs with actual cost changes.16 The "true-up" requires operators to decrease their rates or alternatively permits them to increase their rates to make an adjustment for over or under estimations of ~ese cost changes. 5. On April 13, 1995 and on September 20, 1995 valid complaints were filed against the May 1, 1995 and October 1, 1995 rate increases that were to be implemented by Mary land Cable in Prince George's County. In addition, pursuant to the 1996 Act, the local franchise authority, Prince George's County Government ("County") filed a valid17 complaint on July 30, 1996, regarding Maryland Cable's rate increase. 6. Upon review of Maryland Cable's FCC Form 1200, multiple FCC Forms 1210 and FCC Form 1240, we find that Maryland Cable charged in excess of its calculated maximum permitted rate or has not correctly calculated its maximum permitted rate beginning May 15, 1994, as discussed in the paragraphs below .18 7. FCC Forms 1200. 1210 and 1240 Filings: 19 On August 15, 1994, Maryland Cable filed its FCC Form 1200 to justify CPST rates in effect after May 14, 1994. Maryland Cable ,. See In the Matter of Sections of the Cable Television Consumer Protection and Competition Act of 1992: Rate Regulation, MM Docket No. 92-266, Thirteenth Order on Reconsideration ("Thirteenth Reconsideration Order"), 11 FCC Red 388, 291 (1996). '$ Id. at 392. •• Id. 11 See FCC Form 329 complaint filed by the County dated July 30, 1996 to Maryland Cable. The July 30, 1996 complaint from the LF A triggers an obligation on behalf of the cable operator to file a justification of its CPST rat.es with the LFA. In response, on August 20, 1996, Maryland Cable filed an FCC Form 1240 with the County. On Sept.ember 9, 1996 the County filed its CPST rate increase complaint with the Commission along with Maryland Cable's FCC Form 1240. " This fmding is based solely on the representations of Maryland Cable. Should information 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 fmding that we have accepted as correct any specific entry, explanation or argument. made by any party to this proceeding not specifically addressed herein. 19 Information regarding the specific adjustments made to Maryland Cable's FCC Form 1200, FCC Forms 1210 and FCC Form 1240 filings can be found in the public file for CUID No. MDOl 72 which is available in the Cable Services Bureau's public reference room, or through the Commission's copy contractor, International Transcription Services (ITS), 1919 M Street N.W., Washington, DC, 20554, or by calling ITS at (202) 857-3800. 20892 Federal Communications Commission DA 96-2071 calculated a maximum permitted rate for the CPST of $9.01. However, Maryland Cable was actually charging $9.04 for its CPST. Thus Maryland Cable has failed to demonstrate that its rate for the CPST was not unreasonable. 8. On September 1, 1994, Maryland Cable filed an FCC Form 1210 to justify a rate increase of $0.18 effective October 1, 1994. We find that Maryland Cable correctly calculated a maximum pennitted rate of $9.26 justifying the October 1, 1994 CPST charge of $9.22. 9. On February 27, 1995 Maryland Cable filed an FCC Form 1210 to justify a CPST rate increase of $0.26 effective May 1, 1995. We find that Maryland Cable did not correctly calculate its maximum pennitted rate on this filing. Maryland Cable claimed previous pennitted charges of $9.37 for CPST on Line A2 of it FCC Form 1210 filing. The correct maximum· pennitted rate from its previous FCC Form 1210 was $9.26. We adjusted Line A2 to reflect the corrected previous pennitted rate to $9.26 for CPST. In addition, Maryland Cable did not bring forward the correct previous external cost amounts as filed on Line B 10 of its previous FCC Form 1210. In accordance with FCC Form 1210 instructions, we corrected Line B13 on the May 1, 1995 FCC Form 1210 filing to reflect the external costs recorded on Line BIO of the previous FCC Form 1210 filing. Our correction reduced the maximum pennitted rate for CPST from $9.45 to $9.33. Thus, Maryland Cable failed to demonstrate that its May 1, 1995 rate of $9.48 for its CPST was not unreasonable. 10. On October 17, 1995, Maryland Cable filed its FCC Form 1210 to justify a CPST rate increase of $0.29 effective October 1, 1995. Upon review of the FCC 1210, we adjusted Module A, Line 2 to reflect our corrections to the maximum permitted rates on the previous FCC Form 1210. Finally, we adjusted Maryland Cable's inflation to conform with the FCC published rate for the 12 months ending June 30, 1995. These adjustments resulted in a reduction of the maximum pennitted rate for CPST to $9.61 from the rate of $9.74 filed by Maryland Cable. Thus, Maryland Cable failed to demonstrate that its October 1, 1995 rate of $9.77 for its CPST was not unreasonable. 11. On April 30, 1996 Maryland Cable filed FCC Form 1240. We adjusted Module A, Line 1 of that Form to reflect the corrected maximum permitted rate of $9 .61 brought forward from the prior FCC FOrm 1210. In addition, we again adjusted Maryland Cable's inflation to conform with the FCC published rate. We also corrected Worksheet 8 and Line Hl to reflect the maximum pennitted rate corrections we made on FCC Forms 1210 for prior months included in the true-up period. As a result of our adjustments the maximum pennitted rate of $11.11 calculated by Maryland Cable on its FCC Form 1240 for CPST has been corrected to $10.78. Thus, Mary land Cable failed to demonstrate that its June 1, 1996 rate of $11.13 for its CPST was not unreasonable. 12. Accordingly, IT IS ORDERED, pursuant to Section 0.321 of the Commission's rules, 47 C.F.R. § 0.321, that the CPST rates charged by Maryland Cable in the Prince George's County, Maryland, CUID No. MD0172, from May 15,· 1994 to September 30, 1994, ARE . UNREASONABLE. 20893 Federal Communications Commission DA 96-2071 13. Accordingly, IT IS ORDERED, pursuant to Section 0.321 of the Commission's rules, 47 C.F.R. § 0.321, that the CPST rates charged by Maryland Cable in the Prince George's County, Maryland, CUID No. MD0172, from May 1, 1995 to the present, ARE UNREASONABLE. 14. IT IS FURTHER ORDERED, pursuant to Section 0.321 of the Commission's rules, 47 C.F.R. § 0.321, that the complaints against the CPST rates charged by Maryland Cable in Prince George's County, Maryland, CUID No. MD<?172 from May 15, 1994 to September 30, 1994 ARE GRANTED TO THE EXTENT DISCUSSED HEREIN. 15. IT IS FURTHER ORDERED, pursuant to Section 0.321 of the Commission's rules, 47 C.F.R. § 0.321, that the complaints against the CPST rates charged by Maryland Cable in Prince George's County, Maryland, CUID No. MD0172 from May l, 1995 to the present ARE GRANTED TO THE ExTENT DISCUSSED HEREIN. 16. IT IS FURTHER ORDERED, pursuant to Section 76.961 of the Commission's rules, 47 C.F.R. § 76.961, that Maryland Cable shall refund to subscribers in CUID No. MD0172 that portion of the amount paid in excess of the maximum permitted CPST rate of $9.01 per month (plus franchise fee), plus interest to the date of the refund, for the period from May 15, 1994 to August 31, 1994. 17. IT IS FURTHER ORDERED, pursuant to Section 76.961 of the Commission's rules, 47 C.F.R. § 76.961, that Maryland Cable shall refund to subscribers in CUID No. MD0172 that portion of the amount paid in excess of the maximum permitted CPST rate of $9.33 per· month (plus franchise fee), plus interest to the date of the refund, for the period from May 1, 1995 to September 30, 1995. 18. IT IS FURTHER ORDERED, pursuant to Section 76.961 of the Commission's rules, 47 C.F.R. § 76.961, that Maryland Cable shall refund subscribers in CUID No. MDOl 72 that portion of the amount of the CPST rate increase paid by subscribers that exceeded that the maximum permitted CPST rate of $9.61 per month (plus franchise fee), plus interest to the date of the refund for the period from October 1, 1995 to May 31, 1996. 19. IT IS FURTHER ORDERED, pursuant to Section 76.961 of the Commission's rules, 47 C.F.R. § 76.961, that Maryland Cable shall refund subscribers in CUID No. MDOl 72 that portion of the amount of the CPST rate increase paid by subscribers that exceeded that the maximum permitted CPST rate of $10.78 per month (plus franchise fee), plus interest to the date of the refund for the period from June 1, 1996 to the day before Maryland Cable implements the maximum permitted CPST rate of $10.78. 20. IT IS FURTHER ORDERED, pursuant to Section 0.321 of the Commission's rules, 47 C.F.R. § 0.321, that Maryland Cable Partners, L.P. in Prince George's County, CUID No. MOO 172, revise its calculation of its maximum permitted CPST rate in its next FCC Form 1240 filing. 20894 Federal Communications Commission DA 96-2071 21. IT IS FURTHER ORDERED that Maryland Cable shall promptly determine the overcharges to CPST subscribers for the stated periods, 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 determined (including franchise fees and interest), describing the calculation thereof, and describing its plan to implement the refund within 60 days of Commission approval of the plan. FEDERAL COMMUNICATIONS COMMISSION Meredith J. Jones Chief, Cable Service Bureau 20~95