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CAR 4513408, et al.  Yf-Advance/Newhouse Partnership,hh,V)  YO- and Time Warner Entertainment V)  Y8-Advance/Newhouse Partnershiphh,V)  Y!- Transfer of Controlhh,V)  Y-}  MEMORANDUM OPINION AND ORDER ă  Y-Adopted: March 21, 1995 hh,VReleased: March 23, 1995 By the Chief, Cable Services Bureau:  Y%- I.  Introduction  Y-1.` ` On November 30, 1994, Time Warner Entertainment Co., L.P., ("TWE"), filed applications for authority to transfer, pursuant to Section 310(d) of the Communications Act, 47 U.S.C. 310(d), thirty Cable Television Relay Service (CARS) licenses from Advance/Newhouse Partnership ("Advance/Newhouse") and fortythree CARS licenses from TWE, as part of its proposed merger of the TWE and Advance/Newhouse cable systems into the Time Warner EntertainmentAdvance/Newhouse Partnership ("the Partnership"). As explained below, the Bureau finds that approving the proposed license transfers will serve the public interest, convenience and necessity. Therefore, the Bureau grants the transfer applications. ")'0*0*0*P("  Y- II. Background  Y-  Y-2.` ` Time Warner Entertainment Co., L.P. ("TWE"), was formed as a limited partnership and has, since June 30, 1992, owned and operated substantially all of the filmed entertainment, cable television and cable television programming businesses, as well as other  Y-businesses, previously owned and operated by Time Warner Inc. NM Y-ԍTime Warner Entertainment Co., L.P., Form 10K at I1 (December 31, 1993)  Y-("10K"). Time Warner Inc. owns 100% of TW Partners, which owns 63.27% of TWE and is its general partner. Wholly owned subsidiaries of ITOCHU Corp., and Toshiba Corp., together with US West Corp., own 36.73% of TWE and are its limited partners. The TW Partners are Warner Communications Inc., American Television and Communications Corp., Time Warner Operations Inc., Warner Cable Communications Inc., Capital Cablevision Systems, Inc., Memphis CATV, Inc., and People's Cable Corp., each of which is a direct or  Yj -indirect wholly owned subsidiary of Time Warner. 10K at I1 to I2.  The Time Warner Cable  Yw-division ("Time Warner Cable") of TWE operates TWE's cable television systems.IwM Y-ԍId. at I13.I Time Warner Cable's wholly and partially owned cable systems serve approximately 7.2 million  YI-cable subscribers located in 34 states.:I M Y-ԍId.: Time Warner Cable is the secondlargest multiple system cable operator in the United States, owning or operating 22 of the largest 100 U.S.  Y -cable systems. : D M Y-ԍId.: TWE has total assets exceeding $17 billion. I  Y-ԍId. at F21.I  Y -3.` ` Advance/Newhouse Partnership is a general partnership between Newhouse  Y -Broadcasting Corporation and a whollyowned subsidiary of Advance Publications, Inc.  M Y2-ԍTime Warner Entertainment Co., L.P., Form 8K at 2, September 9, 1994 ("8K").  Y -Advance/Newhouse's cable television systems serve approximately 1.4 million subscribers.: ]M Y-ԍId.: Newhouse Broadcasting Corp. is owned 50% by S.I. Newhouse, Jr. and 50% by Donald E.  Y-Newhouse.M YS#-ԍSee Application for Cable Television Relay Service Station Authorization, Exhibit B6, CAR 4513508. Metrovision, Inc., NewChannels Corp. and Vision Cable Communications, Inc. ("Vision"), each operate Advance/Newhouse's cable television systems and are subsidiaries of Newhouse Broadcasting Corp. Vision Cable of Pinellas, Inc. is a subsidiary of Vision  YM-Cable Southern Systems, Inc., which is a subsidiary of Vision Cable Communications, Inc.  Y-4.` ` TWE and Advance/Newhouse have formed a general partnership, the"0*0*0*" Partnership, to which Advance/Newhouse will contribute all of its cable television systems, with 1.4 million customers, along with certain related assets and TWE will contribute certain of its cable television systems (or TWE's interests therein), which serve approximately 2.8  Y-million subscribers, and certain related assets.F 4 Y4-ԍ8K at 2.F TWE will own a twothirds equity interest in  Y-the Partnership and Advance/Newhouse will own a onethird equity interest.< {4 Y-ԍId. <  Yv-5.` ` As a result, TWE would have interests in cable systems that provide service to  Y_-approximately 8.8 million subscribers, _.4 Y> -ԍPaul Kagan Associates, Inc., Top 100 Cable System Operators as of November 30,  Y) -1994, Cable TV Investor, January 31, 1995 (insert). approximately 14.5% of the subscribers in the  YH-United States.H H4 Y-ԍBased upon the total number of subscribers nationwide, using Paul Kagan Associates,  Y-Inc., The Cable TV Financial Databook 1415 (1994); Paul Kagan Associates, Inc., Top 100  W-Cable System Operators as of November 30, 1994. H The Partnership's total value has been estimated at approximately $8.4  Y1-billion. 1Q 4 Y3-ԍRobichaux, Time Warner to Put Some Cable Systems Into Venture With Newhouse  Y-Operations, Wall St. J., Sept. 13, 1994, at A2.  Y -6.` ` The applications to transfer the Advance/Newhouse CARS licenses and the TWE CARS licenses to the Partnership were placed on public notice on December 7, 1994. A supplemental public notice was issued on December 19, 1994, establishing a pleading cycle for oppositions and replies. Talk TV, a Florida corporation which produces programming for distribution over cable television systems using a live callin format, filed a  Y-Petition to Deny the transfer of the CARS licenses. 4 Y0-ԍTalk TV, Inc., Petition to Defer and Deny, January 13, 1995, at 3 ("Petition"). Vision filed an Opposition to Talk  Yy-TV's Petition,y4 Y-ԍVision Cable Communications, Inc., Opposition to Petition to Defer and Deny,  Y -Jan. 26, 1995 ("Opposition"). On January 20, Vision filed a Request For Clarification, Or,  Y!-In the Alternative, Motion for Extension of Time. Since there was no opposition to this motion, the request was granted and Vision was given until January 26, 1995 to reply. and Talk TV filed a Reply to Vision's Opposition.r y4 Y>$-ԍTalk TV, Inc., Reply to Opposition to Petition to Defer and Deny, Feb. 7, 1995  Y)%-("Reply"). On February 10, 1995, Talk TV, Inc., filed a Submission Of Original  Y&-Declarations referenced in Talk TV's February 7, 1995, Reply To Opposition To Petition To  Y&-Defer and To Deny.  On March 8, Talk TV filed a letter alleging violations of the"&0*(('"  Y-Commission's ex parte rules by Advance/Newhouse. Talk TV's letter referred to a March 3 letter from TWE to Deborah Klein which disclosed the existence of oral communications between AdvanceNewhouse and FCC personnel. On March 13, Advance/Newhouse filed a response to Talk TV's letter disclosing the substance of those communications. On March 16, Talk TV filed a response to Advance/Newhouse's March 13 letter, again alleging  Y-violations of the ex parte rules arising out one of the same communications referred to in Talk TV's March 8 letter. On March 17, TWE filed a letter which was served on Talk TV.  Y-The ex parte matter has been referred to the Office of the Managing Director, see 47 C.F.R. 1.1212, 1.1214, and does not necessitate delay in the disposition of the license transfers. r "y 0*((aaJ"Ԍ X-ԙ  X-III.Petition to Defer and Deny and Opposition   Y-7.` ` In its Petition, Talk TV asserts that Vision is not qualified to be a Commission licensee and that, therefore, the Commission should deny the transfer applications, which would transfer the CARS licenses from Vision to a partnership in which Vision's parent will  Yv-be a onethird owner.Av 4 Y-ԍId. at 10.A Talk TV alleges that Vision does not have the proper character to be a licensee because it improperly denied Talk TV's request to lease time on Vision's  YH-Clearwater, Florida cable television system.IHc 4 Y\-ԍPetition at 5. Talk TV asserts that, in several instances in the past three years, it has approached Vision to make leased access channel capacity available to Talk TV on Vision's Clearwater, Florida cable system and that it has been unsuccessful in those attempts. I Talk TV has a pending lawsuit, which alleges  Y1-that Vision's denial violates the Cable Act.O14 Y-ԍSee infra note 23.O  Y -8.` ` Talk TV asserts that the Commission should apply to CARS license applicants the qualification standards the Commission has established for broadcast applicants in the  W -Policy Regarding Character Qualifications in Broadcast Licensing ("Character Policy  Y -Statement").H  Y -ԍ102 FCC 2d 1179 (1986).H In that statement, the Commission said that in determining the qualifications for holding a Commission broadcast license, the Commission will examine an applicant's character, including past misconduct of an applicant. In making this determination, the Commission will consider the willfulness, frequency, and currency of an applicant's misconduct, the participation of an applicant's managers and owners, and any efforts made  YM-by an applicant to remedy the wrongdoing.ML4 YJ&-ԍCharacter Policy Statement, 102 FCC 2d at 1227 28.Ă Talk TV asserts that Vision's denial of Talk TV's leased access requests demonstrates willful violations of the Commission's rules, a type"60*((aa "  Y-of misconduct encompassed by the Character Policy Statement.Q4 Yy-ԍPetition at 1011. Q Talk TV asserts this is a sufficient reason to deny a license transfer to Vision.  Y-9.` ` Talk TV urges further that, rather than acting on the petition to deny at this time, the Commission may wish to defer action on the CARS transfer applications pending  Y-resolution of the court proceeding.{4 Y-ԍId. at 1.  CASE  Complaint, Talk TV, Inc. v. Vision Cable of Pinellas, Inc., Civ. Action No. 9554CIVT24B (M.D. Fla. filed Jan. 13, 1995). Following resolution of that proceeding, the Commission could designate the applications for hearing. By proceeding in this manner, the Commission can avoid having both the Court and the Commission make factual  YJ-determinations on the same matters.IJ4 Y-ԍId. at 12. I  Y - 10.` ` In its Opposition, Vision asserts that (1) Talk TV has chosen an inappropriate  Y -vehicle by which to assert its leased access complaint,I 4 Y-ԍOpposition at 38.I (2) Talk TV lacks standing to file a  Y -petition to deny,@ }4 Y-ԍId. at 5.@ and (3) Talk TV's discussion of the Commission's remedies for licensee  Y -misconduct is inapplicable to the instant situation. 0 4 Y-ԍId. at 15. Vision contends that Talk TV mistakenly discussed the remedy for  Y-misconduct by broadcast licensees rather than cable television licensees. Id.  at 1516. Vision contends that a grant of the CARS license assignments would in no way affect Talk TV's ability, in its pending court action against Vision Cable of Pinellas, Inc., to recover damages and restore access to  Y-Vision's cable system.: 4 Y-ԍId.:  Yd- 11.` ` Vision's first argument is that Section 612 of the Cable Television Consumer Protection and Competition Act of 1992 provides for specific and, by inference, exclusive remedies for persons with complaints arising under the Act's leased access provision. Vision states that the appropriate remedies are either a district court action or a petition to the  Y-Commission for relief.4 Y:$-ԍ 612(d)36(e) of the Communications Act of 1943, as amended, ("Communications Act"), 47 U.S.C. 532; 76.975(b) of the Commission's Rules. Vision argues that Talk TV has missed the 60day procedural deadline set out in Commission rules for filing petitions for relief. Thus, Talk TV's only appropriate course of action is to pursue its pending court case. In these circumstances,"0*((aa" Vision asserts, Talk TV should not be permitted to evade the leased access procedures by  Y-asserting its leased access claims in this CARS license transfer proceeding.h4 Yb-ԍOpposition at 5, citing 47 C.F.R. 76.975(d).h  Y- 12.` ` Vision's second argument is that Talk TV is not a "party in interest," and,  Y-therefore, lacks standing to object to the license transfer applications.{4 Y-ԍId. at 5, citing Pinelands, Inc., 18, 7 FCC Rcd 6058 (1992) ("Pinelands"). Vision asserts that in order to file a petition to deny, Talk TV must show that it is a party in interest according to Section 309(d)(1) of the Communications Act, which states that any "party in interest" may  Y_-file a petition to deny an application for a license. _.4 Y> -ԍOpposition at 5; 47 U.S.C. 309(d)(1). License transfer applications are governed by Section 310(d) of the Communications Act, which directs the Commission to dispose of the applications pursuant to procedures established by Section 308 of the Act. Section 308 gives the Commission authority to grant licenses. Section 309(d)(1) states that any party in interest may file a petition to deny a license application.  Y1- 13.` `  SERVICES Vision's third argument is that Talk TV's misconduct assertions are irrelevant to the Commission's determination of whether to approve the CARS transfer applications,  Y -because the Character Policy Statement cites factors only relevant to broadcast licensees, not  Y -to CARS licensees.N! 4 Y$-ԍOpposition at 16.N Vision states that the FCC has recognized that character issues carry less weight in the context of nonbroadcast licenses, such as CARS, than they do in the  Y -broadcast license context._" 8 4 Y-ԍId. at 1617; see CablecomGeneral, Inc.,  49 RR 2d 1057, 1060 (1981)  Y-("Cablecom") ("[t]here is nothing inherent in the public interest standard which mandates that we evaluate CARS . . . and broadcast transfers in an identical manner . . . ."). _ Vision notes that in CablecomGeneral, Inc., the Commission distinguished CARS licenses from broadcast licenses, the type of license discussed in the  Y-Character Policy Statement. Vision asserts that the Commission has stated that while "[b]roadcast licensees have a special responsibility for the content of the information which they disseminate to the public," "CARS licenses do not afford the licensee a medium to communicate directly with the public; but instead merely provide a medium by which the cable system operator relays programming produced by others between and among other  Y#-communications facilities."e##4 Y#-ԍPetition at 17; Cablecom, 49 RR 2d at 106061.e Vision cites a Commission opinion stating that a CARS licensee "operates as a mere conduit for the transmission of information" and does not have  Y-"control or responsibility for the content of the information . . . which it transmits."X$r4 Y'-ԍCablecom, 49 RR 2d at 1061.X For"%$0*((aa"  Y-these reasons, Vision alleges that the broadcast standards set forth in the Character Policy  Y-Statement should not be applied to persons seeking to transfer CARS licenses and concludes that the misconduct assertions made by Talk TV should be dismissed.  Y- 14.` ` In its Reply, Talk TV disagrees with Vision's argument that violations of the leased access rules may only be considered in a federal district court proceeding or in a  Yz-complaint filed with the Commission.]%z4 Y-ԍOpposition at 35; Reply at 34.] Talk TV contends that Section 309(d)(1) of the Communications Act establishes a broad right for any party in interest to file a petition to deny any application subject to Section 309(b) of the Communications Act, including  Y5-applications for CARS licenses.D&5{4 Ya -ԍReply at 34.D hh,  Y -15.` ` Talk TV also disagrees with Vision's claim that Talk TV lacks the requisite  Y -standing to file a petition to deny.]' .4 Y-ԍOpposition at 57; Reply at 45.] Talk TV asserts that a party has standing to contest an  Y -action that results in a concrete economic injury to that party.( 4 Yk-ԍOrange Park Florida T.V., Inc. v. FCC, 811 F.2d 664, 673 (D.C. Cir. 1987). Talk TV contends that it has  Y -suffered economic injury sufficient to give it standing.B) 4 Y-ԍReply at 5.B  Y-16.` ` Talk TV states that Vision's reliance on Cablecom is misguided, since that case involved the assignment of CARS licenses from RKO to a third party despite the  Yh-findings of misconduct against RKO's broadcast stations.B*hG 4 Y`-ԍId. at 56.B Talk TV asserts that the instant  YQ-case is different from Cablecom because the proposed assignment will result in the formation  Y<-of a partnership in which Vision's owners will have an interest. Thus, unlike Cablecom, the Petition questions the qualifications of both the transferor and transferee, rather than the  Y-transferor alone.p+ 4 Y -ԍId. at 56, citing Cablecom, 49 RR 2d at 1060 n.10.p Talk TV also cites language in Cablecom in which the Commission said  Y-that the decision "should not be read overly broad."d, 4 YY#-ԍCablecom, 49 RR 2d at 1063 n. 23.d "`,0*((aa"Ԍ X-ԙ IV. Discussion  Y-17.` ` Talk TV lacks the qualifications set by the Communications Act for filing a petition to deny. Section 309(d)(1) of the Act states that any "party in interest may file with  Y-the Commission a petition to deny any application."-4 Y-ԍSee Section 309(d)(1) of the Communications Act. Section 309(d)(1) also states that the petition should contain specific allegations of fact sufficient to show that petitioner is a party in interest. A party in interest has been defined as "an individual or entity which is able to establish that a grant of the instant application would result in, or be reasonably likely to result in, some injury of a direct, tangible or substantial  Y_-nature."._M4 Y] -ԍSee Pinelands  18, 7 FCC Rcd at 6063; Telesis Corp., 68 FCC 2d 696 (1978). Talk TV's assertion that it will suffer injury as a result of the grant of the instant application is incorrect. Vision's allegedly improper denial of Talk TV's leased access requests, not the proposed license transfers, has been the proximate cause of Talk TV's  Y -injury, if any. Nonetheless, as in the Commission's Pinelands decision, the Bureau will consider the allegations made by Talk TV as part of the Commission's "independent public  Y -interest analysis."\/ 4 Y-ԍPinelands  18, 7 FCC Rcd at 6063.\  Y - ` `  Y -18.` ` Vision has characterized Talk TV's Petition as an inappropriate vehicle for Commission consideration of Vision's alleged improper denial of Talk TV's leased access request. Talk TV, however, is not asking us to resolve its leased access complaint in the context of this Petition. Nor is it seeking relief for Vision's alleged violation of the leased access rules. Rather, Talk TV is asserting that the proposed license transfers will not serve the public interest because the character of one of the transferees, Vision, disqualifies it from receiving a license. As will be discussed below, a transferee's character is an appropriate factor to consider in determining whether Commission approval of a CARS license transfer application serves the public interest.  W-  Y-19.` `  BUREAU Section 310(d) provides that in granting a license transfer, the Commission must find that the "public interest, convenience, and necessity will be served" by the  Y-transfer.G04 Y!-ԍ47 U.S.C. 310(d).G In Cablecom, the Commission noted that Section 310(b) of the Communications Act requires that transfer applications be construed as if the proposed transferee were  Y-applying ab initio for the license under Section 308(b) of the Act.n1d 4 Y$-ԍCablecom, 49 RR 2d at 1060 n.10; 47 U.S.C. 310(b).n Section 308(b) provides that applicants (including prospective transferees) "shall set forth such facts as the Commission . . . may prescribe as to the citizenship, character, and financial, technical, and"T 10*((aak"  Y-other qualifications of the applicant to operate the station."X24 Yy-ԍ47 U.S.C. 308(b) (emphasis added).X In Teleprompter Corporation,F3y4 Y*-ԍ87 FCC 2d 531 (1981).F the Commission stated that in evaluating CARS license transfers, "we must make a judgment as to how that applicant will conduct itself in the future. We look to an applicant's past  Y-conduct . . . as a guide to how an applicant is likely to operate its station in the future."K4*4 Y-ԍId. 83, at 571.K Because of the different nature of the services provided the public by broadcast and CARS  Y-licensees,h54 Y -ԍSee supra para. SERVICES13.h the Commission need not employ the same method in evaluating CARS license  Yx-transfer applications as it uses for broadcast licensees.X6x4 Y-ԍCablecom, 49 RR 2d at 1060.X But in deciding whether to approve the transfer applications, the Commission must decide whether the Partnership is a "qualified  YJ-applicant" transferee.7JC 4 Y>-ԍThis review contrasts with a review of the transferor's character qualifications, which  Y'-would serve no valid purpose in this proceeding.  See Cablecom, 49 RR 2d at 106162. Although in Cablecom, the Commission drew a number of important distinctions between CARS licensees and broadcast licensees, the Commission also noted  Y -"that there are no material questions as to the proposed transferee's qualifications to operate  Y -any of these stations."M8 4 Y-ԍ49 RR 2d at 1060 n.10.M  Y -20.` ` The Commission's Character Policy Statement, which the Commission established for broadcast licensees, provides a reasonable analytic framework to use in determining whether the public interest would be served by approving a CARS license transfer to a particular transferee. The Commission has previously applied the character  Y-qualifications expressed in the Character Policy Statement when evaluating the character  Yj-qualifications of prospective licensees for similar services.99j 4 Y-ԍSee Western Telecommunications, Inc., 3 FCC Rcd 6405 (1988) (using the broadcast policy statement as guidance when evaluating the qualifications of microwave radio  Y!-licensees); A.S.D. Answer Service, Inc., 1 FCC Rcd 753 (1986) (applying the broadcast  Yj"-character standards to a Domestic Public Radio Service (DPLMRS) application). See also  WU#-Policy Regarding Character Qualifications in Broadcast Licensing, Memorandum Opinion  Y>$-and Order  18, 1 FCC Rcd 421, 424 (1986) (Gen. Dkt. No. 81500) (Common carrier character issues "are adjudicated on a casebycase basis without the guidance of a specific policy statement. As a result, reference is occasionally made in common carrier cases to broadcast policies and precedents as aids in resolving character issues.") "j 90*((aa:"Ԍ Y-ę21.` ` In its Character Policy Statement, the Commission stated that "future inquiries into an applicant's basic character eligibility will be narrowed to focus on the likelihood that an applicant will deal truthfully with the Commission and comply with the Communications  Y-Act and our rules and policies."m:4 Y6-ԍCharacter Policy Statement 7, 102 FCC 2d at 1183.m In examining the likelihood that, in the future, a licensee applicant will comply with the Act and the Commission's rules, the Commission considers "the willfulness of the misconduct, the frequency of such behavior, and its currency," as well as the seriousness of the misconduct, the nature of the participation, if any, of a licensee's  Ya-managers and owners, and a licensee's efforts to remedy the wrong.b;a{4 Y -ԍId. 10206, 102 FCC 2d at 122729.b  Y3-22.` ` In order to be entitled to a hearing, a party must show that "a grant of the  Y -application would be prima facie inconsistent with the public interest."< .4 Y-ԍGencom Inc. v. FCC, 832 F.2d 171, 180 (D.C. Cir. 1987); 47 U.S.C. 309(d)(1) (2). Courts have determined that "the decision of whether or not hearings are necessary or desirable is a  Y -matter in which the Commission's discretion is paramount."= 4 Yi-ԍGencom Inc., 832 F.2d at 181, (quoting United States v. FCC, 652 F.2d 72, 91 (D.C. Cir. 1980)). Talk TV's Petition proffers but a single instance of alleged, but unadjudicated, misconduct. Nor has it presented information suggesting that the alleged violation involves bad faith rather than simply a dispute over the application of the rules and their requirements.  Y{-23.` ` Talk TV's Petition does not allege sufficiently egregious conduct by Vision to support a decision to defer granting the license transfers until after the court decides the leased access issues. Nor is it necessary to conduct an independent fact finding investigation on the leased access issue at this time. Further, assuming Talk TV's leased access allegations against Vision to be true, such conduct is an insufficient basis on which to deny the license transfer applications. Denial of a license to operate multiple cable systems is a significantly greater penalty than those prescribed by the Commission in its leased access  Y-rules.>Hf 4 Y -ԍSection 612(d) of the Communications Act provides that any person with a leased access complaint may bring an action in U.S. district court, and that if the court finds that the channel capacity sought was not made available, the court may order such system to make it available, and may award actual damages if appropriate. 47 U.S.C. 532(d). The leased access rules also provide that the aggrieved person may petition the Commission for relief upon a showing of prior adjudication of Section 612 violations, and that the Commission may establish any further rule or order necessary to comply with the section. 47 U.S.C. 532(e). If, however, a subsequent decision demonstrates that Vision has violated the" v>0*((aa" Communications Act or the Commission's rules or policies, or has engaged in  Y-anticompetitive conduct,K?4 Yb-ԍSee Character Policy Statement 42 44, 102 FCC 2d at 120003 (when business misconduct rises to the level of an adjudicated violation of anticompetitive or antitrust laws, then the Commission could consider the activity relevant to an applicant's character). K then Talk TV may bring that decision to the Bureau's attention in a subsequent proceeding.  Y-24.` ` In the absence of any showing by Talk TV or anyone else that approval of the applications to transfer CARS licenses to the Partnership would not be in the public interest,  Yv-the Bureau denies Talk TV's Petition.  Y_-  XH-  X1-III. Ordering Clauses  Y -25.` ` Accordingly, IT IS ORDERED that the pending CARS license transfer applications referenced herein are GRANTED.  Y - 26.` ` 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 (1993). ` `  hh,FEDERAL COMMUNICATIONS COMMISSION ` `  hh,Meredith J. Jones ` `  hh,Chief, Cable Services Bureau