$//Letter to Paragon Cable Manhattan, DA 95-699//$
$/Part 76 Subpart N, Cable Rate Regulation/$
$/FCC Form 1210 Rate Increase/$
FOR RECORD ONLY
                     Federal Communications Commission
                           Washington, DC  20554
                              March 31, 1995
                                                  

VIA FACSIMILE AND FIRST CLASS U.S. MAIL
                                                  DA 95-699
Arthur H. Harding, Esq.
Fleishman and Walsh, L.L.P.
1400 Sixteenth Street, NW
Washington, DC 20036


               Re:  FCC Form 1210 rate increases for Paragon Cable Manhattan,
                    CUID No. NY0104

Dear Mr. Harding:

On March 10, 1995, Paragon Cable Manhattan ("Paragon") filed with the Cable Services
Bureau a request for approval, on an expedited basis, of a proposed rate increase to its cable
programming service (CPS) tier as computed on FCC Form 1210.  Paragon states that the
increase is necessary to allow it to provide its subscribers with new programming.   Because
we found Paragon's rates to be unreasonable, obligating it to pay refunds to its CPS
subscribers, Paragon must obtain the Bureau's approval before it may increase its CPS tier
rate.  See FCC Form 1210, page 2.  This requirement allows us to monitor subsequent rate
increases, once we have found rates unreasonable.  Paragon states that the proposed
programming and external cost increases are not dependent on the issues involved in the
Bureau's Order imposing refund liabilities, and that approval should not be delayed on that
account. 
 
To date, we have undertaken a full review of Paragon's rates only for the period prior to
May 15, 1994, and have found those rates unreasonable.  Our review of the reasonableness
of Paragon's rates from May 15, 1994 to the present is currently underway.  Paragon's
current request for approval of FCC Form 1210 is for expenses incurred in the fourth quarter
of 1994, and programming expenses to be accrued upon our approval.  

We have reviewed the Form 1210 filing before us, and find no patent defects.  We believe
that the impetus behind Paragon's request is to provide its subscribers with new
programming in the above-noted community, and that approval of Paragon's instant request
will encourage this development.  Our permitting the requested increases is on an interim
basis only, and is subject to our determination of the reasonableness of Paragon's CPS rates
for the period beginning May 15, 1994, including subsequent changes to the rates filed on
Paragon's FCC Form 1200.  Thus, although we allow the requested increase for new
programming, the increased rate which Paragon may charge is potentially subject to refund if
our review of its FCC Form 1200 and Form 1210 filings finds that Paragon's underlying
CPS rate is unreasonable.

                                   Sincerely,



                                   Meredith J. Jones
                                   Chief,
                                   Cable Services Bureau