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Attachment A, below, lists the cable communities that are served by these four systems. A group of local franchising authorities with jurisdiction over CTEC's regulated cable service  xrates in many of the affected communities ("Michigan LFAs") jointly filed the only opposition to CTEC's  S-Petition ("Opposition")." {O- x;ԍOpposition to Petition for Special Relief, In the Matter of CTEC Cable Systems of Michigan, Inc., Petition for  xhSpecial Relief, CSR4674D (filed March 25, 1996). The Michigan LFAs consist of Coopersville City, Grand Haven  xJCity, Grand Haven Twp., Robinson Twp., Spring Lake Village, Holland Twp., Park Twp., Zeeland City, and Zeeland  yOV-Twp.  S\- ` 2x2.` ` Section 623(i) of the Communications Act of 1934, as amended ("Communications Act"),  xrequires that the Commission design rate regulations that reduce the administrative burdens and the cost  S - xLof regulatory compliance for cable systems with 1,000 or fewer subscribers.>  yOF$-ԍ47 U.S.C.  543(i).> Accordingly, in the course  xof establishing the standard benchmark and costofservice ratemaking methodologies generally available  S- x>to cable operators, the Commission adopted various measures aimed specifically at easing regulatory"* ,**88"  S- xburdens for these smaller systems.hm {Oh- xԍSee, e.g., Report and Order and Further Notice of Proposed Rulemaking in MM Docket No. 92266, FCC 93 {O2- x177, 8 FCC Rcd 5631 (1993); Second Order on Reconsideration, Fourth Report and Order, and Fifth Notice of  {O- xProposed Rulemaking in MM Docket No. 92266, FCC 9438, 9 FCC Rcd 4119 (1994); Fifth Order on  {O- xReconsideration and Further Notice of Proposed Rulemaking in MM Docket Nos. 93215 & 93266, 9 FCC Rcd  {O- x5327 (1994); Eighth Order on Reconsideration in MM Docket Nos. 92266 & 93215, FCC 9542, 10 FCC Rcd 5179 (1995). In the Small System Order, the Commission further extended small  S- xzsystem rate relief to certain systems that exceed the 1,000subscriber standard.UJhm {O-ԍSmall System Order, 10 FCC Rcd at 7406.U These systems were  xldeemed eligible for small system rate relief because they were found to face higher costs and other  S-burdens disproportionate to their size. hm {O - x[ԍId. at 7407. More recently, Congress amended Section 623 of the Communications Act to allow greater  xideregulation for "small cable operators," defined as operators that "directly or through an affiliate, [serve] in the  xaggregate fewer than 1 percent of all subscribers in the United States and [are] not affiliated with any entity or  xKentities whose gross annual revenues in the aggregate exceed $250,000,000." Telecommunications Act of 1996  xZ("1996 Act"), Pub. L. No. 104104,  301(c), 110 Stat. 56, approved February 8, 1996; Communications Act,   x623(m), 47 U.S.C.  543(m). Pursuant to this amendment, the rate regulation requirements of Sections 623(a), (b)  xand (c) do not apply to a small cable operator with respect to "(A) cable programming services, or (B) a basic service  xhtier that was the only service tier subject to regulation as of December 31, 1994," in areas where the operator serves  {OH-50,000 or fewer subscribers. Id.  S:- ` }x3.` ` The Small System Order defines a small system as any system that serves 15,000 or fewer  S- xsubscribers.Uhm {Od-ԍSmall System Order, 10 FCC Rcd at 7406.U The Commission recognized that systems with no more than 15,000 subscribers were  x/qualitatively different from larger systems with respect to a number of characteristics, including: (1)  S- xkaverage monthly regulated revenues per channel per subscriber; (2) average number of subscribers per  S- xmile; and (3) average annual premium revenues per subscriber.: Bhm {O~-ԍId. at 7408.: The magnitude of the differences between  x.the two classes of systems as to these characteristics indicated that the 15,000 subscriber threshold was  xthe appropriate point of demarcation for purposes of providing for substantive and procedural regulatory  S$ -relief.2 $ hm {O-ԍId. 2  S - ` x4.` ` Rate relief provided under the Small System Order and the Commission's rules is also  S - xNavailable only to a small system affiliated with a small cable company, which is defined as a cable  S - xoperator that serves a total of 400,000 or fewer subscribers over all of its systems.2 fhm {O#-ԍId. 2 A small system is  xkdeemed affiliated with a cable company if the company "holds more than a 20 percent equity USESESUSinterest  S6- xk(active or passive) in the system or exercises de jure control (such as through a general partnership or"6 ,`(`(88;"  S- xmajority voting shareholder interest)."C hm {Oh-ԍId. at 741213, n.88.C The Commission adopted this threshold because it roughly  S- xcorresponds to $100 million in annual regulated revenues, a standard the Commission has used in other  S- xcontexts to identify smaller entities deserving of relaxed regulatory treatment.= Zhm {O-ԍId. at 740911.= The Commission found  S- xthat cable companies exceeding this threshold would find it easier than smaller companies to attract the  S`- xfinancing and investment necessary to maintain and improve service.:`hm {O-ԍId. at 7411.: In addition, the Commission  xdetermined that cable companies that exceeded the small company definition "are better able to absorb  S-the costs and burdens of regulation due to their expanded administrative and technical resources.":~hm {O. -ԍId. at 7409.: x` `  S- ` ox5.` ` In addition to adopting the new categories of small systems and small cable companies,  S- xthe Small System Order introduced a form of rate regulation known as the small system costofservice  Sr- xmethodology.=rhm {O"-ԍId. at 741828.= This approach, which is available only to small systems owned by small cable companies,  x[is more streamlined than the standard costofservice methodology available to cable operators generally.  xyIn addition, the small system rules include substantive differences from the standard costofservice rules  x[to take account of the proportionately higher costs of providing service faced by small systems. Eligible  S - x[systems establish their rates under this methodology by completing and filing FCC Form 1230. In order  xjto qualify for the small system costofservice methodology, systems and companies must meet the new  S - xsize standards as of either the effective date of the Small System Order, or on the date thereafter when  S\-they file the documents necessary to elect the relief they seek.\hm {O-ԍId. at 7413. The effective date of the Small System Order was August 21, 1995.  S - `  x6.` ` Cable systems that fail to meet the numerical definition of a small system, or whose  x[company do not qualify as small cable companies, may submit petitions for special relief requesting that  xthe Commission grant a waiver of its rules to enable the petitioning systems to utilize the various forms  S- x.of rate relief available to small systems owned by small cable companies.=4 hm {Oh-ԍId. at 741213.= The Commission stated that  Sl- xpetitioners should demonstrate that they "share relevant characteristics with qualifying systems."1l hm {O -ԍId.1 Other  xlpotentially pertinent factors include the degree by which the system fails to satisfy either or both  xdefinitions and evidence of increased costs (e.g., lack of programming or equipment discounts) faced by  S- xthe operator.1X hm {O$-ԍId.1 If the system fails to qualify for relief based on its affiliation with a larger cable company,  xthe Commission will consider "the degree to which that affiliation exceeds our affiliation standards, and  xwhether other attributes of the system warrant that it be treated as a small system notwithstanding the",`(`(88#"  S- xpercentage ownership of the affiliate."2hm {Oh-ԍId. 2 The Commission also stated that "a qualifying system that seeks  xjto obtain programming from a neighboring system by way of a fiber optic link, but that is concerned that  xinterconnection of the two systems may jeopardize its status as a standalone small system, may file a  S- xpetition for special relief to ask the Commission to find that it is eligible for small system relief.":Zhm {O-ԍId. at 7413.: The  x=Commission specifically stated that this list of relevant factors was not exclusive and invited petitioners  S8-to support their petitions with any other information and arguments they deemed relevant.18hm {O -ԍId.1  S- II.xBACKGROUND  S-  S- xA.` ` CTEC's Petition  SH - `  x7.` ` CTEC filed its Petition on behalf of four of its cable systems Allendale, Grand Haven,  xHolland and Hudsonville. CTEC states that each of the four systems serves fewer than 15,000  S - xsubscribers. ~hm yO- xKԍThe systems serve the following number of subscribers: Grand Haven 12,286; Allendale 3,674; Holland  {O- 12,887; and Hudsonville 2,185. See Petition, Exhibit A. CTEC thus states that, when considered individually, each system clearly falls within the  S - xdefinition of small system in the Small System Order and is "entitled" to establish regulated rates in  S - xyaccordance with the small system costofservice methodology set forth in the Small System Order.f hm {O"-ԍPetition at 12; Small System Order, 10 FCC Rcd at 7406.f C xTEC states that the four systems will be consolidated by fiber optic links, and indicates that the interconnected systems will serve a total of 31,032 subscribers.  S - ` `x8.` ` CTEC asserts that it also qualifies as a "small cable company" under the Small System  S- xOrder" because, as of December 31, 1995, CTEC and its "affiliated companies" served a total of 372,773  S- xsubscribers.ij hm {O-ԍPetition at 1, n.2; Small System Order, 10 FCC Rcd at 7408.i On May 20, 1996, we denied CTEC's petition contending that it was a small cable  S-company.l\ hm {O4- xiԍId. See Memorandum Opinion and Order, In the Matter of CTEC Cable Systems of Michigan, Inc., Small  xSystem Filings to Support Cable Programming Service Rate Increases, DA 96801, 11 FCC Rcd 6189, 6193 (1996)  {O -("May 20, 1996 CTEC Order") appeal pending. l  SH- ` x9.` ` CTEC requests that the Commission waive its regulations to the extent necessary to  x?permit these four systems to "retain" their eligibility for small system relief after the systems are  S- x>interconnected "even though the aggregate number of subscribers will exceed the 15,000 threshold."6 hm yO%-ԍPetition at 2.6  S- xPursuant to the Small System Order, CTEC attempts to demonstrate that the combined system is entitled  x to small system status because, notwithstanding the combined system's service to more than 31,000",`(`(88"  S- xxsubscribers, the combined system will continue to "share relevant characteristics with qualifying systems."hm {Oh-ԍPetition at 2; Small System Order, 10 FCC Rcd at 741213.  See supra para. 6.  xSpecifically, the combined system will:(a)yield an average monthly regulated revenue per channel per  S- x[subscriber of $0.57, as compared to $0.86 for the average small system and $0.44 for the average system  x/with more than 15,000 subscribers; (b) serve an average of 34.5 subscribers per mile, versus the 35.3  xsubscribers per mile served by the average small system and 68.7 served by the average larger system;  xkand (c) receive $44.21 in average premium revenue per subscriber, as compared to $41.00 received by  S-the average small system and $73.13 by the average larger system.oZhm {O -ԍPetition at 5. See Small System Order, 10 FCC Rcd at 7408. o  S- ` x 10.` ` CTEC states that the similarity between its combined system and the average small  x system is "even stronger" once a rate adjustment in February 1996 is reflected in rates and revenues.  xSpecifically, the combined system's average monthly regulated revenues per channel per subscriber  xincreases from $0.57 to $0.71, and the average premium revenue per subscriber decreases from $44.21  S -to $40.45, respectively.w hm yO-ԍThe average number of subscribers per mile remains unchanged. Petition at 45.w  S - ` x 11.` ` CTEC contends that according the combined system small system status will serve the  x=public interest, and states that the Commission has previously granted similar petitions for special relief  S - xfrom the threshold requirements of the Small System Order."  |hm {O- xԍPetition at 5 citing Memorandum Opinion and Order, In the Matter of Insight Communications Company, L.P.  {Of-("Insight"), Petition for Special Relief, DA 952334, 11 FCC Rcd 1270 (1995) ("Insight Order")." CTEC states that it faces difficulties in  xnegotiating discounts because of its limited size, and adds that, while these difficulties will not diminish  xappreciably after interconnection of the systems, the benefits of interconnection for subscribers will be  xM"significant." CTEC also states that the resulting increase in capacity will permit it to add a channel  xcalled Music Choice to all of the systems, and will allow CTEC to add other services in the future. C xTEC relates that consolidation will reduce equipment and maintenance costs, and generally improve the  x>quality and reliability of service to subscribers in the relevant areas. In addition, interconnection will permit CTEC to use the headends that are no longer needed to expand service in other smaller areas.  S- xB.` ` Michigan LFAs' Opposition  S- ` x 12.` ` The Michigan LFAs note that, once the four systems that are the subject of the Petition  xare interconnected by fiber optic links, they will serve a total of more than 31,000 subscribers, or more  Sz- xthan double the 15,000 subscriber threshold set forth in the Small System Order. The Michigan LFAs  ST-argue that CTEC's systems are not eligible for small system status.8!Thm yO"-ԍOpposition at 4.8  S- ` 3x 13.` ` The Michigan LFAs argue that CTEC also does not qualify as a small cable company  S- xunder the Commission's definition of that term. Under the Small System Order, a cable system is deemed  S- xto be affiliated with a cable company if the company holds more than 20% equity interest, whether active"h !,`(`(88-"  S- xor passive, in the system or exercises de jure control.j"hm {Oh-ԍSmall System Order, 11 FCC Rcd, 11 FCC Rcd at 741213, n.88.j The Michigan LFAs note that CTEC holds a 40%  xinterest in Megacable, and argues that, when these 177,000 subscribers are added to CTEC's 372,733 domestic subscribers, CTEC serves well over the 400,000 threshold.  Sb- ` x 14.` ` The Michigan LFAs state that the regulations adopted in the Small System Order are  S<- x=intended to provide relief to small cable companies who "do not have access to the financial resources or  S- xother purchasing discounts of larger companies."s#Zhm {O -ԍOpposition at 2 quoting Small System Order, 10 FCC Rcd at 7408. s They believe that CTEC errs in arguing that  S- xyMegacable's subscribers "are not under the jurisdiction of the FCC and [thus] are irrelevant;"G$hm yOx -ԍOpposition at 3; Petition at 2.G rather, the  S- xrelevant question is whether CTEC has access to the "resources it needs to grow."g%|hm {O -ԍOpposition at 3 quoting Small System Order at 7412. g The Michigan LFAs  x/state that, for purposes of small system relief, the Commission is not regulating CTEC's Megacable  x]subscribers, but is merely determining the overall number of subscribers served by CTEC and its  SL -affiliated systems.7&L hm {O-ԍId. at 3.7  S - ` `x15.` ` The Michigan LFAs state that the definition of a small cable company is not limited to  xinclude only subscribers in the United States, and that location of subscribers is not relevant to measuring  xthe financial resources of a cable operator. The Michigan LFAs state that CTEC and its affiliates  x=(including noncable assets) have annual revenues in excess of $250 million, and that CTEC's "ultimate"  xparent company, Peter Kiewit and Sons, Inc., has approximately $3 billion in annual revenues. The  xMichigan LFAs contend that, unlike other small cable companies that are truly entitled to small system  xstatus, CTEC's interconnected system has easy access to "vast" financial, technical and managerial  S- xresources.7'hm {O$-ԍId. at 4.7 According to the Michigan LFAs, it is "doubtful" that the Commission intended small system  S-relief for a cable company of CTEC's size and resources.(2 hm {O- xԍId. at 34. In further support of their contention that CTEC may not qualify for small system status, the  {OX- xMichigan LFAs assert that CTEC also is not a small cable company under the 1996 Act. In the Order and Notice  {O"- xhof Proposed Rulemaking, CS Docket No. 9685, FCC 96154 (1996), the Commission defined, for interim purposes  xonly, that a small company is one who serves fewer than 617,000 subscribers and whose annual revenues, when  xcombined with the total annual revenues of all of its affiliates, do not exceed $250 million in the aggregate. While  xhthe Michigan LFAs appear to concede that CTEC falls within this numerical threshold, they argue that CTEC fails  xto qualify because it is affiliated with entities whose gross annual revenues in the aggregate exceed $250 million.  xxWe do not address this argument here because the 1996 Act established a definition of a small cable company for  xpurposes of determining whether a particular cable system is subject to rate regulation, which is not at question in  xZthis Order, with respect to CTEC. Here we are called upon to consider whether CTEC's interconnected system is eligible for streamlined costofservice regulation. "(,`(`(88"Ԍ S- ` x16.` ` The Michigan LFAs add that, even if CTEC is granted small system status, it is  xprohibited from filing a costofservice showing in the areas regulated by the Michigan LFAs. The  xMichigan LFAs state that, in order to resolve a number of rate regulation disputes, CTEC entered into  x[a contract with the Michigan LFAs and approximately 70 other local franchising authorities that regulate  x[service provided by CTEC and its affiliates in Michigan (Settlement Agreement"). The Michigan LFAs  xstate that, under the Settlement Agreement, CTEC expressly agreed to "not file a new costofservice  xjanalysis...with the Community or the FCC for the purpose of changing the price cap" until September  S- x1, 1997.a)hm yOP-ԍOpposition, Exhibit E, Settlement Agreement, at para. 13.a CTEC also agreed to certain rate reductions and refunds, and to withhold any rate increases  xfor regulated rates until April 1, 1995, and thereafter to raise regulated rates only to reflect inflation or  S-programming cost increases until September1, 1997.>*Xhm {O -ԍId. at para. 12.>  SH - ` Rx17.` ` The Michigan LFAs state that "the key" for the Commission is that the Settlement  x/Agreement resolved major disputes between CTEC with respect to preceding costofservice filings  S - x]submitted by CTEC to the involved local franchising authorities.8+ hm yO-ԍOpposition at 9.8 The Michigan LFAs urge the  x=Commission to safeguard its general policy of encouraging the settlement of rate disputes by prohibiting  xCTEC from now reneging on a critical element of this agreement, namely, its voluntary moratorium on  S - x.the filing of costofservice showings until September 1, 1997., zhm yO- xKԍThe Commission has adopted an alternative interim incentive approach to rate regulation that allows cable  xoperators and regulatory authorities a measure of flexibility in resolving rate disputes. Under this approach, a cable  xoperator may enter into a "Social Contract" with its customers, as represented by the Commission or the relevant  {O- xLFAs, to resolve outstanding rate disputes. Report and Order and Further Notice of Proposed Rulemaking, 9 FCC  {O-Rcd 4527, 4677 (1994); Second Report and Order, First Order on Reconsideration, 11 FCC Rcd 2220, 2281 (1996). If CTEC is permitted to raise its rates  x\in a manner that is inconsistent with the Settlement Agreement, then the affected subscribers will not  xreceive the full benefits they are due under the agreement. The Michigan LFAs argue that CTEC is not  xeligible for streamlined small system relief, or in the alternative, not eligible until after September 1,  S-1997.;-. hm yO-ԍOpposition at 910.;  S- III.xDISCUSSION  S@- xA.` ` Small Cable System  S- ` x18.` ` We begin by comparing the small system subscribership limit of 15,000 to the subscriber  S- xbase of the four systems that are the subject of the Petition.. hm {O&$- xԍSee Small System Order, 10 FCC Rcd at 7412 (relevant factors "include the degree by which the system fails to satisfy either or both definitions.") CTEC states that two of the four systems  xeach serve approximately 12,500 subscribers, while the other two each serve less than 4,000. Each system  xlthus falls within the 15,000 threshold on an individual basis. However, after the four systems are  SP- xinterconnected by fiber optic links, the combined system will serve 31,032 subscribers, or more than twice"P.,`(`(88"  x.the threshold. We find that CTEC's subscribership level of 31,032 exceeds the 15,000 cap by too wide  xa margin to allow us to grant a waiver, and therefore CTEC does not qualify for the small system relief it requests in its petition.  S`- ` x19.` ` It is true that in the Small System Order, the Commission encouraged the interconnection  x.of cable systems where it would provide benefits to subscribers, and invited such parties to petition the  S- xCommission for special relief if the systems shared relevant characteristics with qualifying systems./hm {Oz-ԍSee, e.g., Inter Mountain Order, 11 FCC Rcd at 708687 (citing Small System Order, 10 FCC Rcd at 7413).ġ  S- xHowever, as the Commission also stated in the Small System Order, the "degree by which the system fails  xto satisfy either or both definitions" will be a relevant factor in considering all such petitions for special  S- xrelief.U0Zhm {O -ԍSmall System Order, 10 FCC Rcd at 7412.U We believe that a system should not be entitled to special relief if it, like CTEC's interconnected  xsystem, serves more than twice as many subscribers as are included in the small system definition. The  xyfact that CTEC's interconnected system would exceed the small system threshold by such a great degree  xweighs against CTEC's arguments that its system will nevertheless share relevant characteristics with  xqualifying systems. Therefore, we find that CTEC's interconnected system will not be entitled to special relief.  S - xB.` ` Small Cable Company  S4- ` x20.` ` In the Small System Order, the Commission also required that operators meet the definition  S- xof a small cable company in order to qualify for small system relief.:1hm {O-ԍId. at 7408.: We have previously determined  S- xthat CTEC does not meet the definition of a small cable company.O2j ~hm {O- xKЍMay 20, 1996 CTEC Order, 11 FCC Rcd at 6193. As we noted in the CTEC Order, CTEC International,  xa whollyowned subsidiary of CTEC, owns a 40% interest in Megacable, which serves approximately 177,317  {O- x subscribers. Id. We stated in the Order that we have no basis to conclude that efficiencies, such as cable  x;management expertise and programming or equipment discounts, are less significant because some of the subscribers  xfrom which those efficiencies derive are foreign. We concluded that the Commission adopted the 400,000 subscriber  xthreshold with the intention to include the subscribers over all of a cable operator's systems, including those outside  {O- xthe boundaries of the United States. Id. at 6194. For purposes of determining CTEC's status under the Small  {O- xySystems Order, we therefore included Megacable's subscribers in our determination of CTEC's total subscriber  xcount. When CTEC's 371,319 subscribers are coupled with Megacable's 177,317 subscribers, the total exceeds the  {O- xJ400,000 subscriber cap specified in the Small Systems Order by more than 37%. In addition, it appears that CTEC  x-presents itself to the public, including potential lenders and investors, as a company of over 400,000 subscribers Opposition, Exhibit C. O Nothing submitted in this record  S-persuades us that the decision in our previous order was incorrect or that circumstances have changed.   S-  Sn- ` }x21.` ` Furthermore, CTEC does not appear to face any financial or economic difficulties because  xjof its size. Relief is intended for those systems that lack access to the financial resources, discounts, and  S- xother economic efficiencies of larger companies._3hm {On&-ԍSee Small System Order, 10 FCC Rcd at 7408._ Our conclusion in the Insight Order is instructive in"B3,`(`(885"  S- x.this regard. Insight owned 32 cable systems that complied with the definition of a small cable system.p4\hm {Oh- xЍ29 of the 32 systems served fewer than 15,000 subscribers. Insight Order, 11 FCC Rcd at 1271. The  xremaining three systems were deemed small cable systems because they shared relevant characteristics with the  {O-average small cable system. Id. at 127374.p  S- xWith respect to the definition of a small cable company, although Insight directly served a total of only  xabout 158,000 subscribers, Continental Cablevision, Inc. ("Continental"), which served more than 3 million  S-subscribers, held a 34% ownership interest in Insight, thus in excess of the 20% standard.:5hm {O-ԍId. at 1271.:  S>- ` x22.` ` We noted, however, the Commission's pledge in the Small System Order that if a system  xfails to qualify for the small system definition because it is affiliated with a cable company that serves  x[over 400,000 subscribers, "we will consider...whether other attributes of the system warrant that it be  S- x/treated as a small system notwithstanding the percentage ownership of the affiliate."r6~hm {O -ԍId. at 1272 quoting Small System Order, 10 FCC Rcd at 741213.r Based on the  S- xrecord, we found that Insight gained no meaningful access to financial resources as a result of its  Sz- xaffiliation with Continental. We noted that Continental had never loaned Insight any money and that in  ST - xborrowing money from others, Continental had never guaranteed any indebtedness of Insight.=7T hm {O-ԍId. at 127273.= Moreover,  S, - xInsight had to pay a significantly higher origination fee and interest rate than Continental could secure.  S - xWe also noted that no officers or directors of Continental sat as officers or directors of Insight, that  S - xContinental played no role in the daytoday management of Insight, and that Continental did not provide  S - xInsight with any experience or expertise regarding the raising of debt and capital, programming, budgets,  S - xmergers and acquisitions, or the disposition of property.8 hm {O- xԍId. We found that the obstacles raised by these factors outweighed the benefits of programming discounts  {O-enjoyed by Insight because of its affiliation with Continental. Id. Based on this merely "passive" relationship  Sl-between Continental and Insight, we found Insight eligible for small system status.:9l hm {O -ԍId. at 1273.:  S- ` ~x23.` ` CTEC states only that it faces "disadvantages...in negotiating discounts and in other  S- xmatters." Unlike Insight, however, CTEC fails to provide any financial data to demonstrate these  x[difficulties. CTEC also states that interconnection will allow it to offer a "channel called Music Choice,  S- x"previously available only in the more urban Grand Haven system...to all subscribers to the  xinterconnected system," and that "[t]here will be room for CTEC to add more services in the future as  SX- xwell."6:X hm yO"-ԍPetition at 5.6 CTEC adds that "[e]quipment and maintenance costs will be reduced by consolidation...[a]nd  S0- xthe equipment from the eliminated headends will be used to beef up the capabilities of other, smaller C S- xTEC systems."7; hm {O%-ԍId. at 6.7 CTEC similarly fails to provide any evidence that interconnection and the benefits derived therefrom could or would not be accomplished without grant of the Petition. " ;,`(`(88"Ԍ S- ` x24.` ` Moreover, as the Michigan LFAs note, CTEC and its affiliates have annual revenues in  xexcess of $250 million, and that CTEC's "ultimate" parent company, Peter Kiewit and Sons, Inc., has  xapproximately $3 billion in annual revenues. It is clear that CTEC does not require relief from its  xregulatory burdens in order to attract capital. As the Michigan LFAs state, a company the size of CTEC  x\is not without the resources necessary to improve, manage or maintain its service. We agree with the  x{Michigan LFAs that CTEC is generally not the type of company envisioned to be eligible for the streamlined costofservice process.  S- ` x25.` ` Therefore, we find that not only has CTEC failed to demonstrate that its system is eligible  S-for relief as a small cable system, but it has also failed to meet the definition of a small cable company.t<Xhm yO - xKЍWe need not reach the matter of CTEC's Settlement Agreement. We note that our resolution of CTEC's  xPetition is consistent with our policy of encouraging such arrangements that can resolve outstanding cable rate  yO -regulations issues in a mutually agreeable manner. t  Sp-  SH -V.xORDERING CLAUSES  S - ` x26.` ` Accordingly, IT IS ORDERED that the Petition for Special Relief filed by CTEC Cable  xySystems of Michigan, Inc. requesting a waiver of the Commission rules defining systems subject to small  S -system rate relief IS DENIED.  SX- ` x27.` ` This action is taken pursuant to delegated authority under Section 0.321 of the  S0-Commission's rules.==0hm yO-ԍ47 C.F.R.  0.321.= x` `  hhFEDERAL COMMUNICATIONS COMMISSION x` `  hhMeredith J. Jones x` `  hhChief, Cable Services Bureau" x=,`(`(88"  S- ATTACHMENT A ă  S-Allendale:  S`-  XxAllendale Twp. (MI0487); Blendon Twp. Allendale (MI ); Coopersville City (MI0486); Polkton Twp. (MI0875); Tallmadge Twp. (MI0971); Wright Twp. (MI1339).(#  S-Grand Haven:   XxCrockery Twp. (MI0970); Fruitport Village (MI1536); Grand Haven City (MI0371); Grand Haven   Twp. (MI0372); Robinson Twp. (MI1610); Spring Lake Twp. (MI0374); Spring Lake Village (MI0373).(#  S -Holland:   XxFillmore Twp. (MI1551); Holland Twp. (MI0344); Laketown Twp. (MI0874); Park Twp. (MI0345); Zeeland City (MI0435); Zeeland Twp. Holland (MI0683).(#  S0-Hudsonville:   XxBlendon Twp. Hudsonville (MI0700); Georgetown Twp. (MI1692); Hudsonville City (MI0700); Olive Twp. (MI1521); Zeeland Twp. Hudsonville (MI1522).(#