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In the Matter of Comcast Social Contract with the FCC
Before the Federal Communications Commission
Office of the Secretary
Federal Communications Commission
1919 M Street, N.W.
Washington, D.C. 20554
Attention: Cable Services Bureau
In the Matter of
Comcast Social Contract with the FCC
June 10, 1997
To Whom It May Concern,
Thank you for the opportunity to submit these comments pertaining to the Comcast Social Contract pending before you.
As Comcast of Indianapolis has already launched a migrated product tier (MPT), it appears that for the system we have jurisdiction over, the proposed contract will not impose an unnecessary financial burden upon its subscribers. Many of the requirements of Comcast in this social contract are already covered in our franchise agreement with them.
The Area Vice President, who manages the Indianapolis and Ft. Wayne operations, has represented to our local franchising authority (LFA) that Comcast fully intends to hook up all public libraries that their plant passes with free cable modem service. This was conveyed after we expressed a concern regarding the language in the Social Contract that speaks to a minimum of 250 libraries being connected. That raised a question as to which libraries would be left out should Comcast stop at 250 libraries and not connect all those that their plant passes.
In understanding that offering this free service to the public libraries is not only benevolent but a good business decision by Comcast to maximize the exposure of its cable modem service to the public, we respectfully suggest that Comcast consider offering the modem service to all public libraries that its plant passes. This would eliminate the possibility of some public libraries not receiving the service after Comcast has reached its minimal requirement.
Additionally, some language that details an outreach program should be included in this contract to ensure that Comcast contacts the libraries and schools in good faith, and makes every effort to live up to the Consumer Benefits portion of this social contract. In the social contract draft, page seven, last paragraph, and page 8 (2A) regarding the cable and Internet service to be provided to libraries, reference that it is indeed the schools and libraries that must request these services from the cable operator.
How are the schools to know that these services are available if the onus is on them to contact and make the request of Comcast? What incentive is there for Comcast to notify the schools of this service? The Cable Communications Agency specifically recommends that it be the responsibility of Comcast to do an outreach program to the schools and libraries explaining the services that they have to offer, their benefits and then connecting those that wish to receive these benefits.
The proposed language speaks to reporting the social contract compliance requirements to the FCC, (page 5/2b). We wish to add to the contract that Comcast submit those same reports on to their LFAs. As it is proposed, LFAs have no coordination or verification exercising in the language of this contract, except provisions that parallel their franchise agreements with Comcast. The Commission should recognize that the LFAs can verify the data that Comcast is submitting in their reports to the FCC and convey to the FCC if they have data contrary to that being represented. Meaningful coordination begins on the local level and unless the FCC is planning on expanding its staff to travel and verify these reports, it makes sense to let the LFAs receive copies for review and verification.
What enforcement is the FCC planning to conduct if Comcast does not meet its educational commitments under the Consumer Benefits? The July 13 edition of Cable World, (page 14) makes reference to Time Warner’s Social Contract stipulations for monthly educational training as having the appearance of a "one shot deal" instead. This concerns us as we franchise both Time Warner and Comcast.
On the morning of June 9, 1997, it was announced that Microsoft may consummate a deal that would give them a billion dollar stake in the Comcast Corporation. The concern of the Cable Agency is that Microsoft may engage Comcast into establishing proprietary agreements regarding the use of software and Internet access to the schools and libraries that will inhibit and greatly restrict the libraries and schools. This could come in the form of what they access off the Internet and the programs that they run on their computers via the software available to them (not just from Microsoft). The Cable Agency specifically recommends that the FCC insert language into this contract that would exclude any proprietary notion that Microsoft and Comcast may establish on the use of the Consumer Benefits portions of this proposed social contract.
Finally, the language in Item H./page 11 in reference to failing to comply with Social Contract as a basis for denial of franchise renewal by LFA: we respectfully take exception to this language insomuch that the provisions of our franchise agreement with Comcast and proposed language in this Social Contract draft that overlap. Failure in meeting some of those franchise requirements that are parallel to those in the Social Contract should be basis for consideration to deny renewal of operator (also see Item E./No Impairment of Local Authority/Page 10 of this proposed social contract).
Thank you for your kind consideration in taking our concerns under advisement.
Respectfully submitted,
Rick Maultra
Director
Cable Communications Agency
City of Indianapolis
cc: Marion County Cable Franchise Board
Dr. Beurt SerVaas/President- Indianapolis City-County Council
Bob Elrod/Esquire
Peggy Piety/Assistant Corporation Counsel
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