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FCC Threatens Community Television

November 27, 2018

On September 25, the FCC issued proposed rulemaking (Docket 05-311) that could have a catastrophic impact on BCTV and all Public, Educational and Governmental (PEG) cable access channels and community media centers around the country. We are calling on supporters to take a moment to file comments with the FCC expressing your disapproval of their proposed actions. Instructions for filing comments are available on this page. Initial comments had to be filed by November 14, but "Reply Comments" can be filed through December 14 at 11:59 PM.

What's at stake?

The new FCC rulemaking allows cable companies to assess the value for 'in kind' services related to providing PEG channels and deduct that amount from the Franchise Fees passed to municipalities and nonprofits like BCTV to run PEG stations and channels. These loosely defined 'in kind' costs can include the 'value' of the cable channels themselves as well as any other services provided. The FCC fails to set any guidelines or limitations to the values that cable companies can assess, and it's conceivable that station operating funds could be eliminated.

We need your help!

Here's how to submit a letter that supports BCTV's filed comment in opposition to the proposed Rulemaking.

1) Download the template for your letter here. Customize the parts in red and print it on your letterhead with your signature. Letters from organizations are especially important at this stage. 

2) Either email your letter to (by end of day on Thursday, December 13) and I will submit it for you, or save your letter as a PDF and submit it directly to the FCC before 11:59 PM on Friday, December 14.

Steps to file:

Go to:

Enter the following information:

  • Proceeding(s)                    05-311
  • Name(s) of Filer(s)             Your Name or Organization
  • Law Firm(s)                        leave blank
  • Attorney/Author Names     leave blank
  • Primary Contact Email        Your Email Address
  • Type of Filing                     choose 'Reply to Comments'
  • File Number                       leave blank
  • Report Number                  leave blank
  • Bureau ID Number             leave blank
  • Address of                         choose 'Filer'
  • Address                             Your Address
  • Address 2                          Your Address                
  • City-State-Zip                    Your Address

In the 'Upload Documents' area, click to select your PDF file from your computer or drag and drop the file into the box. 

When a dialog box appears, add Description: Reply Comment opposing FCC proposal and in support of the Comments of Brattleboro Community Television, Inc. File ID 1113560010350.

Check 'Email Confirmation'

Click on 'Continue to Review Screen.'

Click on 'Submit'

You should receive an email confirmation. Please forward this confirmation to

Thank you for supporting Commmunity Media in Vermont and across the nation!


Read the FCC Second Further Notice of Proposed Rulemaking (Second FNPRM),

Read Comments already filed for RM 05-311


FCC Proposal Could Hurt BCTV's Bottom Line (Brattleboro Reformer),557852?

BCTV: FCC Action Threatens Future (Vermont Business Journal)

FCC rule change could threaten PEG-TV funding (Rutland Herald)

Media Alliance Article on this FCC Action

A Proposed FCC Rule Change Could Put An End To Local Access TV Stations

FCC is at it again: Proposed changes to benefit big cable, harm local access channels

FCC Rule Change Could Limit Funding for Public Access Programs


In the Cable Act legislation of 1984, Congress established Franchise Fees and PEG Fees as a condition for cable operators providing commercial cable TV services. Franchise fees are often described as 'rent' for the commercial access and use to the public right of ways within a municipality. These fees help cover the associated costs to cities from cable TV installations and also help fund other municipal public services. PEG fees can optionally be established by a municipality to provide for the capital equipment necessary to the operations of local PEG channels. Both Franchise and PEG fees are public interest obligations that ensure the commercial media being pumped into residents homes is balanced by meaningful non-commercial locally originated content. Non-commercial PEG channels are unique, they provide an important means of free speech via the public channel, government transparency and communication with residents via the government channel and an educational channel available for use by local schools and universities. It's important to note that Cable companies do not pay Franchise or PEG fees, these fees are paid by cable subscribers and merely pass through the cable companies to the cities and nonprofits. The new FCC rulemaking will not change the amount currently charged to cable subscribers, it merely allows cable companies to keep this money. The FCC explained that its proposals "are intended to place new entrants and incumbent cable operators on an equal regulatory footing and remove obstacles to the deployment of broadband."

The FCC's press release and supporting documents can be found here: