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Charter Communications Effective Competition Petition

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Released: September 30, 2013

Federal Communications Commission

DA 13-2008

Before the

Federal Communications Commission

Washington, D.C. 20554

In the Matter of
)
)

Charter Communications, on behalf of its
)
CSR 8558-E
subsidiaries and affiliates
)
CSR 8559-E
)
CSR 8560-E
Petitions for Determination of Effective
)
CSR 8561-E
Competition in 46 Communities in Massachusetts, )
New Hampshire, and New York
)

MEMORANDUM OPINION AND ORDER

Adopted: September 30, 2013

Released: September 30, 2013

By the Senior Deputy Chief, Policy Division, Media Bureau:

I.

INTRODUCTION AND BACKGROUND

1.
Charter Communications, on behalf of its subsidiaries and affiliates ("Charter" or "the
Company") has filed with the Commission petitions pursuant to Sections 76.7, 76.905(b)(2), and 76.907
of the Commission's rules for a determination that it is subject to effective competition in the 43
communities listed on Attachment A ("the Attachment A Communities"). Charter alleges that its cable
systems serving the Attachment A Communities are subject to effective competition pursuant to Section
623(l)(1)(B) of the Communications Act of 1934, as amended ("Communications Act"),1 and the
Commission's implementing rules,2 and are therefore exempt from cable rate regulation in those
Communities because of the competing service provided by three companies. The three companies are
the two direct broadcast satellite ("DBS") providers, DIRECTV, Inc., and DISH Network ("the DBS
Providers") and, in eight Communities, Verizon New England Inc. ("Verizon").3 They will be referred to
collectively as "the Competing Providers." Charter also claims to be exempt from cable rate regulation in
the two communities listed on Attachment B ("the Attachment B Communities"), pursuant to Section
623(l)(1)(A) of the Communications Act4 and Section 76.905(b)(1) of the Commission's rules,5 because
Charter serves fewer than 30 percent of the households in those franchise areas.
2.
An opposition concerning all the Attachment A Communities in Massachusetts was filed
by the Massachusetts Department of Telecommunications and Cable ("MDTC").6 Charter filed a reply.7
The government of one Attachment A Community, the Town of Berlin, Massachusetts ("Berlin"), filed an


1 See 47 U.S.C. 543(l)(1)(B).
2 47 C.F.R. 76.905(b)(2).
3 The eight Attachment A Communities served by Verizon are all in CSR 8561-E and are Dunstable, Grafton,
Groton, Millbury, Northborough, Southborough, Sutton, and Westborough.
4 See 47 U.S.C. 543(l)(1)(A).
5 47 C.F.R. 76.905(b)(1).
6 The MDTC is the franchise authority for rate regulation of cable services throughout the Commonwealth of
Massachusetts. Massachusetts Department of Telecommunications & Cable Opposition to Charter's Petition for
Determination of Effective Competition ("MDTC Opposition") at 2 n.2.
7 Reply to Opposition of Massachusetts Department of Telecommunications & Cable.

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DA 13-2008

opposition of its own8 and Charter replied to it.9 Charter also filed a Motion to Withdraw its petition
concerning the community of Wales, Massachusetts (MA0338), the only community involved in CSR
8558-E. We grant the Motion without prejudice.
3.
In the absence of a demonstration to the contrary, cable systems are presumed not to be
subject to effective competition,10 as that term is defined by Section 623(l) of the Communications Act
and Section 76.905 of the Commission's rules.11 The cable operator bears the burden of rebutting the
presumption that effective competition does not exist with evidence that effective competition is present
within the relevant franchise area.12 For the reasons set forth below, we grant the petitions based on our
finding that Charter is subject to effective competition in the Communities listed on Attachments A and
B.

II.

DISCUSSION

A.

The Competing Provider Test

4.
Section 623(l)(1)(B) of the Communications Act provides that a cable operator is subject
to effective competition if the franchise area is (a) served by at least two unaffiliated multi-channel video
programming distributors ("MVPDs") each of which offers at least 50 percent of the households in the
franchise area comparable programming; and (b) the number of households subscribing to programming
services offered by MVPDs other than the largest MVPD exceeds 15 percent of the households in the
franchise area.13 This test is referred to as the "competing provider" test.
1.

The First Prong

5.
The first prong of the competing provider test has three elements: the franchise area must
be "served by" at least two unaffiliated MVPDs who offer at least "50 percent" of the households in the
franchise area "comparable programming."14 It is undisputed that the Attachment A Communities are
"served by" both DBS Providers and that these two MVPD providers are unaffiliated with Charter or with
each other. A franchise area is considered "served by" an MVPD if that MVPD's service is both
technically and actually available in the franchise area. DBS service is presumed to be technically
available due to its nationwide satellite footprint, and presumed to be actually available if households in
the franchise area are made reasonably aware of the service's availability.15 The Commission has held
that a party may use evidence of penetration rates in the franchise area (the second part of the competing
provider test discussed below) coupled with the ubiquity of DBS services to show that consumers are
reasonably aware of the availability of DBS service.16 We further find that Charter has provided
sufficient evidence to support its assertion that potential customers in the Attachment A Communities are


8 Opposition of the Town of Berlin, MA (Massachusetts) to Petition for Special Relief for Determination of
Effective Competition of Charter Communications ("Berlin Opposition"). Both Oppositions were filed pursuant to
extensions of time granted by the Bureau. Extensions were also granted to the Town of Douglas and the City of
Worcester, but both ultimately decided not to respond to Charter's petition.
9 Reply to Opposition ("Reply to Berlin").
10 47 C.F.R. 76.906.
11 See 47 U.S.C. 543(l); 47 C.F.R. 76.905.
12 See 47 C.F.R. 76.906-.907(b).
13 47 U.S.C. 543(l)(1)(B); 47 C.F.R. 76.905(b)(2).
14 47 U.S.C. 543(l)(1)(B)(i); 47 C.F.R. 76.905(b)(2)(i).
15 See, e.g., Petition in CSR 8559-E at 3-4.
16 Mediacom Illinois LLC, 21 FCC Rcd 1175, 1176, 3 (2006).
2

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DA 13-2008

reasonably aware that they may purchase the service of the DBS Providers.17 Also undisputed is
Charter's assertion that both DBS Providers offer service to at least "50 percent" of the households in the
Attachment A Communities because of their national satellite footprint.18
6.
Whether the DBS Providers' programming is "comparable" to Charter's is disputed
between Charter and Berlin. Section 76.905(g) of our rules provides that the "comparable programming"
element is met if a competing MVPD provider offers at least 12 channels of video programming,
including at least one channel of nonbroadcast service programming.19 Charter's petitions include copies
of channel lineups for both DBS Providers.20 They show that the DBS providers offer programming that
far exceeds the requirements of our rule.
7.
Berlin disputes our rule because DBS programming does not include that City's Public,
Educational and Government ("PEG") channels. Berlin makes allegations about its PEG programming's
popularity and the technical feasibility of the DBS Providers offering it.21 It does not substantiate those
allegations with any factual evidence, however, and so we disregard them. Moreover, to the extent those
allegations are factual, they are irrelevant. Our rule does not make PEG channels a necessary element of
comparable programming. As Berlin concedes, we have repeatedly held that the absence of PEG
channels from a competing service does not disqualify it from being comparable for purposes of
determining effective competition.22 Berlin has given us no sound reason to revise those holdings. More
broadly, the statute requires that the programming of the petitioning cable operator and its competitor(s)
be "comparable," not that it be identical.23 In its argument that DBS programming is not comparable to
the Company's, Berlin also argues broadly against deregulation because of the importance, to an
unsubstantiated number of Berlin residents, of affordable basic cable service.24 This argument, too, is
immaterial. The only issues under the first prong of the competing provider test are those set forth in the
first sentence of paragraph 5 above.
8.
Although criticizing the substance of the first prong of the competing provider test, the
MDTC concedes that Charter has satisfied the first prong of the competing provider test for all the
Attachment A Communities (including Berlin).25 We agree, and we find that the first prong of the
competing provider test is satisfied for all the Attachment A Communities.
2.

The Second Prong

9.
The second prong of the competing provider test requires that the number of households


17 47 C.F.R. 76.905(e)(2).
18 See, e.g., Petition in CSR 8560-E at 2-3.
19 See 47 C.F.R. 76.905(g); see also, e.g., Petition in CSR 8561-E at 5.
20 See, e.g., Petition in CSR 8559-E at Ex. 2.
21 Berlin Opposition at 2-3.
22 Comcast Cable Commc'ns, 26 FCC Rcd 3993, 3994-95, 5 (2011); Cablevision of Oakland Inc., 24 FCC Rcd
1801, 1803-04, 6-8 (2009) (at 1803, 7: "[t]he full Commission, when it adopted the definition of `comparable
programming,' was fully aware of PEG channels - it discussed both in the same decisions. If the full Commission
had wanted PEG channels to be part of `comparable programming,' it would have stated so. It did not.").
23 Accord, Comcast Cable Commc'ns, LLC, 25 FCC Rcd 13340, 13343, 13, n.37 (2010) ("In many decisions we
have refused to require that a cable operator's service be identical to its competitor's before the latter may provoke
deregulation of the former's basic rates").
24 Berlin Opposition at 4-6; see also MDTC Opposition at 4 n. 12.
25 MDTC Opposition at 3-4.
3

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DA 13-2008

subscribing to MVPDs, other than the largest MVPD, exceed 15 percent of the households in a franchise
area. Charter asserts that in some Attachment A Communities it is the largest MVPD; and that, in others,
Charter's household share is over 15 percent and so is the combined share of the Competing Providers.26
The Commission has recognized that in the latter conditions, whichever MVPD is the largest, the
remaining MVPDs have subscribership of over 15 percent.27 To show its compliance with the second
prong of the competing provider test, Charter establishes a ratio for each Attachment A Community, the
numerator of which is the number of subscribers to the Competing Providers there and the denominator of
which is the number of households.
a.

Charter's Evidence

10.
For its numerators, and in particular the numbers of DBS subscribers, Charter first
obtained from Media Business Corporation ("MBC") a list of zip codes matching each Community. It
appears that MBC included in a Community any five-digit zip code that was contained entirely within the
Community and any nine-digit zip code whose "centroid" was within the Community.28 A centroid is the
point of intersection of two lines, one of which goes between the northernmost and southernmost points of a
nine-digit zip code and the other of which goes between its easternmost and westernmost points.29 Charter
then gave MBC's list of zip codes to the Satellite Broadcasting and Communications Association
("SBCA"), which reported to Charter the numbers of DBS subscribers in each zip code.30 The Company
learned the numbers of Verizon subscribers from the web page of the Massachusetts Office of Consumer
Affairs and Business Regulation.31 The sum of these numbers was the numerator of Charter's ratio for
each Attachment A Community. For its denominators, Charter took household numbers for each
Attachment A Community from the 2010 Census.32 The resulting ratios show that the number of
households subscribing to programming services offered by MVPDs, other than the largest MVPD,
exceeds 15 percent of the households in each Attachment A Community.33 These ratios, if accepted,
satisfy the second prong of the competing provider test for the Attachment A Communities.
b.

The MDTC's Objections

11.
The MDTC makes three objections to Charter's numbers. First, it objects to numbers that
Charter has included in two of the petitions and in other regulatory filings concerning two Attachment A
Communities (Westport in CSR 8560-E, and Northborough in CSR 8561-E). The numbers that MDTC
has derived from these filings show the sum of subscribers to Charter and the Competing Providers in


26 Petition in CSR 8559-E at 7; Petition in CSR 8561-E at 8. The latter Attachment A Communities are, all the
Communities in CSR 8559-E except for Copake, New Lebanon, and West Stockbridge; and, in CSR 8561-E, the
Communities of Dunstable, Northborough, Southborough, and Westborough.
27 If Charter is the largest MVPD, then the MVPDs other than the largest one are the DBS Providers (and, where it
serves, Verizon), which have a combined share of over 15%. On the other hand, if one of the DBS Providers or
Verizon is the largest MVPD, then Charter (which alone has over 15%) and the remaining others combined have
over 15%. See, e.g., Comcast Cable Commc'ns, LLC, 26 FCC Rcd 10967, 10968-69, 5 (2011); Comcast Cable
Commc'ns, LLC
, 26 FCC Rcd 4901, 4903, 5 (2011); Time Warner Cable Inc., 25 FCC Rcd 14422, 14424, 6
(2010).
28 Petition in CSR 8559-E at 6; Petition in CSR 8561-E at 6-7; MDTC Opposition at 9.
29 MDTC Opposition at 9 n.31.
30 See, e.g., Petition in CSR 8560-E at 6.
31 Petition in CSR 8561-E at 6 n.23.
32 See, e.g., Petition in CSR 8559-E at Ex. 6.
33 See, e.g., Petition in CSR 8561-E at Ex. 9.
4

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DA 13-2008

these Communities being larger than the number of households there. 34 The MDTC requests that we
deny Charter's petitions for these two Communities and, more broadly, that we "reevaluate all of the data
submitted in support of the Petitions."35
12.
In past decisions, we have denied petitions that stated cable operator and DBS subscriber
numbers that were higher than household numbers, finding such numbers "obviously inaccurate and
unreliable."36 The numbers that were obviously inaccurate in those cases were all stated in the petitions.
The numbers in Charter's petitions about Westport and Northborough do not suffer from this defect,
however. Rather, the MDTC has taken numbers from Charter's petitions and from other Charter filings
with different government bodies on different dates.37 The sums that the MDTC has produced may result
from different kinds of counts made on different dates and for different purposes. MDTC questions, but
provides no specific factual evidence concerning the accuracy of the competing provider or Charter
subscriber figures for these communities. Accordingly, although we urge Charter to make its petitions as
accurate as possible, we dismiss the MDTC's objection to Charter's numbers about Westport and
Northborough, as well as its request for a general reevaluation of the petitions' supporting numbers.
13.
Second, the MDTC objects that all of Charter's ratios overstate Competing Provider
subscribership. The MDTC correctly notes that the Company's numerators (DBS subscribers from
SBCA, for example) include dwellings that do not count as "households," such as seasonal or vacation
homes, and other temporary dwellings;38 but that the Company's denominators ("households" as defined
by the Census) do not include such dwellings.39 This mismatch, the MDTC objects, overestimates
Competing Provider subscribership. We reject this objection, as we have rejected similar ones in past
decisions.40 The MDTC has not shown that there are any seasonal homes or other non-"household"
dwellings in the Attachment A Communities in Massachusetts, much less enough of them to lower
Competing Provider subscribership to 15 percent or less. Undoubtedly, the MDTC is familiar with the
Communities. It could have found out, with less effort than Charter, nine-digit zip codes that encompass
temporary dwellings such as dormitories and assisted living facilities, and deducted SBCA's number of
DBS subscribers there from Charter's numerators.41 Instead of using facts, however, the MDTC rested on
generalities. That is not enough to rebut the factual evidence presented by Charter.42


34 MDTC Opposition at 5; id. at Ex. 3. The same is true of Charter's numbers for Wales, which Charter has
withdrawn, supra 2.
35 MDTC Opposition at 6.
36 See, e.g., Time Warner Cable Inc., 25 FCC Rcd 14422, 14424, 7 (2010); Time Warner Entertainment-
Advance/Newhouse Partnership
, 23 FCC Rcd 18355, 128357, 10 (2008); Time Warner Cable Inc., 23 FCC Rcd
12069, 12072, 10, reconsideration denied, 23 FCC Rcd 16483 (2008).
37 MDTC Opposition at Ex. 3 at 2.
38 MDTC Opposition at 7, citing Time Warner Entertainment-Advance/Newhouse Partnership, 26 FCC Rcd 3829,
3835, 20 (2011). Other dwellings that are not "households" include dormitories and assisted living facilities. Id.
39 MDTC Opposition at 8.
40 For decisions in which we have refused to increase household numbers to account for seasonal homes and the
like, see, e.g., Charter Commc'ns Entertainment I, LLC, 26 FC Rcd 5975, 5980-81, 18-19 (2011); Time Warner
Entertainment-Advance/Newhouse Partnership
, 26 FCC Rcd 3829, 3835-36, 22 (2011).
41 Where franchise authorities have submitted credible numbers of seasonal homes and the like, we have subtracted
them from cable operators' DBS subscriber numbers. Charter Commc'ns, 25 FCC Rcd 2289, 2294, 15 (2010);
Bright House Networks, LLC, 22 FCC Rcd 3499, 3502, 7 (2007); Comcast Cable Commc'ns, LLC, 22 FCC Rcd
1691, 1697-98, 16 & n.61 (2007).
42 See, e.g., Time Warner Cable Inc., 26 FCC Rcd 7666, 7670, 11 (2011) ("We have repeatedly refused to deny
cable operators' otherwise valid showings of effective competition based on . . . unsubstantiated objections by
(continued....)
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14.
In the same vein, the MDTC objects that Charter overstates competing provider
subscribership by including in its ratios DBS subscribers and households in the parts of the Attachment A
Communities where Charter does not provide cable service. The MDTC speculates that DBS
subscribership is higher where DBS is the only MVPD service and calls it "illogical" for Charter to prove
competition between itself and DBS where it does not serve.43 We dismiss this objection, as we have in
previous decisions. Section 623(l)(1)(B) states that the material area for measuring effective competition
is "the franchise area,"44 and these are the areas within which Charter has measured Competing Provider
subscribership. Section 623(l)(1)(B) makes no exception for areas to which the cable operator has not
brought its service. The MDTC's position thus is defeated by the statute.45 In addition, the MDTC has
produced no factual evidence that subtracting households not served by Charter in any Attachment A
Community in Massachusetts would lower the Competing Providers' subscribership to 15 percent or
lower no indication of how large any unserved area is, how many households it contains, and how many
of those households subscribe to DBS service. Accordingly, we dismiss the MDTC's objection because,
in addition to being barred by the applicable statute, it is unsubstantiated. Charter's petitions correctly
measure effective competition in the Company's franchise areas.
15.
Third, the MDTC objects to MBC's use of centroids46 as the basis for assigning nine-digit
zip codes to the Attachment A Communities, claiming that this practice overstates DBS subscribership.
A centroid, the MDTC notes, is a central point within a zip code. It is possible, the MDTC alleges, that
the centroid of a zip code on the edge of a Community is in the Community, but that most or all of the
households in the zip code, including the ones that subscribe to DBS service, are outside the Community.
Counting those households overstates DBS subscribership, the MDTC contends.47
16.
This objection by the MDTC may have theoretical validity, but is of no significant
practical effect in these proceedings. Nine-digit zip codes are very small; the typical one contains no
DBS subscribers or one or two.48 Any overstatement of DBS subscribership that result from the
phenomena the MDTC has identified are likely to be de minimus in any of the Attachment A
Communities in Massachusetts. Moreover, we expect that for every nine-digit zip code whose centroid is
barely inside a Community but most of whose DBS-subscribing households are outside it, there is another
nine-digit zip code on the edge of the same Community whose centroid is barely outside it but most of
whose DBS-subscribing households are inside it. In that event, any overcounting errors such as the


(...continued from previous page)
franchise authorities"); Charter Commc'ns, 25 FCC Rcd 2289, 2292, 6 (2010); Cablevision of Paterson, 17 FCC
Rcd 17239, 17242, 6, n.22 (2002).
43 MDTC Opposition at 6-7 n.23.
44 47 U.S.C. 543(l)(1)(B)(ii) ("the number of households subscribing to programming services offered by [MVPDs]
other than the largest [one must] exceed[] 15 percent of the households in the franchise area") (italics added); 47
C.F.R. 76.905(b)(2)(ii); CoxCom, Inc., 22 FCC Rcd 4533, 4536-37, 8 (2007).
45 The only exception to our use of the franchise area is when the franchise authority proves that the cable operator
has made an affirmative decision, confirmed by its own conduct, to serve less than the whole area granted in its
franchise. In that event, we will measure effective competition in the lesser area that the cable operator actually
serves. See, e.g., County of New Hanover, North Carolina, 23 FCC Rcd 15348, 1350-52, 7-12 (2008);
Cablevision of Paterson, 17 FCC Rcd 17239, 17240-41, 2-4 (2002); Implementation of Sections of the Cable
Television Consumer Protection &Competition Act of 1992: Rate Regulation
, 9 FCC Rcd 1164, 1181, 25 (1993).
The MDTC has neither alleged nor proved such conduct by Charter, however.
46 See supra 10.
47 MDTC Opposition at 10.
48 Petition in CSR 8561-E at Ex. 7. The first page of Exhibit 7 lists 51 nine-digit zip codes. Of them, 24 have no
DBS subscribers, 11 have only 1, and 8 have 2.
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MDTC alleges, already minuscule, are further reduced by undercounting errors.
17.
Similarly, the MDTC has identified five nine-digit zip codes that Charter has assigned to
certain Attachment A Communities in Massachusetts but that, according to the web page of the U.S.
Postal Service, are actually in neighboring Communities.49 As noted in previous discussions, it is highly
likely that, if MBC made any mistaken assignments, the small number of DBS subscribers in nine-digit
zip codes would make any mistakes inconsequential. Also, as we noted in dismissing the same point in
an earlier decision,50 what the MDTC has identified may not be mistaken assignments by Charter at all.
The USPS associates streets with communities for efficient mail delivery, and sometimes disregards
precise political boundaries between communities.51 It is the latter, however, that are important for
measuring effective competition. MBC's method of associating zip codes with communities' precise
boundaries is better matched to our needs in these proceedings than the USPS web page on which the
MDTC relies. In addition, Charter's reply convincingly demonstrates that, in at least one specific
instance alleged by the MDTC, MBC has assigned a nine-digit zip code to the correct Community
although the USPS, for its own purposes, has assigned it to another one.52 Accordingly, we reject the
MDTC's objections to the treatment of nine-digit zip codes by MBC and Charter.
18.
Despite the MDTC's objections, the second prong of the competing provider test is
satisfied for each Attachment A Community. It requires that Charter show that the competing providers'
market share exceeds 15 percent in each Attachment A Community, and Charter has made that showing.
Based on the foregoing, we conclude that Charter has submitted sufficient evidence demonstrating that
both prongs of the competing provider test are satisfied and Charter is subject to effective competition in
the Attachment A Communities.

B.

The Low Penetration Test

19.
Section 623(l)(1)(A) of the Communications Act provides that a cable operator is subject
to effective competition if Charter serves fewer than 30 percent of the households in the franchise area.
This test is referred to as the "low penetration" test.53 Charter alleges that it is subject to effective
competition under the low penetration effective competition test because it serves less that 30 percent of
the households in the Attachment B Communities.
20.
Based upon the subscriber penetration level calculated by Charter, as reflected in
Attachment B, we find that Charter has demonstrated that the percentage of households subscribing to its
cable service is less than 30 percent of the households in the Attachment B Communities. Therefore, the
low penetration test is satisfied as to the Attachment B Communities.

III.

ORDERING CLAUSES

21.
Accordingly,

IT IS ORDERED

that the petitions for a determination of effective
competition filed in the captioned proceeding by Charter Communications on behalf of its subsidiaries
and affiliates

ARE GRANTED

.


49 MDTC Opposition at 10 n.35.
50 Comcast Cable Commc'ns, LLC, 24 FCC Rcd 1780, 1786-87, 21 (2009).
51 Reply to MDTC at 4.
52 Id. at 5 (concerning zip code 01607-1705 and with which community Rydberg Terrace, Massachusetts is
associated).
53 47 U.S.C. 543(l)(1)(A).
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22.

IT IS FURTHER ORDERED

that the certification to regulate basic cable service rates
granted to any of the Communities set forth on Attachments A and B

IS REVOKED

.
23.

IT IS FURTHER ORDERED

that Charter's request to withdraw its petition seeking a
finding of effective competition in the Massachusetts community of Wales

IS GRANTED.

24.
This action is taken pursuant to delegated authority pursuant to Section 0.283 of the
Commission's rules.54
FEDERAL COMMUNICATIONS COMMISSION
Steven A. Broeckaert
Senior Deputy Chief, Policy Division, Media Bureau


54 47 C.F.R. 0.283.
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ATTACHMENT A

CSRs 8559-E, 8560-E, and 8561-E

COMMUNITIES SERVED BY SUBSIDIARIES AND AFFILIATES

OF CHARTER COMMUNICAITONS

2010 Census

Estimated Competing

Communities

CUIDs

CPR*

Households

Provider Subscribers

CSR 8559-E

Ancram
NY1568
63.84
661
422
Berlin
NY1583
32.70
789
258
Canaan
NY1572
54.83
673
369
Chatham Town
NY1570
37.28
1797
670
Chatham Village
NY1569
25.97
801
208
Copake
NY1575
43.71
1416
619
Ghent
NY1574
34.54
2203
761
Hillsdale
NY1573
55.12
849
468
Hinsdale
MA0313
38.13
868
331
Lanesborough
MA0300
36.64
1291
473
New Lebanon
NY1582
30.50
1013
309
West Stockbridge
MA0311
40.81
593
242

CSR 8560-E

Westport
MA0297
33.64
6154
2070

CSR 8561-E

Auburn
MA0073
16.02
6542
1048
Barre
MA0329
22.67
2025
459
Berlin
MA0333
16.80
1125
189
Brookfield
MA0335
16.73
1375
230
Brookline
NH0164
23.18
1631
378
Charlton
MA0309
15.36
4608
708
Douglas
MA0323
16.83
3000
505
Dudley
MA0036
16.84
4062
684
Dunstable
MA0343
64.35
1063
684
East Brookfield
MA0312
16.43
828
136
Grafton
MA0177
49.49
6892
3411
Groton
MA0282
44.44
3753
1668
Hubbardston
MA0330
23.69
1566
371
Millbury
MA0121
40.76
5294
2158
Millville
MA0291
17.09
1094
187
North Brookfield
MA0308
26.32
1862
490
Northborough
MA0197
53.74
5110
2746
Oakham
MA0344
29.93
685
205
Oxford
MA0120
17.85
5272
941
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2010 Census

Estimated Competing

Communities

CPR*

Households

Provider Subscribers

CSR 8561-E (continued)

Pepperell
MA0281
15.82
4197
664
Rutland
MA0328
21.78
2791
608
Southborough
MA0259
68.49
3332
2282
Southbridge
MA0029
18.07
6866
1241
Sutton
MA0292
50.02
3213
1607
Upton
MA0242
16.28
2733
445
Uxbridge
MA0290
16.83
5056
851
Webster
MA0037
16.69
7088
1183
West Brookfield
MA0305
15.62
1479
231
Westborough
MA0198
49.93
6924
3457
Worcester
MA0018
15.73
68613
10795
*CPR = Percent of competitive penetration rate.
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ATTACHMENT B

CSR 8559-E

COMMUNITIES SERVED BY SUBSIDIARIES AND AFFILIATES

OF CHARTER COMMUNICAITONS

Franchise Area

Cable

Penetration

Communities

CUIDs

Households

Subscribers

Percentage

Austerlitz
NY1571
726
96
13.22
Petersburg
NY1685
616
66
10.71
11

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