Public Service Department Rewrite of Telecommunications Plan

March 20, 2014

As the Vermont Public Service Department takes on the task of re-writing Vermont's telecommunications plan, it is important that communities weigh in on what they feel about the future of community access to cable channels, equipment, coverage of meetings and service - including HD cababilities, broadband and accessibiliy to content outside the cable channels.  To this end, CCTV has written the following memo to the VT Department of Public Service.

20 March 2014

MEMO TO: Corey Chase, Vermont Department of Public Service

FROM: Lauren-Glenn Davitian, Channel 17/ Town Meeting TV & CCTV Center for Media & Democracy

RE: Vermont Telecommunications Plan

In light of the Vermont Department of Public Service’s revision of the Vermont Telecommunications Plan, we offer the following recommendations.

  1. Access to Plan: Post the complete Plan in an easy to find location on the DPS website. Currently all that is listed on the “Telecommunications Plan” page is the Broadband Plan. http://publicservice.vermont.gov/publications/telecom_plan

  2. Plan Ahead: Warn Public Hearings at realistic times—not Friday evenings at 6 p.m. on VIT (!). Use the opportunity to educate the public about the impact of the plan so they can participate, make it clear what opportunities the private sector has to participate (are these happening through one on one meetings?). Be realistic about what is required for members of the public who are interested to provide useful and informed input.

  3. Update the Plan no less than every 36 months. The nature of the technology is changing at a rapid pace, as is the policy framework. It is necessary for the State to remain nimble and up-to- date with its technology planning.

  4. Regulation Parity: While the Department of Public Service does not have jurisdiction over the matter, it is important for the Plan to acknowledge that future policy should move in the direction of parity. That is, all regulated providers of telecom services should set aside revenue for public purposes such as community media. Why? Because these companies utilize the public rights-of-way to move their content, and thereby, generate private revenue through the use of our public resources. As the “public advocate” it is legitimate for the DPS to include this position in the Plan.

  5. Enforce Existing Rules and PEG Agreements. Vermont cable operators, namely Comcast, have taken it upon themselves to diminish the PEG access services available to the public. This has taken place incrementally, over time. The Department of Public Service has been informed of the operator’s unique interpretations of rules and regulations, yet little concrete has been done

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to hold the operator’s accountable. For many PEG Access operations, video signal quality has degraded over the past five years. The State is clear about the systems of accountability in place to address these issues. Once they are exhausted (as in Comcast will not provide digital quality connections, or they insist on charging for PEG access to the cable network), the Department of Public Service must help the PEG Access Community by enforcing the rules and regulations.

  1. Public Access to Commercial Features of the Cable Network. Access Management Organizations are entitled to public access to commercial features of the cable network. This is the exchange that was made in the early 2000’s when the Department of Public Service “negotiated away” a Public Service Board order entitled PEG Access to 10% of the cable bandwidth. This promise has yet to be fulfilled. In the upcoming Plan, we urge the Department to specify that Access Management Organizations are entitled to reach the public as any commercial channel does. Namely through access to HD Channels and Program Schedules that can be found, programmed, and used by the public via the Electronic Program Guide.

  2. Improved Web Access. PEG Channels now use the web to communicate with their public and expand the reach of community programming. At Channel 17, we have received several complaints from Comcast customers that our programming is unwatchable online. Our research indicates that Channel 17’s video content is routed in an inefficient manner, across the United States, rather than locally, resulting in poor or nonexistent online video quality. The PEG Channels traffic should be given parity to commercial content and the speed of complimentary service provided to the PEG Channels by the operators should be increased to realistically move large amounts of video content to cable subscribers and others in the community.

  3. Data Collection. The Department of Public Service and the State needs to make decisions based on data, not anecdotes. The Plan should provide for a comprehensive, statewide study of PEG Access and its impacts and importance to our communities.

  4. Vital Role of Community Media in Quality of Life of Vermont. National declines in cable television subscription (because programming is now available on line) and increases in Vermont’s internet penetration, will lead to “cord cutting” in the state. This will have a direct impact on the revenue available for Vermont community programming. If the plan is meant to affect the quality of life of Vermonter’s, then we must consider the vital role that community access channels play in the communications ecology of our local communities. This must be articulated in the Plan. We are glad to provide more background on this, if you are interested in including it.

Please let us know if you would like additional comment or back up for these recommendations. I can be reached at davitian [at] cctv [dot] org or 802.862.1645 x12.

Thank you.