O-1744-7-99ORDINANCE NO. 1744-7-99
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF ALLEN, COLLIN
COUNTY, TEXAS, ESTABLISHING MAXIMUM RATES THAT TCI
CABLEVISION OF THE METROPLEX, INC., MAY CHARGE ITS ALLEN CABLE
TELEVISION SUBSCRIBERS FOR PROGRAMMING COSTS, EQUIPMENT AND
INSTALLATION; FOR ORDERING REFUNDS; PROVIDING A SEVERABILITY
CLAUSE; PROVIDING A REPEALING CLAUSE; PROVIDING A PENALTY OF
FINE NOT TO EXCEED THE SUM OF FIVE HUNDRED DOLLARS ($500) FOR
EACH OFFENSE; AND PROVIDING FOR AN EFFECTIVE DATE.
WHEREAS, the City of Allen, Texas, (the "City") is the Grantor of a Franchise Ordinance executed on or
about July 20, 1995, by and between the City of Allen and TCI Cablevision of the Metroplex, Inc.
("TCI"); and
WHEREAS, the City pursuant to the Cable Consumer Protection and Competition Act of 1992 (the "Cable
Act") and the rales and regulations adopted thereunder by the Federal Communications Commission (the
"FCC"), is certified to regulate the rates for the basic cable service tier and related equipment; and
WHEREAS, as local regulator of rates for the basic service tier, the City may within one year of receipt of
proposed rates make a rate ruling on the proposed rates submitted by TCI to be charged to subscribers of
the basic service tier; and
' WHEREAS, the City has reviewed he proposed rates submitted by TCI and desires to make a rate ruling.
NOW, THEREFORE, BE IT ORDAINED BY THE CITY COUNCIL OF THE CITY OF ALLEN,
COLLIN COUNTY, TEXAS:
SECTION 1. "FINDINGS: The City of Allen, Texas finds as follows:
1. The City is the Grantor of a Franchise Ordinance executed on or about July 20,
1995, by and between the City and TCI.
2. In accordance with the applicable provisions of the Cable Consumer Protection and
Competition Act of 1992 and the rales adopted by the FCC, the City has
undertaken all appropriate procedural steps to regulate the basic cable service tier
and related equipment.
3. On or about March 1, 1999, the City received TCI's FCC Form 1205, Form 1235
and Form 1240.
4. The City has engaged the services of C2 Consulting Services, Inc. to provide
assistance to the City for review of TCI's FCC Form 1205, Form 1235 and Form
1240.
5. On or about May 20, 1999, C2 Consulting Services, Inc. submitted a fatal report
' regarding a review of TCI's FCC Form 1205.
6. On or about May 21, 1999, C2 Consulting Services, Inc. submitted a final report
regarding a review of TCI's FCC Form 1240.
7. On or about June 10, 1999, C2 Consulting Services, Inc. submitted an evaluation
letter regarding a review of TCI's FCC Form 1235.
8. Based upon information received from TCI, the calculations and recommendations
from C2 Consulting Services, Inc., and the deliberations and advice of the Cable
TV and Telecommunications Advisory Committee, the City makes additional
findings regarding to FCC Form 1205, FCC Form 1235 and FCC Form 1240 filed
by TCI, as set forth in the reports of C2 Consulting Services, Inc., which are
attached hereto as Exhibits "A", "B", and "C".
9. The City must act upon the pending rate request consistent with current FCC rate
rules and regulations."
SECTION 2. "CONCLUSIONS: The City of Allen, Texas concludes as follows:
1. Proerammine Rates (Foran 1240). The City concludes that the maximum
permitted rate for the current basic service tier is $12.15.
2. Unerade Costs (Form 1235). The City concludes that the maximum permitted
system upgrade rate increase (Form 1235 rate) is $1.19.
3. Installation and Eauioment Rates (Form 1205). The City concludes that the
permitted rate for hourly service charges and other installation and equipment rates
shall be as outlined in Exhibit "D" attached hereto and incorporated herein for all
' purposes.
4. The City has an obligation to act timely upon the pending rate application consistent
with current FCC rules and regulations. However, if the FCC alters the
benchmark calculations resulting in a lower reasonable rate for Allen subscribers,
the City has an obligation to its subscribers to reconsider the pending analysis
consistent with such changes the FCC may make in its regulations.
SECTION 3. "ORDER FOR ACTION: Based upon the foregoing findings and conclusions, the City
hereby orders the following:
1. Pursuant to current FCC regulations, from the date of this order and until further
order of the City, TCI shall be permitted to charge an initial rate for the basic
service tier, exclusive of any franchise fee but inclusive of the FCC regulatory fee,
of not more than $12.15.
2. Pursuant to current FCC regulations from the date of this order and until further
order of the City, TCI shall be permitted to charge a rate for the upgrades of basic
service tier of not more than $1.19.
3. pursuant to current FCC regulations from the date of the order and until further
order of the City, TCI shall be permitted to charge (exclusive of any franchise fee)
an hourly service charge of not more than the amount set forth in Exhibit "D", and
TCI shall be permitted to charge for installation services and leased customer
Ordinance No. 1744-7-99 Page
equipment in the amounts set forth in Exhibit `D", attached to this Ordinance and
incorporated as if fully set forth herein.
' 4. The City hereby waives, for this rate order only, the requirement for thirty (30)
day prior written notice to subscribers required by the City's Cable Communication
Ordinance.
5. TCI shall immediately undertake all necessary steps, in accordance with applicable
FCC regulations to provide refunds to all subscribers who have been overcharged
since lune 1, 1999, based upon the difference between TCI's current equipment
and installation charges and the permitted equipment and installation charges
approved herein.
6. TCI shall provide the City evidence the order for actions "1" `2" "3" and "5"
above have been complied with and that all refunds have been properly made in
accordance with the Cable Act and applicable FCC regulations.
7. This Ordinance shall not be reconsidered should any further analysis pursuant to
future FCC rules and regulations result in high rates to subscribers, unless such
future FCC regulations mandates that the City order such an upward adjustment."
8. The City requests that TCI provide additional information when filing its FCC Form 1205
that demonstrates TCI's quality control in the data collected in its aggregation of costs.
' 9. City Council is not waiving any right to require TCI to file a revised and final FCC Form
1235 based on any final rulemaking from the FCC requiring cable operators to adjust 1235
rates to reflect changes in subscriber numbers.
10. TCI agrees to consider future FCC rulings with regard to the Sunset provision of Section
76.922(g)."
SECTION 4. In adopting this Ordinance, the City Council of the City of Allen, Texas is not approving or
acquiescing in any way whatsoever to the cost data and/or methodologies not specifically addressed in this
Ordinance. Furthermore, the City Council of the City of Allen, Texas is not waiving any rights to which it
is entitled.
SECTION 5. That should any word, sentence, paragraph, subdivision, clause, phrase or section of this
ordinance, or of the Code of Ordinances, as amended hereby, be adjudged or held to be void or
unconstitutional, the same shall not affect the validity of the remaining portions of said ordinance or the
Code of Ordinances, as amended hereby, which shall remain in full force and effect.
SECTION 6. That all provisions of the Code of Ordinances of the City of Allen, Texas, in conflict with
the provisions of this ordinance be, and the same are hereby, repealed, and all other provisions not in
conflict with the provisions of this ordinance shall remain in full force and effect.
SECTION 7. That any person, tum or corporation violating any of the provisions of this ordinance or of
the Code of Ordinances, as amended hereby, shall be deemed guilty of a misdemeanor and, upon conviction
' in the municipal court of the City of Allen, Texas, shall be subject to a fine not to exceed the sum of five
OrdinanceNo. 1744-7-99 Page 3
hundred dollars ($500.00) for each offense, and each and every day said violation is continued shall constitute
a separate offense.
' SECTION 8. This ordinance shall take effect immediately from and after its passage, as the law and
charter in such case provides; and it is accordingly so ordained.
DULY PASSED AND APPROVED BY THE CITY COUNCIL OF THE CITY OF ALLEN, COLLIN
COUNTY, TEXAS, ON THIS THE 15"' DAY OF JULY, 1999.
APPROVED:
Stephen Terrell, MAYOR
APPROVED AS TO FORM ATTEST:
Peter G. Smith, CffY ATTORNEY JJ y Mo on, CMC, CITY SECRETARY
Ordinance No. 1744-7-99 Page
k
INONSULTING SERVICES, INC.
7801 Pencross
Dallas. Texas 75248
May 20, 1999
Mr. Michael R. Stanger
Assistant City Manager
City of Allen
One Butler Circle
Allen, Texas 75013
Mr. Scott Barnett
Planning Manager
City of Bedford
PO Box 157
Bedford, Texas 76095-0157
' Ms. Dianne McWethy
Assistant City Manager
City of Colleyville
PO Box 185
Colleyville, Texas 76034
Dear City Representatives:
Exhibit "A"
(972)726-7216
(972) 726-0212 (fax)
Ms. Candi Terry
Assistant Town Manager
Town of Flower Mound
2121 Cross Timbers Road
Flower Mound, Texas
Ms. Debra Wallace
Assistant Finance Director
City of McKinney
222 N. Tennessee
McKinney, Texas 75069
Ms. Lynda Humble
Managing Director— Management Services
City of DeSoto
211 E. Pleasant Run Road
DeSoto, Texas 75115-3939
C2 Consulting Services, Inc. ("C2") has completed the evaluation of the FCC Form 1205
filed by TO with the Cities on or about March 1, 1999.! This is TCI's third year to file
its proposed changes in equipment monthly lease rates and installation and maintenance
charges based on its aggregation of data/costs related to all owned and/or managed
systems. As you recall, the Form 1205 is to be filed once each year, is to be based on the
most recent fiscal year costs/data, and is to be filed simultaneously with the Form 1240.
The Cities have original jurisdiction with respect to the review and regulation of charges
resulting from the Form 1205 computations.
This study does not constitute an examination of the financial condition of TCI or its
parent company. As such, C2 cannot and does not express any position with regard to the
' The Form 1205 represents data related to all systems owned and/or managed by TO Communications,
Ina ("TCIC") Your respective jurisdictions are served by either TO of North Texas or TO TKR of the
Metroplex, Inc, refereed to collectively herein as ("TCI")
Ordinance No. 1744-7-99
I
I
City Representatives
May 20, 1999
Page 2
accuracy or validity of the financial information provided by TCI during the course of the
analyses.
BACKGROUND
In its 1999 Form 1205 filing, TO proposes maximum permitted equipment installation,
maintenance rates for the year June, 1999 through May, 2000 that are lower than the
maximum permitted rates filed by the Company in 1998. TCI's maximum permitted
rates for equipment lease show increases over 1998 rates. With respect to TCI's operator
selected rates, the Company proposes increases in its equipment lease rates, with
proposed decreases in the installation rates that it has been charging during the past
twelve months.
The following table provides a comparison of TCI's 1998 filed rates, the Cities' order
1998 rates, and TCI's proposed 1999 rates:
"= Maximum Permitted Rates "= Operator Selected Rates
(1) As ongmail, ordered b)all but the Cit% of McKinney
(2) Ordered b all but the Tos%n of Flower Mound as rates to be charged subsequent to discussions with TO
concerning resolution of noted issues
Consistent with the 1997 and 1998 aggregated filings, the 1999 filing has the following
components:
Ordinance No. 1744-7-99
COMPARISON OF EQUIPMENT AND INSTALLATION RATES
TCI Proposed
TCI Proposed
City Ordered
City Ordered
TCI Proposed
TCI Proposed
1999 MPR'
1998 OSR'
MPR(1)
Rates (2)
1999 MPR'
19N NSR"
Hourly Service Charge
$3590
$29.00
$2700
$27.11
$27.93
$27.00
Service
Instal - Unwin home
$53.16
$46.95
$40.99
540.55
$41.38
$39.95
Install - Prewired home
$28.44
$2495
$21.92
$2195
$22.37
$21.50
Instal- Additional conned ini8el
$1658
$13.95
$1278
$12.64
$14.68
$13.95
Install- Add, connect separate
$26.42
$21.95
$20.37
$20.15
$21.08
$1895
Move outlet
$25.48
$2195
$19.64
$19.44
$20.82
$18.95
Upldovmgrade
$199
$199
$199
$1.99
$1.99
$1.99
Dosmirade non -addressable
$1117
$895
$861
$8.52
$848
$8.95
Upgrade non -addressable
$34.01
$13.95
$26.22
$13.95
$33.04
$1395
Changing Tiers
$34.01
$13.95
$26.22
N/A
NIA
NIA
Connect VCR impal
$812
$6.95
$626
$6.19
$6.83
$5.95
Connect VCR separate
$1725
$13.95
$13.30
$13.16
$13.82
$1295
Monthly Lease Rates
Remotes
$0.40
$0.30
$0.34
$0.30
$0.41
$0.35
Basic only converters
$2.59
$150
$1.97
$1.50
$3.56
$160
Non -basic only converters
$3.78
$325
$3.16
$3.25
$4.55
$3.50
"= Maximum Permitted Rates "= Operator Selected Rates
(1) As ongmail, ordered b)all but the Cit% of McKinney
(2) Ordered b all but the Tos%n of Flower Mound as rates to be charged subsequent to discussions with TO
concerning resolution of noted issues
Consistent with the 1997 and 1998 aggregated filings, the 1999 filing has the following
components:
Ordinance No. 1744-7-99
City Representatives
May 20, 1999
Page 3
• The computation of the Hourly Service Charge ("HSC") based on the
averaging of calculations made for forty sample systems as applied to the total
number of systems that have the same sample characteristics (subscriber
counts)
• An allocation of common TCIC costs to each of the sample systems based on
the number of subscribers
• The computation of individual installation activities based on the HSC times
an averaging of the time requirements reported by the forty sample systems
• The computation of equipment rates based on TCI's inclusion of certain costs
at the TCIC level
• The computation of converter rate categories that are dependent on the type of
service rather than the type of equipment
ANALYSES OF THE FILINGS
Project Objectives and Activities
' The project objectives are three fold:
1. Assessment of the completeness of the filings with regard to the information
and documentation that must be filed with the Cities.
2. Assessment of the reasonableness of the proposed computations in light of
FCC regulation and recent FCC rulings.
3. Assessment of the reasonableness of the proposed computations in light of
TCl's proposed method of aggregation and prior rulings by the Cities.
Given these objectives, C2 conducted the following project activities:
• Review of the filings to assess the completeness based on the FCC Form
instructions
• Review of the filings to identify any issues with respect to the data and/or
methodologies employed by TCI
• Submission of follow-up data requests and subsequent review of TCI's
responses
• Review of recent FCC decisions that may have an impact on TCI's proposed
methodologies or the Cities' alternative actions
• Development of potential alternatives available to the Cities in establishing
' maximum permitted equipment and installation rates
Ordinance Na 1744-7-99
City Representatives
May 20, 1999
Page 4
' Summary of Findings
Due to the issues identified in the prior Form 1205s filed by TCI, both at the system level
and as aggregated filings, C2's analysis of the 1999 Form 1205 was premised on the
extent to which TO continued to incorporate costs that had been identified, in prior
analyses, as inappropriate. Such cost categories included:
• Security devices and repair
• Self insurance already embedded in programming service rates
• Tap audits
• Disconnects
• Converter Retrieval
Based on C2's analysis of TCI's forty sample systems' Form 1205s, none of the above
costs have been included by TCI in its 1999 aggregated computations. However, C2 did
note three additional issues with respect to TCI's 1999 Form 1205 computations:
I. TO should calculate the incremental cost increase for self insurance based on an
averaging of the monthly subscribers during the fiscal year.
2. TO should limit its inventory of converters to a more appropriate level.
3. TO has not justified the significant increase in the number of hours assigned to
converter repair and maintenance as compared to prior years.
1. Self Insurance Calculation
In its 1998 Form 1205 filing, TO provided a computation for self insurance costs that
had not previously been included in the programming services rates. C2 recommended
that this incremental increase in self insurance cost be included in the computation of
the HSC. In the instant filing, TO has again proposed to include the incremental
increase in self insurance. In computing the amount per subscriber not already embedded
in the rates, TO used the number of subscribers as of the end of the fiscal year (i.e.,
December 1998.)
In C2's opinion, the use of the year-end subscriber count is inaccurate in that TO sold
many of its systems during the year. The number of subscribers at the beginning of the
year was significantly greatly than the year-end number. However, the insurance expense
per subscriber was incurred throughout the course of the year. Therefore, in C2's
opinion, a more appropriate measure of the amount of self insurance per subscriber is to
use the average number of subscribers during the year.
The impact of using the average number of subscribers during the year in the
computation reduces the maximum permitted hourly service charge by approximately
' $0.05. However, this adjustment does not reduce the HSC below the TCI's operator
selected rate of $27.00.
Ordinance No. 1744-7-99
City Representatives
May 20, 1999
Page 5
' 2. Converter Inventory
In the instant filing, TCI reflects the total investment in converters and spreads these
costs over the number of units that are in service. Based on the data provided by TCI, the
total investment reflects a fourteen percent inventory in non -basic only converters and an
eighteen percent inventory in basic only converters. In C2's opinion, these inventories
are somewhat excessive.
Based on the Form 1205 instructions, the gross book value of equipment included on
Schedule C can include:
... the cost of a reasonable number of spare customer equipment units that the
operator keeps on -hand as replacements for broken equipment',2
Pursuant to the formulae, the operator would include the capita[ costs of such "spare
units" without reflecting these units as "in service' on Line C of Schedule C. The result
is a higher per converter cost in order to compensate the operator for the requirement of
having "spare units" to easily replace damaged or non-functioning units.
However, a fourteen to eighteen percent inventory of equipment does not appear to
satisfy the classification of"spare units." Therefore, if TCI is going to include the capita[
costs, then there should be some portion of the units that are considered "in-service"
since these additional units do not appear to be strictly "spares".
The FCC has taken the position that it is the burden of proof of the cable operator to
support any level of equipment inventory. As noted in FCC Consolidated Order DA 95-
720:
`9n rate regulation proceedings, the cable operator, not the franchising authority,
bears the burden of proof. The determination of whether a cable operator should
be allowed to recover the costs of allegedly excess inventory in its rates is an
issue to be left to the discretion of the local franchising authority, and we will not
disturb the findings of local franchising authorities if there is a reasonable basis
for its decision.'s
C2 adjusted the inventory to reflect aten percent (10%) level for each category of
converter. This adjustment impacts the monthly lease rates for converters, but does not
reduce the maximum permitted rates below TCI's operator selected rates for the rate year.
' e Form 1205 [Revised August 1996) Instructions for Schedule C Capital Costs of Leased Equipment, Line
D.
' Crown Media, Inc. d/b/aiCrown Cable, Consolidated Order DA 95-720, released April 5, 1995.
Ordinance No. 1744-7-99
City Representatives
May 20, 1999
Page 6
3. Converter Repair and Maintenance Hours
In its filing, TCI assigns a certain number of the total regulated hourly activities to the
repair and maintenance of converters and remotes. This particular computation is based
on the data that is collected from its forty sample systems.
In the prior two aggregated Forth 1205s, TCI assigned approximately one-half hour per
converter for maintenance and repair. These repair costs (as computed by using the
HSC) along with the capital cost component are combined to determine the appropriate
monthly lease rate for the equipment.
In the instant filing, TCI assigned slightly over three quarters of an hour for each
converter in service. C2 questioned the extent to which TCI researched the variations in
the reporting of these hours over prior years reporting. TCI stated that, in general, the
sample systems are asked to complete questionnaires concerning time spent, costs, etc,
for their respective systems, but that the Company had not routinely followed up on such
variations.
Without supporting documentation that the significant increase in the hours assigned to
converter repair and maintenance is justifiable, it is C2's opinion that the average for the
last two years should be used. Adjusting the hours to approximate the one-half hour
assignment reduces the maximum permitted monthly lease rates for remotes and
converters, but not below the operator selected rates chosen by TCI.
SUMMARY OF RECOMMENDATIONS
Based on the above findings and conclusions, the Cities should consider taking the
following actions:
1. Approve the operator selected rates proposed by TO for installation and
equipment rates as being reasonable.
2. Request that the Company institute quality controls for consistency in the
reporting of data by the forty sample systems should the Company continue to
employ this aggregated methodology.
C2 appreciates having this opportunity to work with the Cities in review of the Form
1205 rates. If you have any questions regarding this report or need clarifications as to the
recommendations, please contact Ms. Connie Cannady at (972) 726-7216.
Very truly yours,
C2 Consulting Services, Inc.
Ordinance No. 1744-7-99
Exhibit T"
ENCINSULTING SERVICES, INC.
' 7801 Pencross (972)726-7216
Dallas. Texas 75248 (972) 726-0212 (fax)
June to, 1999
Mr. Michael Stanger
Assistant City Manager
City of Allen
One Butler Circle
Allen, Texas 75013
Dear Mr. Stanger:
Pursuant to your request, C2 Consulting Services, Inc. has reviewed the May 21" letter from TCI
Central with regard to TCI's proposed Form 1235 rate. As you are aware, the Form 1235 is an
abbreviated cost of service filing for capital and operational costs related to significant network
upgrades. The upgrade of the system serving the Allen franchise area was completed in
December 1998!
This study does not constitute an examination of the financial condition of TO or its parent
company. As such, C2 cannot and does not express any position with regard to the accuracy or
validity of the financial information provided by TO during the course of the analyses.
OVERVIEW OF THE FILING AND PROPOSED RATE
The Form 1235 was developed by the FCC for use by cable operators that had significantly
upgraded the systems providing cable services. Pursuant to the FCC instructions, Form 1235 rate
increases are limited to:
"(1) the actual costs of the capital improvement, less any gains realized from the
disposition of property, plant, and equipment used prior to the upgrades; (2) a reasonable
return on the net investment in property, plant, and equipment used to provide the
upgraded services; and (3) additional expenses necessary for the delivery of upgraded
services, including changes in operating expenses and depreciation on property, plant,
and equipment... The recoverable costs of the upgrade would be added to the rates
permitted under benchmark... The recovery period for upgrade costs would be the
weighted average of the useful lives for the plant placed in service from this upgrade."'
On or about March I, 1999, TO filed Form 1235s with the Cil of Allen, requesting a "pre -
approval" of $1.29 to be added to the Form 1240 basic service rate.i Pursuant to the FCC
Based on Attachment I of the Form 1235 filing.
' r FCC Form 1135: Purpose and Filing Invoucrionq Abbreviated Cost of Service Filing for Network
Upgrades—General.
' The combination of the maximum permitted proposed Form 1240 rate of $12.15 and the maximum
permitted proposed Form 1235 rate of $1.29 is a proposed maximum permitted basic service rate of 513.44.
Ordinance No. 17447-99
Mr. Michael Stanger
' June 10, 1999
Page 2
regulations, a "pre -approval" filing can be submitted based on the total estimated costs for the
upgrade, but can not be charged to any subscriber until they are receiving the services. A "final"
upgrade filing is submitted 30 days after the completion of the upgrade with essentially a "truing -
up" of the capital and operating costs that were originally estimated in the "pre -approval" filing.
TCI's original "pre -approval" request included all of the regulating franchise areas served by the
entire TCI Cablevision of North Texas.' The costs were allocated to the basic service tier based
on the number of channels offered via such tier. TCI had not included costs related to
construction subsequent to 1999 and/or Allowance For Fonds Used During Construction
("AFUDC"), but had indicated that it would include these costs in a "final" filing.
DISCUSSION
C2's analysis of the Form 1235 as filed identified two main issues that were brought to TCI's
attention by C2 and members of the City Staff. These issues are:
1. Given that the Allen system is already complete, the inclusion of this system in the
aggregated filing did not appear to be appropriate.
2. The allocation factor employed by TCI did not appear to be representative of the
benefits received by the basic service subscribers.
Through a series of discussions with TCI representatives, the provision of additional Form 1235
computations and the estimation of differences between the "pre -approval" filing and a "final"
' filing, TCI presented a maximum permitted Form 1235 rate of SI.19. With the acceptance of this
rate, the City would not be required to review a "final" Form 1235, nor would any additional
costs that have not been included in the "pre -approval" filing (e.g., AFUDC) be added at any
future time.
It is C2's understanding that TCI does not require that the City acquiesce to any of the
methodologies presented, but only to agree that the SI.19 is a reasonable Form 1235 rate given
the FCC computations and potential changes if the Company were to file a "final" filing in the
near future. It is only with this understanding, that C2 concludes that the $1.19 appears
reasonable.
C2 appreciates having this opportunity to work with the City of Allen in review of the Form 1235
rates. If you have any questions regarding this report, please contact Ms. Connie Carmody at
(972)726-7216.
very truly yours,
C2 Consulting Services, Inc.
' However, the operator selected rate chosen by TO is $12.50. The filings for the City of McKinney and
Stonebridge Ranch are identical to that filed in the City of Allen.
' In its filing, TO noted approximately 50,000 basic service customers ultimately impacted by this
aggregation of costs.
Ordinance No. 17447-99
1
Exhibit 'ICI'
MdONSULTING SERVICES, INC.
7801 PenCFOSs (972) 726-7216
Dallas. Texas 75248 (972) 726-0212 (tax)
May 21, 1999
Mr. Michael Stanger Ms. Debra Wallace
Assistant City Manager Assistant Finance Director
City of Allen City of McKinney
One Butler Circle 222 N. Tennessee
Allen, Texas 75013 McKinney, Texas 75069
Dear City Representatives:
C2 Consulting Services, Inc. ("C2") has completed its review of the FCC Form 9240s
submitted to the Cities of Allen and McKinney, Texas (the "City") by TCI Cablevision
of Texas, Inc. ("TCI" or the "Company") on or about March 1, 1999. The following
report provides a brief discussion of the issues noted during the review, and C2's
recommendations regarding potential City Council actions for TCI's proposed basic
service rates.
This study does not constitute an examination of the financial condition of TCI or its
parent company. Therefore, C2 cannot and does not express any position with regard to
the accuracy or validity of the financial information provided by TCI during the course of
the analyses.
OVERVIEW OF THE FILING
TO filed the identical Form 1240 computation for the services provided in the City of
Allen, the City of McKinney, and at Stonebridge Ranch. TCI stated that its rationale for
doing so was that the headends that were providing services to each of these systems
have been consolidated into the Stonebridge Ranch headend operation. Therefore, TCI
filed the Form 1240 based on the computations from the Stonebridge Ranch Form 1240
from 1998.
In the Report and Order for CS Docket No. 95-174, the FCC encouraged uniform rate
setting to the extent that the computations would not result in rates that were higher than
Ordinance Nn. 1744-7-99
City Representatives
May 21, 1999
Page 2
' would otherwise be under separate rate -making proceedings.1 In the instant filing, it
appears that the use of the Stonebridge Ranch filing results in a slightly higher rate for the
prior McKinney system and a lower rate for the prior Allen system. However, TCI is
correct is stating that the programming being received by each of the locations is now
from a sin¢le headend (Stonebridge Ranch) and is identical in line-up for each
jurisdiction.
According to the information provided by TCI, the basic service tier includes twenty-nine
channels. TCI currently charges $14.06, $11.80 and $11.94 for basic service in Allen,
McKinney and Stonebridge Ranch, respectively and proposes to change the rate to
S12.15.' The new rate year is from June 1, 1999 through May 31, 2000.
ANALYSES OF THE FILINGS
Project Objectives and Activities
The project objectives are three fold:
I. Assessment of the completeness of the filings with regard to the information
and documentation that must be filed with the Cities.
2. Assessment of the reasonableness of the proposed computations in light of
FCC regulation and recent FCC rulings.
3. Assessment of the reasonableness of the proposed computations in light of
TCI's proposed method of aggregation and prior rulings by the Cities.
Given these objectives, C2 conducted the following project activities:
• Review of the filings to assess the completeness based on the FCC Form
instructions
• Review of the filings to identify any issues with respect to the data and/or
methodologies employed by TCI
• Submission of follow-up data requests and subsequent review of TCI's
responses
• Review of recent FCC decisions that have an impact on TCI's proposed
methodologies or the Cities' alternative actions
• Development of potential alternatives available to the Cities in establishing
maximum permitted basic service rates.
r The FCC ruling appears to have been with respect to setting uniform rates for subscribers in a geographic
area that were not necessarily served off of a single headend with identical casts.
' a m
Therefore, the esteal cost of the programming is the same for each subscriber.
The total rate proposed by the Company is $12.54. The additional $0.39 is related to the Form 1235
amputation. The Form 1235 is for the recovery of upgrade capital costs and will be discussed in a
separate report.
Ordinance No. 17447-99
City Representatives
May 21, 1999
Page 3
' SUMMARY OF FINDINGS AND RECOMMENDATIONS
Based on the analysis, C2 identified one main issue with respect to TCI's proposed
computations of basic service rates:
1. TCI inappropriately requested a change in "mark-up" costs for channel
additions to the basic service tier subsequent to January 1, 1998.
Proposed Adjustment for Mark-Up Costs
As originally established, the computation of the Form 1240 included adjustments to the
basic service rates for the adding or movement of channels to and/or from the tier. Based
on the total number of channels offered on the system (inclusive of all regulated
channels), an operator could add an additional "mark-up" to the rate for an increase in the
total number of channels offered on the basic service tier. In addition, an operator could
add/delete the residual costs of a channel when it was moved from/to the expanded basic
service tier.
Section 76.922(8) provided for these adjustments and was implemented with the passage
of the Thirteenth Order on Reconsideration in 1995. However, §76.922(g)(8) provided:
' `.Sunset Provision. Paragraph (g) of this section shall cease to be effective on
January 1, 1998 unless renewed by the Commission."
In a ruling released March 26, 1999 (FCC 99-12), the FCC made reference to this
provision as follows:
"CATA proposes to revise this rule to clarify that the "Mark-Up Method" of
adjusting rates continues to be available to cable operators. We find that the
reinstatement of the "Mark-Up Method" of adjusting cable rates is an issue
involving rate regulatory matters and therefore is beyond the scope of this
streamlining proceeding."[pamgmph 3 1 ]
However in the ordering clauses, paragraph 37, the FCC provided that §76.922(g) be
changed only to sunset specific provisions that did not include "mark-up" and residual
cost movement.
The inconsistencies were brought to the attention of the FCC and on April 27, 1999, the
Erratum was issued that deleted paragraph 37. Thus, §76.922(8), in its entirely, sunset
on January 1, 1998.
Within the filing, TCI proposes to increase the basic service rate for the addition of two
channels in December 1997 and four channels subsequent to January 1, 1998. Based on
the FCC's ruling, C2 concludes that the "mark-up" costs related to the adds in December
Ordinance No. 1744-7-99
City Representatives
May 21, 1999
Page 4
1997 should be allowed, while the proposed additional costs for the four channels added
in June 1998 should not be included. The adjustment to exclude the latter reduces the
basic service rate by approximately $0.06.
Recommendations
Based on the above findings, C2 concludes:
1. The Cities should consider excluding the additional "mark-up" costs for
channels added subsequent to January 1, 1998, resulting in a Form 1240 basic
service rate of $12.09.
C2 greatly appreciates having this opportunity to work with the Cities. If you have any
questions regarding this report, the project activities, or any of the recommendations,
please contact Ms. Connie Cannady at (972) 726-7216.
Very truly yours,
C2 Consulting Services, Inc.
Ordinance No. 1744-7-99
FWnel t'mw 2010 t'wun,aim
NmM1mgbn IX' 3e33J
t Sbtir of Previoe FRmg of FCC Front 1210 (enter an -i m Me appropriate box)
Appre�d by ulm ..S
11S NO
a Hot eo FCC Four 1210 been mviowly Med wide the FCC?
Lw Il yc. tuner dote.1 the .'et mans ldee:0 (m dddYY)
ES No
m FCC Fluor, 1210 been prev Med with Me Pmmhvere Amhaity?
if ycc, emer the dein of ON, amexent[lit:0 (melediry)
9. Slamx of FCC Fora 1200 Filing (enter an'i in the vpmphate box)
Tel NO
a His No FCC Form 1200 bear pmvlouly hind. Al Me FCC?
IIYes,emerthe dab MedO (wall
YES NO
A Har an FCC Fort 12M berm mviouly lied web Me Fmlchwmg Authority?
If Yes, mterthe ddelied0 (ramlddlyy)
10. Cable Prngmv in, Services Cnaplaint State (emer e'i in the appropriate box)
NO
a wthwo Imbeve lied'm announce apne to FCC Fav 329 compleerdt
If ye, emer Me Mme of Me complerat (rev M*Y)
YES NO
It. le FCC Fore 1205 Being Included WA Thin Fogg
12. Settled. .1'Gomlg Forered' Channel Addition Methodology (enter m'i in An esprox ime box)
=Cheat here iyou me wee Me o igerW Iola [MARKUP METHOD[.
=Cha ck Iwe iyou. wing the Of alternative Ne [CAPS METHOD].
11were the CAPS METHOD, heve you elected 1. .,in recovery la
ch.& added long Me proof Mry 15, 1994 to Dec. 31,19911
YES NO
13. Headead Upgrade Methodology
•J'..iro,�a'eremm.mrnaJtrr.a.etrre4�Ay:•'w,sw.w�E®+^�Awy...dv�d...vy�ewsu.eeay".r:.ee..werwe.
Check here iyou are aqueliytax mall ryabre were Me meandered heedend upgmde methodology.
Part I: Preliminary Information
Module A: Maximum Permitted Rat. From Previous Filing
s r d
Lou Description actio Twr2 Tura tiara lier5
AI Cure. 'I.—. RrmXud M@ 1$1195
bd
1.ve Line De e [low Twr x Ter T far J Tier 5
m' X.vRe SUNariWWpFa Tne llp PwwJl2 4
Z52
b d
Derw Te, 2 Tiu 3 Twr a Twr 5
m' Aruge SubvnWNp 4oirve-I�p
Cunallemeudumun Segew
Ill FvtimelN A•vaga 5obcnbvabiP FV Full Rnotl VAI[
nT
dlelioc
Idluiw r.— lrw T—A,
IrMao I..a Fa I—'rp
Carron FCC IdWiw Fault
to
I.iu
Lise mavioina,
b d
Derw Te, 2 Tiu 3 Twr a Twr 5
DI
Cunallemeudumun Segew
wour.
nT
Cuua Eueeel Cew46e.
MI.b7119
Cana Cepa Method Scream
menew
Cuun Ma ke, Me1hM 5egleea
mow
Cana Chaoul Mo•cen am Oeleines,peael
(10.1014)
06
Cuun Tnwt'p Sgaam
W.I=
Mee 2 Muoaml EmI m Vatic FCC FMy 1916
Ordinance No. 17447-99
Febd C�mwetliw Cmnsw
WmbmpOn nC N331
npmo.ed by GMu vroa6vs
Module E: Timint Information
\um6rd Mwal6dwee LLe ed dTv-Up peed I W IM.W d da
Module F: Maximum Permitted Rate For True -Up Period 1
I3.
I1!
6 d
OL TL res Tir1 r..s
FI
Crp Meapd SRSFIla Tp UpM1 l(WF121
MmMq m., Srwd Fm Tw-Uppend21WSI 1
F]
MmWWAWSrwmFa Tp Upp IJW621
Wm00
FS
CWMum Nl Sgmeu FaTn Uplbiotltf W' l
(W1014)
FI
Tw Upp lR4 EkybY FaldYbplOMFIFFNFx1
slab s
FS
IpReiop Sgwdru Tm Uph l[(p'UI Rj
W1124
%
H WUpaehSg=WFVTne-Uppeed I1W 61
7
Etl CmLLfi{meel Fm Tm Uphriodl 1W 71
W.mll
4T
TutUpSt Fn TnrUphn^dl
I0.16
I.o
Mni RY Iw TmAlphned 111MFHF O+FPl
SII.wW
Module C: Maximum Permitted Rate For True -Up Period 2
L2w
Id
Li -nen' Ruk r.x Tlvs Ter4 rin5
Cep Sle6ad Srywd Fe Trn.Up Po 21WF121
MmMq m., Srwd Fm Tw-Uppend21WSI 1
PON
CW W. Geld. Segwd F. 1. Up p W21W "I
W
TL'Po 2R. Elaibk Ea [d .-JP FSWIWNWI
GS
Idlein smwm ru True Vp N,W 2(W'CIWII
G6
llednd Vpp k4SwGM1a Iru Up W21W 61
G]
61kmICaLl Frwrl l'u 1es-1'p1a 2(WC111
Tm{'p Serred Fn Twi'p hwd 2
Mu Mm Rw le'Irv�l'p hmI21G1eG3rW W]WNI
FCC F-1210
rpt Maeo1d11':mI1.0 Vexes Jw, 1m
Ordinance No. 1744-7-99
FadnJ Cwmn mCmmiso
N'mMndm CC 20I5<
Module it: *rmi, Up Adjustment Calculation
Ap,-W by onle 3ryAU}45
Pail III: Projected Period
Module t: New Maximum Permitted Rate
Iia
Lep Dr
6 e
Rnk lira Tma3 Tare Tb5
H
Fm Te Ilp MidI
a Fmmnriod 1
SUKAIx 2a
IS
mmFmMm la ItpplmR l
i3.36MI(U]A39UpPomJiMjudmemtD2Hll
r
swuna.11e"
.Poled l AA..
FS192MW
Fm Tem -Up paid 2
m.de.e UpRde MrvdFa Paajemd Pmiod 1U 61
es Frafl 2Elpi6M rm lampm
5YnMCaLe LRatlFm Agxmtl Pemdlw4ll
ROM
Fam Ma Rome Rem lm Po 2Flgibm Fa lmeem
Ta Up SpatlFm Pwp3 W
w
IFiad 2 Mpuam ftAm Fe leleee 1IwHS)
MURne la Pg W PaW IW]5+16eHHM
IIU
Imma-1 2 miuemed(Sa iWemtiom rm re e )
Olvelm5hamd Rme Fm Fojerw Mod
He
Renes Fom Powd 2laliD'N lm lama
1110
Renes Fmm Ma Fra Rae la Neil 2 lmliew la lmmem
on
Najd 2 MNmam lmSybk For lmmel IHIDIMI
eW T.u, Adjemmem
12
ftt o ReseiepT�Up Atljodaa
11I3
T"T—Up Adj..RlMpH7.Hp4HII.H12l
$74@2.5315
HII
Ammm dT1m-Up CluadFa lYoflymmd lbwe
iJ9.m25H5
HIS
Remeieft Ta Up Ad1.—e1I116H1AI
womm,
Pail III: Projected Period
Module t: New Maximum Permitted Rate
Iia
Lim M.O.-
6 e d
Deem Tier 2 Tor 3 Tw 6 Tier 5
H
Cepa MCUod Srymetl fa Ngmmtl PowdlWSe21
IS
Mmtup MCWN Setnevi Fa FgmW Re—d 1w 51
Moen
CW Mvmm NW Sryam Fm Fgetmd Mod lI9FRY51
(10.1014)
Fq. Mod R. Eb,.W Fm ldodue JW+F5cG5+II 12.131
Imumme Sped la Fojeled IViod R14-CSh14I
$I I.Ob69
MOW
16
m.de.e UpRde MrvdFa Paajemd Pmiod 1U 61
I7
5YnMCaLe LRatlFm Agxmtl Pemdlw4ll
ROM
IU
Ta Up SpatlFm Pwp3 W
maple
le
MURne la Pg W PaW IW]5+16eHHM
112.W05
IIO
Olvelm5hamd Rme Fm Fojerw Mod
1 $113e
�nm7t®mammwamM+.,o-re,,.,m.rx2e.a..armreams.✓Ada±e'�m�..er,:. o�me.nsm�wmn-a..o-w.rdirrc Q>a...Nr/ sg2mdm+�'maa,dum
_ me.a,sa�eddroa.oar.mew®r..e.seda+..�v>Nrsmaal'✓.w�Areov...d.ramemf.,eve...a,ma�.w
CMiiedpm Sltlaeml
WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND/OR IMMSONMENT
(U.S. CODE TITLE 10. SECTION 1001), AND/OR FORFEITURE (U.S. CODE. TITLE 17. SECTION 503).
m aW IO Ne bat R I twill betel ma. made Cl good left
SMnebee Dde
Nme mW Tide of Prion Cmpletug Die F9m:
Tdepham mmba Fm Naber
1(C 1-1202
Pel OIMriiDancevo.'iR4-7-99 Joe, 19%
p
Fedcod Commlmicetiom Commmion
W6h'nklom DC 20554
Approved By OMB 30600685
Worksheel I - True -1113 period Inflation
For vmwcoaa. eu Appmda A of lm,.n me For FCC Fam 1240
IA.
rer4tl
FCC IMnOm F'annr
101
IQ
103
101
105
106
101
108
109
110
III
112
IU
Month 1
Month
M.th3
Month
Momb 5
Mash6
MwM7
Mash 8
Ma0h 9
Month 10
Month 11
Mmlh 12
Avenge ln0411m Fsssa for Tm Jp
1'er4d I
1.43.1
1.14%
1.14%
1.14%
O.U%
0.82%
0.8x%
1.00%
1.00%
IAO%
1.00%
10055
10103
114
115
116
ill
18
119
IN
121
122
123
IN
125
126
Ma0h 13
Mash 14
Momb 15
Mash 16
Momh 17
Mash 18
Mamh 19
Mmlh x0
Month xl
Month 22
Mash 23
Mash 24
A.<repe Infletmn I -.or fa I'ae-Up
renpd x
FCC Fore 1240
Fqa 1 Microsoft Excel 4.0 Vmiw MY 19%
Ordinance No. 17447-99
F.d Cormwice,i. Conmmioo Appmv,d By OMB 3060-0665
WwhmWm DC 20551
Worksheet 3- Markup Method
True -Up Period, Basic Tier
Fa hxmKtimu.,m Appedi, A of hrmcnwu Fm FCC Fmm 1240
T—up Pmol Pm IM Pend
QY,mm1 I. W—le IM1e pcnd for which this w short i, beng od. 1Pm m' X' w the eppropnw boa.) IX
Qw.2 Wicnr Ne 4a(m xbicM1,hn xoiblwe, isbeuM,ved.lfU,m'X'mdr appmpdre bo,)
Bmic i Tim2 Tic3 Tier Tier5
X
(juc,nm 3. Hox .,m the fi. Pend, in maths. fm whrh ale, em being,el x11M1 Ihi, wm4,h.? 12
Q.4. How"i, Ih, rand pad. m mmnhs. For which ams em being rr w &,M1is wnh t? 6
Ordinance No. 1744-7-99
FCC F.1240
age 1 My 1996
Fedend Ccmmicssinas Cosmesim Ap ved By OMB 3060-0695
Washh,Ias6 a N554
Worksheet 3 - Markup Method
Projected Period, Basic Tier
Fa iasmcuans. sec Appsm ix A of hnintsi asp Fa FCC Form 1340
T—up Period p'*,utiPeriod
Qm+eon I. Wimte IM1e pemd pm which An wexkeM1mt is lice, used. (M- W in the epryopmte ham.) I X
Qsedon 3. Mkem IM der fm which this waYshed is bem, used. (M his W in tive eppop ide bass)
Bask Tina Tina Tiers TiasS
X
Qts,i6m 3. How ling is t1n Om ptsoW. in mwxM1s, lw wWM1 mics sm being en with this v ss;hmt7 13
Quntisn 4, Bow his, is the snmd psiM. kmonths. his wbkh min em bee, st with this w nits? 0
I
Ordinance No. 1744-7-99
FCC F.1140
Ates Joy 1996
Fedor Commmucnliom Commmion Appmved By OMB 1060-0685
Wmhi(gton, DC 20551
Worksheet 5 - Channel Movement and Deletion
True -Up Period, Basic Tier
FwaWu tim, xc Appedin A of In noon m F" FCC Fam I240
Qlxmkw 1, IMiute lk lerid for wh.h thio wwrkdmm mkft toot (ft sn'X- ..he ol'1'nY'nole hn)
1.. Up I'mod I'rojuYN !'enW
X
whole de I ier frrwhich this
Qoealim 3. How"w the fico peoioi. ie mama. for which Mn w being rot with this wMsha14 IS
Qto e.Haw Imga Mseemdperiod,wmwnhs,farwhichmlmombhgs wishthiswenhshrn9 0
FCC Farm 1360
Pqe 1 Mirnaoh Fgael 1.0 Vmion IWy 1996
Ordinance No. 1744-7-99
FedW Covvmipdia0 Cmv'vim Approved By OMB 30600665
We 6WIM DC 20551
L Workshecl5 - Channel Movement and Deletion
Projected Period, Basic Tier
Fa eM . to AgeWix Aofhwee .For FCC Faa 1240
Qe 1. Winn die pemd fa which dtit wohchen ie berg �.(Dd m'X' M the Oppge *Me.)
Tv pPmW Pv od Pmol
X
Qnedm 3. How Imp ie Ne fi. pe .mmmdu, ra which n.n en bn,. with thie wwhdvell
Q1 4. Haw Iwg it Ow 1ecaW period. w m , fm which wtw w bw, W whh We wwheheet9
Lw
501
502
Pei0d
F A.Period
Ma 1
aaidOYd dp DaleW
Ti
Floe Tie
54.9000
I
RoiduldCYwei Mored
(odded)biie
500000
3
Nd P COe.el Cml
Adjeded iC W. S•C01�v
SOA000
4
C.dWNd PvCY®el
CCod Adjmeveffi
(10.1014)
(10.1014)
503
Ma 2
Samoa
$0.0000
50A000
(10.1014)
504
Madh3
50.0000
$0.0000
10.0000
(10.1014)
505
Mad14
10.0000
$00000
10.0000
(10.1014)
506
Mm 5
SO.ONO
$0.0000
10.0000
(SO.1014)
501
MOWh6
10.0000
10.0000
50.0000
(10.1014)
0
Ma ?
10.0000
$DONO
SO -OHO
(10.1014)
Madh0
10.0000
10.0000
$0.0000
(10.1014)
Maeh9
$0.0000
10.0000
50.0000
(10.1014)
M1 10
$0.0000
$0.0000
10.0000
(50.1014)
$12
Moeh 11
10.0000
30.01100
10.0000
(50.1014)
513
MmM 12
500000
$0.0000
10.0100
($0.1014)
514
Awefo0e Period I
huml Mmueet.d Deldi®Adryeved
(10.1014)
FCC Fav 1240
P4ge 1 M.aft Fud 4.0 Version 3Wy 1996
Ordinance No. 1743-7-99
Fe Cavm—. Cmmutim
WMWSl BC mm
Worksheet 7 - External Costs
True -Up Period
Fv � s Apptlu A d b4vYim Fw FCC Fwv 13 W
Pia I. FowAiAl® FviW vsYm1111W vl Y8 xoi4n} IFw � x' in Ne rR+A�^ie NSI
4eiMia 2 Hov Isla b tle fn pio6. u oi.eM1r. M MioA � vo bwv d wiN No wvk.Mni
PvBs J.11ev InM i LLr �ul PkA b wwY. fv alid � n 6i7 wl .i16 bb vvbbnl
Append By OMBA60 S
IJ— Ilr llwnl aeMe TMJ Tb 3 Tirol T1w6
NrWd 1
Exk11W C.I. ERgIbk for M6
rllrl CabE bk for'
ml
CaO ofRegvewy Fa Cleeb A666Pivb Nn9ly
,ww Nllm uaeFnSwkW kMekd Fweee
slv.lnn
mz
xevemi.Im cmaw Pow F. pwiN
1ppp
m!
Copm6M Fm Fw P.
$14"5.63
AS
F I Cm ElipbM Fw 7.1% MwkW
f1,6.5M.16
m!
%M wup EW IW Cab
$157,391.6373
ESMIbd Cab NW MOW I., M.b
l'vviaePe}Yelmfw fv PvioE
m3
file 3pmifieTm Fw Pwwd
plpp
rot
iimliw 0.eleblCyeiw Paio6
3911.9.1
Toe
cawi.la llryuleiaYFm Fw lbier
uxmxb
m9
TeW FmWf Fw Poc6
SIm,965.11»
716
lbwlFlr. Pv�Selwoib ErimulfMeFv Fwidl
SOW71
1
CC Fav =
PVI Miina ce N . 17 July 19%
Ordinance No. 1744-7-99
rllrl CabE bk for'
CeMofRopm'vlF kC6eeb.164dfliesb NIJ9Iv
AM 5/i 191IFq M.kiq pklle6 Fw Peio6
13
Rimirm Cvoaefm Fw P—d
ll5
C! i3M Tm Fw Md
16
EavvlC EHOWFv T5`FMvkq
»5
Mvke6tbci c.
EIkJ Cab NM bk for Mmrkup
716
CikSmiry T®Fvrvvl
717
Frm3'se Be CWF. Pviod
711
l'vviaePe}Yelmfw fv PvioE
719
TW FiJmel Coo F. PavJ
7"
bIwMYFv'SuluilivF tmelfm Fw l'niad3
1
CC Fav =
PVI Miina ce N . 17 July 19%
Ordinance No. 1744-7-99
Fa Commuo .. Coww —
Worksheet 7 - External Costs
Projected Period
r0aiqu AFymdi�.�eflwN� is Fw FCC Fam Ii�O
Ghia 1. Fw wAieh Iwe Lr•IUE re7a BIIei6ew Ne MJ 1t (V w'f' in Be 4PmIMe Im.l
QYim2 Hw byelils+psioyvmeOa fw Mid tienLeinF aS WNNuwwkJsit
Or+la 0. Ibw by : tlr aaaM pio6w w W r fw MM tiw.. a W.e rs wiN N:.ws,s,e7
Am—By OMB L'OtlRS
Ib Ib Bern Bee1e n-2 lbr1 lbrf 11f5
Nrl.d 1
E7kmal C.ft ElWbk fpr M.
AI
Cu�fRopmWy Fw llmbMhdgbb1l1f91w
AM f 11 f 91 Uey 04e0q AMIGO Fw PaioO
f1A,N3M
1U:
Wtlse'maCwrvGm Fw Psiod
IO.M
fi}
Co ,W Fm F. P.
VIA3238
701
F,EwrIC.EIiOWFw7.1%f ,
slN &10
f
Mhel vbefrw cm
svw,lusnc7
Xltr.l Cab Not EI bk for Mrrbo
705
O spM im FwlUiel
{p.W
707FUM�WWd
UeFw Gmd
Fn.00
Mf
Cwm'smReryluwy Fm FwP
SI21iMS.f7
7nW EerNCo6Fw ltid
SiSI}41.M15
710
b ,pmSab.Tw EEmd C.FwP l
70.1777
KC F.
h12 Mvadl revel lA Venw IW71996
Ordinance No. 17447-99
Federal C...uwi. Comm®ion
WchiMbn DC2055/
Approved By OMBMWMN
Worksheet 8 -True-Up Rale Charged
imnuclim�, xe App—lix A of Imt—oohs Fn FCC Pmn 1240
v.nm I.:1:-,ome T—Up Ne I.in—o,7 Iz
Qucnm 2, 11. 1m8is the Tramp N& 2..n-1h,I 0
Lme
Lme Dmcliptioo
Rdc Ticr2 Tina Tierl Tim5
$01
802
103
101
105
BM
807
BM
BM
M
811
$12
813
Moldhl
Momh2
Momh3
Mor61
Momh5
Month6
Momh3
Mamhe
Momh9
moo h 10
Month 11
Monts 12
Pmod l Me Rale
$111600
$11.2600
$11,2600
$11.2600
811.1600
$11.2600
$11.9500
811.9500
811.9500
$11,9500
$11.9500
$119500
$116050
Ill Month 13
MaOm 14
Month 15
Mart 16
118 March 13
119 Month 18
820 Momh 19
821 Momh20
822 MO 21
823 Mo 22
821 Woth 23
825 Month 21
$26 Pmod 2 Avemgr Rete
�I
FCC Fa.1210
PO l Mwrmoh E.ad 4.0 Vmi. 2WY 1996
Ordivnnce No. 1744-7-99
�I
FCC Fa.1210
PO l Mwrmoh E.ad 4.0 Vmi. 2WY 1996
Ordivnnce No. 1744-7-99
EXMIT "D"
SERVICE
RATES
Hourly Service Charge
$27.00
Install - Unwired Home
$39.95
Install - Prewired Home
$21.50
Install - Additional
Connection Initial
$13.95
Install - Additional
Connection Separate
$18.95
Move Outlet
$18.95
Up/Downgrade
$1.99
Downgrade Non -
Addressable
$8.95
Upgrade Non -Addressable
$13.95
Changing Tiers
N/A
Connect VCR Initial
$5.95
Connect VCR Separate
$12.95
Monthly Lease Rates:
Remotes
$0.35
Basic Only Converter
$1.60
Non -Basic Converter
$3.50
Ordinance No. 1744-7-99