HomeMy WebLinkAbout15 - Cable Communications FranchisesCITY OF NEWPORT BEACH
CITY COUNCIL STAFF REPORT
Agenda Item No. 15
November 12, 2003
TO: MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: Robin L. Clauson, Assistant City Attorney
949 - 644 -3131
rcla uson(a)city. newport- beach. ca. us
Dave Kiff, Assistant City Manager
949 - 644 -3002
dkiff(a.city. newport -beach .ca. u s
Marilee Jackson, Public Information Officer
949 - 644 -3031
mviackson (a)city.newport- beach.ca. us
SUBJECT: Ordinance on Cable Communications Franchises (1st Reading)
ISSUE:
Should the City Council adopt a new ordinance relating to cable communications
franchises?
RECOMMENDATION:
1. Introduce Ordinance No. 2003 - relating to Cable Communications
Franchises: and
2. Pass to second reading on November 25, 2003.
DISCUSSION:
In the 1960s, when the City of Newport Beach entered into two separate franchise
agreements with companies that provide cable television service, cities across the
nation had a significant amount of say in cable companies' operations, including:
• Rates and rate increases
• Customer service standards
• Channel selections and placement
Cable Communications Franchise Ordinance
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Page 2
Cities were able to dictate these aspects of cable companies' operations because the
cable companies used the public right -of -way to lay the cable "plant" (plant includes
coaxial cable, boxes in the rights -of -way, connections to homes, etc).
Federal law has changed significantly since the City adopted its franchise agreements.
The changes, in part, took away almost all of cities' regulatory abilities relating to cable
and moved them to the Federal Communications Commission (FCC or www.fcc.gov).
Today, several different laws, ordinances, and agreements direct our decisions about
cable television. These include:
• Three federal acts relating to Cable TV and Communications (1984 Cable Act,
1992 Cable Act, and 1996 Telecommunications Act);
• The Newport Beach Municipal Code (Chapter 5.44) and City Charter (Article XIII);
• Our Franchise Agreement with Adelphia Communications; and
• Our Franchise Agreement with Cox Community Cablevision.
Attachment A contains a summary of the federal Acts.
The Effect of Changes in Law. It's important to remind the Council and Newport
Beach residents that:
• FCC regulates rates, not cities. The FCC alone has the power to regulate rates
and channel selections, with the lone exception of rate regulation on the basic
service tier of channels (typically Channels 2 -13 and PEG channels). Cities can
only regulate basic tier rate increases if fully certified by the FCC to do so. Cable
customers should note that cable companies rarely, if ever, raise the rates on this
tier - much more frequent are rate increases on the larger (and unregulated)
broadcast basic tier (Channels 14 -65 and up).
• Other tiers are generally unregulated. In March 1999, the FCC (generally)
deemed many cable systems subject to "effective competition" from satellite dish
services and removed almost all rate regulation from cable TV.
• Cable TV in Newport is not literally a monopoly. Cities like Newport Beach
have non - exclusive franchise agreements. Any cable provider can come into the
city limits, negotiate a franchise agreement, lay new cable, and compete directly
with either Cox or Adelphia. Similarly, Cox can attempt to compete directly with
Adelphia and vice - versa. But doing so requires significant investment in new
cable infrastructure, because each cable company owns the cable in the ground
(and on poles). Very few companies anywhere in the nation "overbuild" other
systems.
• Denial of renewal is extremely difficult and expensive. Cities cannot typically
deny a cable provider an opportunity to renew an existing franchise agreement.
• Internet services are unregulated. Courts have ruled that the provision of
Internet service over cable is not a cable - related service and therefore not subject
to municipal regulation. Newport Beach can do very little to help cable customers
interact with their Internet Service Providers (ISPs).
Cable Communications Franchise Ordinance
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Our Current Franchise Agreements. As noted, Newport Beach has a Cable TV
Ordinance and separate Franchise Agreements with Cox and Adelphia, respectively.
The Agreements have been extended several times as follows:
ADELPHIA FRANCHISE AGREEMENT
• Agreement adopted December 1966 —15 -year term (to 1981).
• Amended December 1970 — term reset again to 15 years (to 1986).
• Amended April 1986 — term extended by five years (to 1991)
• Amended October 1991 — term extended to January 27, 2002.
• Amended December 11, 2001 -- term extended to January 27, 2003.
• Amended January 27, 2003 -- term extended to January 27, 2004.
Adelphia Service Area
Old Corona Del Mar Linda Isle Westcliff
Cameo Shores /Highlands Newport Shores Eastbluff
Balboa Island West Newport The Bluffs
Balboa Peninsula Newport Terrace Irvine Terrace
Harbor Island Newport Heights
Lido Isle Dover Shores
COX FRANCHISE AGREEMENT
• Agreement adopted December 1966 — 15 -year term (to 1981).
• Amended November 1981 — term extended for 10 years (to 1991).
• Amended October 1991 — term extended to January 27, 2002
• Amended December 11, 2001 -- term extended to January 27, 2003.
• Amended January 27, 2003 -- term extended to January 27, 2004.
Current Cox' Service Area
Newport Center
Harbor Ridge Harbor View Hills
Jasmine Creek
Spyglass Hill Newport Coast
Big Canyon
Belcourt Newport Ridge
Bonita Canyon
Bonita Creek
' There are several areas of the City where the "primary franchise area" overlaps between Adelphia and Cox. These areas
include Newport Dunes, the Coast side of Bayside Drive, Promontory Point, the Hyatt Newperter, Harbor Cove, the Park
Newport Apartments, Bayview Terrace and Court, and the John Wayne Airport Area.
Cable Communications Franchise Ordinance
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Formation of Telecom Committee. With the franchise agreements about to expire, in
November 2000, the City Council formed the Telecommunications Ad Hoc Committee
and directed it to address the following issues:
1. UPDATING THE CABLE TELEVISION ORDINANCE. We believed that the City's
municipal code chapter that relates to cable television required significant
amendments before the City can enter into any effective franchise agreements with
Adelphia and Cox.
2. UPDATING THE MUNICIPAL CODE AND ENACTING A COUNCIL POLICY
RELATING TO WIRELESS TELECOM. We believed that the City should add a
new section to the municipal code relating to telecommunication to effectively
address:
• Where to site new wireless antennas;
• Whether and where to use City -owned property or rights -of -way for antennas;
• What design and structural standards the City should apply to antennas,
whether placed on rights -of -way or public or private property;
• What fee should be levied for the use of the public property for antennas;
• How to effectively ensure that the City's emergency radio network is not
adversely impacted by siting activity.
The Wireless Telecom Ordinance is now Chapter 15.70 of the NBMC. Council
Policy L -23 (The Siting of Wireless Telecommunications Equipment on City -Owned
Land) governs City actions relating to the use of City property for wireless telecom.
3. FRANCHISE RENEWAL NEGOTIATIONS. Given the pending expiration of the two
cable television franchise agreements, the Committee was tasked with performing a
community needs assessment and bringing to Council a Statement of Minimum
Goals. The latter was accomplished in April 2003.
The Telecom Committee includes Council members John Heffernan (Chair) and Richard
Nichols and community members Leslie Daigle and Don Boortz.
About the Current Cable TV Ordinance and the Charter. The Municipal Code (Chapter
5.44 -- Community Antenna Television) relating to cable television is outdated. It was first
adopted in 1966 and has had little change since then, even as:
• Federal and state telecommunications and cable law dramatically changed;
• Technology dramatically changed (digital TV, satellite TV, cable- carried Internet, pay -
per -view, digital cable radio, fiber optic lines, telephony over cable, etc);
• The city saw a series of providers transfer their Franchise Agreements from one to
another via consolidations and sales;
• Adelphia filed for reorganization.
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Currently, Chapter 5.44 of the NMBC and the City Charter speaks to the following issues
-- but please be aware that many have been pre - empted by changes in federal law:
• Defines "gross annual receipts" as compensation resulting from the operation of
a cable TV system in Newport Beach, but not the franchise fee imposed by the
City. In other words, a cable company's calculation of the 5% franchise fee
cannot include the line item on the bill that charges the franchise fee itself.
• Describes the process by which a cable company files a franchise application
with the City (along with a $1,000 franchise application fee).
• Directs the City to award a franchise with a term between 10 and 25 years. To
terminate a franchise prior to end -of -term, the City must find that a cable
company has "violated a material term or condition" of its franchise OR that any
part of Chapter 5.44 has become unenforceable and has materially changed the
franchise OR the City must acquire the cable TV system.
• Allows the City to inspect the cable company's records at any time.
• Empowers the City Manager to settle any controversy arising between the cable
company and the City or subscribers "in the best interests of the public."
• Directs the City Council to set a franchise fee that is a percentage of the cable
company's gross annual receipts (paid to the City quarterly).
Describes the proper operation of the "Newport Beach Community Channel'
which must be cablecast on the same channel number on all cable systems in
the City (NOTE: This does not occur today -- Cox uses Channel 3 for system-
wide programming and places NB communitv programming on Channel 30.
Adelphia uses Channel 3 for NB community programming). The channel
number can be designated by mutual agreement between the franchisees. The
Channel must include live broadcasts of all regular meetings of the City Council,
at least one re- broadcast of the meetings, and up to 20 hours of community
affairs programs per month as designated by the City Manager. When the
Channel is not broadcasting local origination material, the cable company can
run advertising that "promotes primarily persons maintaining an office within the
city..." The company can collect a fee for ads on the Community Channel.
• Requires the cable company to keep a toll -free phone number in the City as well
as a service and billing office within the main franchise area. Any subscriber
complaint must be addressed within 24 hours via correcting the problem or
scheduling a service call within 48 hours.
• Allows the City Council to review and approve all rates and charges for cable
services "to the extent permitted by State or Federal statutes."
• Allows the City Council to determine which franchisee serves a newly annexed
area, unless the area contains a completed or commenced cable TV system. In
the latter case, the area must be served by the company owning the system.
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The City Charter's section on franchises (Article XIII) requires the City Council to adopt
franchises via ordinance and to hold a public hearing prior to granting a franchise. It
limits all franchise terms to 25 years or less if a determinate term is stated. The Article
allows indeterminate terms but specifies that the City may end the franchise and possess
the franchisee's property if the franchisee is out of compliance with the franchise
agreement (Section 1302).
Preparing a New Ordinance. Since at least Fall 2000, the City has retained William
Marticorena of Rutan and Tucker to assist us in our telecommunications work. Mr.
Marticorena has extensive experience in all phases of franchise renewals and ordinance
amendments. Additionally, upon recommendation of the Telecom Committee, we hired
Sue Buske of the Buske Group to conduct a statistically valid Cable Needs Assessment
(CNA) to determine the community's desires and concerns regarding cable N (for more
information about the Assessment itself, see the Agenda Item from April 8, 2003
whereby the City Council formally accepted the Assessment).
The Assessment and the Statement of Minimum Goals will be used to negotiate a new
Franchise Agreement with each of the two cable providers. A Franchise Agreement is
separate and distinct from a new Cable Communications Ordinance as follows:
The Ordinance reflects the regulatory environment and practices that any cable
provider must follow while doing business in the City.
The Agreement(s) reflects specific permission to a specific company to use the
public right -of -way to operate a cable system. Included in the permission are
negotiated terms by the company and the city as to adequate compensation paid
to the City and its residents for the use of the right -of -way. Adequate
compensation may include the 5% franchise fee, dedication of equipment,
dedication of specific channels for Public, Educational, and Government (PEG)
services, and more.
More about the Proposed Cable Communications Franchises Ordinance. The
proposed ordinance addresses the following issues:
• Definitions. Sets forth and updates definitions used in the Cable
Communications industry.
• Authorization. Authorizes the City to grant non - exclusive franchises for cable
communications services.
• Rights. Reserves certain rights to the City and the cable subscriber; reserves
certain rights for the Franchisee;
• Finances. Explains how payments to the City are made in exchange for a cable
company's use of the public right -of -way; requires a performance bond
• Services. Explains the services that can be required of a provider;
• Construction. Describes the construction standards that a provider must meet;
• Customer Service. Describes the customer service obligations of a provider.
• Records Inspection, Audit. Allows for the City's inspection of certain records,
allows for the conduct of a bi- annual audit;
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• Termination. Describes reasons for termination and process to terminate; and
• More.
Provider Review and Comment. The Telecom Committee itself has not been asked to
review the proposed Ordinance, in part because it is a fairly standard ordinance that
reflects what other cities -- including San Clemente, Lake Forest, Dana Point, San Juan
Capistrano, Laguna Beach, Laguna Niguel, and Moreno Valley (all under the counsel of
Mr. Marticorena and Rutan and Tucker) -- have adopted in recent months or are
preparing to adopt. Since the Council's adoption of the Statement of Minimum Goals in
April 2003, a staff team (Mr. Marticorena, Ms. Clauson, Ms. Jackson, and Mr. Kiff) have
met at least two times each with representatives (including counsel) of Adelphia and Cox.
We have provided both companies with an opportunity to review the draft Ordinance and
to discuss the Ordinance with us.
This Agenda Item asks the Council to review the proposed Cable Communications
Franchise Ordinance, to read it for the first time, and to pass it to second reading and
adoption (set tentatively for November 25, 2003). If the Council wishes, it may refer any
comments made by the cable providers about the Ordinance to the Telecom Committee
for review between now and November 25. Ordinances like this one take effect 30 days
following adoption.
What's Next. If the Council adopts this Ordinance, the staff team and the Telecom
Committee would enter the final phase of their efforts -- the negotiation of new Franchise
Agreements with Cox and Adelphia reflecting the Statement of Minimum Goals and the
newly- adopted Cable Communications Ordinance. We anticipate bringing the negotiated
Franchise Agreements to Council in Spring 2004. That timeline may require a short
extension to the existing agreements, given that they expire in January 2004.
Environmental Review: This Agenda Item does not require environmental review.
Public Notice: This agenda item may be noticed according to the Ralph M. Brown Act
(72 hours in advance of the public meeting at which the City Council considers the item).
Funding Availability: Not applicable.
Alternatives: Not applicable.
Submitted by:
Dave
Clauson
Assistant City Manager Assistant City Attorney
Attachments: Attachment A -- FCC Authority
Marilee Jackson._
Public Information Officer
Cable Communications Franchise Ordinance
November 12, 2003
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Attachment S -- Proposed Ordinance on Cable Communications Franchises
Attachment C -- Letter from Adelphia
Cable Communications Franchise Ordinance
November 12, 2003
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Attachment A
FEDERAL COMMUNICATIONS COMMISSION (FCC) AUTHORITY
P 1984 Cable Act. The Federal Communications Commission (FCC) established new
policies over cable TV via the Cable Communications Policy Act of 1984. Among
other things, the 1984 Act began to define the boundaries between federal, state, and
local governments. The 1984 Act requires cable companies to act under franchise
agreements and prohibits local governments from offering exclusive franchise
agreements. This Act also limited the cable franchise fee to 5% of the cable company's
gross annual revenue.
The 1984 Act also:
• Allowed local agencies to require that cable companies set aside channels for public,
educational, or governmental (PEG) use.
• Established "leased commercial access" allowances so that parties other than the cable
company could air video programming without cable company oversight.
• Placed restrictions on telephone companies that wanted to provide television service.
P 1992 Cable Act. In response to price hikes in the cable industry that far outpaced
inflation, Congress passed the Cable Television Consumer Protection and
Competition Act of 1992. The 1992 Act stated the FCC's hope that the market would
begin to regulate cable TV activities while still protecting consumer interests. Under the
1992 Act, local governments could select a cable franchisee and regulate in any areas
that the FCC did not pre -empt. Prior to 1992, local governments could regulate all rates
— but with the 1992 Act in place, the FCC took over rate regulation of the cable
programming tier (see below) and allowed cable companies to be completely exempt
from rate regulation if they could show that the cable companies were subject to
"effective competition" in a region.
In the 1992 Act, the FCC defines three tiers of cable services:
• the basic service tier (lower channels originating in the region which must be carried
by the cable company). Local governments may regulate rates associated with this tier
when certified by the FCC to do so.
• the cable programming service tier ( "CPST ") — this includes all non -basic channels
provided by a cable company but not sold on a pay - per -view basis. Effective March 31,
1999, the FCC has declared this tier of service subject to "effective competition" and
NO LONGER regulates rate changes to this tier.
• the per channel or per - program tier — provided as single channels for which the cable
company charges a separate rate. This tier is unregulated.
Per the 1992 Act, local governments must apply for certification with the Commission if
they want to regulate rates in the basic service tier. We can do so by submitting a "Form
328" to the FCC. The City has not asked the FCC to certify the City as a basic tier
Cable Communications Franchise Ordinance
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regulator. This is in part because cable companies rarely, if ever, increase their rates on
the basic tier since the development of the 1992 Act — in recent years, cable companies
have reduced and /or maintained their basic tier rates while increasing their CPST rates.
Another important aspect of the 1992 Act set customer service standards for cable
companies — all of which must be enforced by local franchise authorities. Pursuant to the
standards, cable companies must:
Phone and Billing Services
• Maintain a local phone line available 24 hours, seven days a week.
• Not use voice mail during working hours — a real person must answer the phone.
• Place its bill payment office in a convenient location. The office must be open at
least one night a week and /or some weekend hours.
• Answer all calls to the cable company office within 30 seconds of the time that a
connection is made.
Installations and Service Calls
• Complete a standard installation within seven days of a service call.
• Begin working on a service interruption call within 24 hours of notification.
• Offer specific appointment times or four -hour blocks of time for all service calls.
• Have installers call if they are running late to reschedule at the customer's
convenience.
Rate or Service Changes
• Give 30 days advanced notice for all rate or service changes.
• Respond to billing complaints within 30 days.
P 1996 Telecom Act. Most recently, Congress amended the laws even further via the
adoption of the Telecommunications Act of 1996. The 1996 Act was an attempt to
accelerate private sector deployment of services to all residents by opening up all
telecom markets to competition, including allowing cable companies to provide phone
service and vice- versa.
The 1996 Act provided that the CPST would be subject to FCC regulation until March 31,
1999. The Act also prohibited individuals from sending complaints directly to the FCC —
instead, individuals must file complaints with the franchise authority (us) and we forward
one or more complaints to the FCC for review via an FCC "Form 329." Before sending a
complaint to the FCC, we must notify the cable company of the complaint and allow them
30 days to respond. We followed this process earlier this year in forwarding a rate
complaint by a resident.
The 1996 Act also:
• Requires television manufacturers to equip their TVs with a V -Chip.
• Requires broadcast and cable industry representative to develop voluntary rules
that rate programs for sexual or violent content.
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• Requires cable companies to fully scramble audio and video channels not
specifically subscribed by a household.
• Allowed some telephone companies to provide video programming via open video
systems (Pacific Bell Video Service [ "PBVS "] is an open video system that delivers
both local programming and national channels via a small dish or antenna). The
1996 Act exempted these systems from city franchise requirements.
• Limits local franchise authority fees to revenue derived from "cable services."
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Attachment B
ORDINANCE NO.
AN ORDINANCE OF THE CITY OF NEWPORT BEACH RELATING TO
FRANCHISES FOR CABLE COMMUNICATIONS SYSTEMS.
THE CITY COUNCIL OF NEWPORT BEACH DOES ORDAIN AS FOLLOWS:
Section 1. Chapter 5.44 of the Newport Beach Municipal Code entitled "Cable
Communications Franchises" is hereby added to read as follows:
Chapter 5.44
CABLE COMMUNICATIONS FRANCHISES
Sections:
Section 5.44.010
Title.
Section 5.44.020
Definitions.
Section 5.44.030
Grant of Franchise.
Section 5.44.040
Rights Reserved to the Grantor.
Section 5.44.050
Rights of Subscribers.
Section 5.44.060
Finance.
Section 5.44.070
Services.
Section 5.44.080
Design and Construction.
Section 5.44.090
Operations And Maintenance.
Section 5.44.100
Violations.
Section 5.44.110
Termination and Related Rights.
Section 5.44.120
Franchise Applications.
Section 5.44.130
Records; Reports; Right to Inspect and Audit; Experts.
Section 5.44.140
Miscellaneous Provisions.
Title.
This Ordinance is known and may be cited as the "Cable Communications Franchises
Ordinance."
Definitions.
a. For the purposes of this Ordinance, the following words, terms, phrases, and their
derivations have the meanings given herein. Terms defined in the Cable Act shall have the
same meanings herein unless expressly defined otherwise. When not inconsistent with the
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November 12, 2003
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context, words used in the present tense include the future tense, and words in the singular
number include the plural number.
"Administrative Officer" means the City Manager or the City Manager's designee.
"Affiliated Person" or "Affiliates" means each Person who falls into one or more of
the following categories: (i) each Person having, directly or indirectly, a Controlling Interest
in Grantee; (ii) each Person in which Grantee has, directly or indirectly, a Controlling Interest;
(iii) each officer, director, general partner, limited partner holding an interest of five percent
(5 %) or more, joint venturer, or joint venture partner in Grantee's Cable System in the City;
and (iv) each Person, directly or indirectly, controlling, controlled by, or under common
Control with Grantee; provided that "Affiliated Person" excludes the Grantor, any limited
partner holding an interest of less than five percent (5 %) in a Grantee, or any creditor of
Grantee, solely by virtue of its status as a creditor, and which is not otherwise an Affiliated
Person by reason of owning a Controlling Interest in, being owned by, or being under
common ownership, common management, or common Control with Grantee.
"Basic Service" or "Basic Cable Service" or "Basic Service Tier" means the lowest
Service Tier which includes the retransmission of local television Broadcast Signals and
Public, Educational, and Governmental Access Channels.
"Broadcast Signal" means a signal transmitted over the air to a geographically
dispersed public audience and received by a Cable System.
"1984 Cable Act" means the Cable Communications Policy Act of 1984.
"1992 Cable Act" means the Cable Television Subscriber Protection and Competition
Act of 1992.
"Cable Act" means the Cable Communications Policy Act of 1984, as amended by the
Cable Television Subscriber Protection and Competition Act of 1992 and by the
Telecommunications Act of 1996.
"Cable Operator" means any Person or group of Persons (i) who provides Cable
Service over a Cable System in the City and, directly or through one or more Affiliates, owns
a significant interest in that Cable System; or (ii) who otherwise controls or is responsible for,
through any arrangement, the management and operation of a Cable System in the City.
"Cable Service" or "Service" means (i) the one -way transmission to Subscribers of
video programming or other programming service; and (ii) subscriber interaction which is
required for the selection of or use of such video programming or such other programming
service.
"Cable System" or "Cable Communications System" or "System" means a facility,
consisting of a set of closed transmission paths and associated signal generation reception, and
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control equipment that is designed to provide Cable Service, which includes video
programming, and which is provided to multiple Subscribers within the City; but this term
does not include: (i) a facility that serves only to retransmit the television signals of one or
more television broadcast stations; (ii) a facility that serves Subscribers without using any
public right -of -way; (iii) a facility of a common carrier which is subject, in whole or in part, to
the provisions of Title H of the Communications Act of 1934 (47 U.S.C. § 201 et seq.), except
that such facility shall be considered a Cable System (other than for purposes of section 621(c)
of the Cable Act) to the extent such facility is used in the transmission of video programming
directly to Subscribers, unless the extent of such use is solely to provide interactive on-
demand services; (iv) an open video system that complies with section 653 of the Cable Act;
or (v) any facilities of any electric utility used solely for operating its electric utility systems.
"City" means the City of Newport Beach, California.
"Channel" means a portion of the electromagnetic frequency spectrum which is used
in a cable system and which is capable of delivering a television channel (as television
channel is defined by the FCC by regulation).
"Commercial Subscriber" means a Subscriber who receives a Cable Service in a place
other than a Residential Dwelling Unit.
"Complaint" means a dispute in which a Subscriber notifies Grantee of an outage or
degradation in picture quality, billing or other issue pertaining to the Subscriber's Cable
Service which is not corrected during the initial telephone or service call.
"Control" or "Controlling Interest" means actual working control in whatever manner
exercised, including, without limitation, working control through ownership, management,
debt instruments, or negative control, as the case may be, of the Cable System or a Grantee. A
rebuttable presumption of the existence of Control or a Controlling Interest shall arise from
the beneficial ownership, directly or indirectly, by any Person or group of Persons acting in
concert (other than underwriters during the period in which they are offering securities to the
public) of twenty-five percent (25 %) or more of any Person (which Person or group of
Persons is referred to as "Controlling Person "), or being a party to a management contract to
manage the system, or any material portion thereof, in lieu of Grantee.
"Converter" or "Terminal" means a device located at a Subscriber's premises that
converts signals from one frequency to another or otherwise processes signals for use by
Subscribers.
"Drop" means the cable connecting the Cable System's plant to equipment at the
Subscriber's premises.
"Education Channel" means any channel capacity where non - commercial educational
institutions are the primary designated Programmers.
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"Facilities" shall mean any equipment located, in whole or in part, in, above, or below
Streets, Public Rights -of -Way, or other public property used by the Grantor in its System
including without limitation, conduits, cables, cabinets, Nodes, structures, headend
equipment, receive only earthstations, down link equipment and antennas, electronics, fiber
cable, coaxial cable, drops and switching equipment.
"FCC" means the Federal Communications Commission or its designated
representatives.
"Franchise" means a written legal undertaking or action of the Grantor which
authorizes a specific Person to use the Grantor's streets and public ways for the purpose of
installing, operating, maintaining, or reconstructing a Cable System to provide Cable Service.
"Government Channel" means any channel capacity where local government agencies
are the primary designated Programmers, and programming is non - commercial informational
programming regarding government activities and programs.
"Grantee" means the Person granted a Franchise to install, operate, maintain, or
reconstruct a Cable System and the lawful successors, transferees, or assignees of that Person.
"Grantee Manager" means an employee of the Grantor who is designed by Grantor in
writing to Grantee to be the contact person for Grantee in accordance with the provisions of
this Ordinance.
"Grantor" means the City, acting by and through its elected governing body, or such
representative as the governing body may designate to act on cable matters in its behalf.
"Gross Annual Revenue" or "Gross Annual Receipts" or "Gross Receipts" means all
revenue, as determined in accordance with Generally Accepted Accounting Principles, which
is received, directly or indirectly, by Grantee and by each Affiliated Person from or in
connection with the distribution of any Cable Service, and any other Service which may,
under now or then applicable federal law, be included in the Cable Act definition for the
purpose of calculating and collecting the maximum allowable franchise fee for operation of
the System, whether or not authorized by any Franchise, including, without limitation, leased
or access channel revenues and programming fees of any kind, received, directly or indirectly,
from or in connection with the distribution of any Cable Service. It is intended that all
revenue collected by the Grantee, and by each Affiliated Person, from the provision of Cable
Service over the System, whether or not authorized by the Franchise, be included in this
definition. Gross Annual Revenue also specifically includes: (i) the fair market value of any
nonmonetary (i.e., barter) transactions between Grantee and any Person, other than an
Affiliated Person, but not less than the customary prices paid in connection with equivalent
transactions; (ii) the fair market value of any nonmonetary (i.e., barter) transaction between
Grantee and any Affiliated Persons, but not less than the customary prices paid in connection
with equivalent transactions conducted with Persons who are not Affiliated Persons; (iii) any
revenues generated from the provision of Internet services and/or broadband services which
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utilize the Cable System for delivery and must not be excluded pursuant to applicable law;
and (iv) any revenue received, as reasonably determined from time to time by the Grantor,
through any means which is intended to have the effect of avoiding the payment of
compensation that would otherwise be paid to the Grantor for the Franchise granted. Gross
Annual Revenue also includes any bad debts recovered. Gross Annual Revenue also includes
all (100 %) advertising revenue (without exclusions for any commissions, fees, or other costs
incurred in securing said revenue) which is received directly or indirectly by Grantee, any
Affiliated Person, or any other Person from or in connection with the distribution of any
Service over the System or the provision of any Service - related activity in connection with the
System, or allocable thereto based upon subscriber counts. Gross Annual Revenue does not
include: (i) the revenue of any Person to the extent that said revenue is also included in the
Gross Annual Revenue of Grantee; (ii) taxes imposed by law on Subscribers which Grantee is
obligated to collect; and (iii) amounts which must be excluded pursuant to applicable law.
"Nodes" shall mean the cabinet or housing and equipment, power supply, fans, gas
generators, batteries and optical to electrical converters, which is the point where fiber
facilities and coaxial facilities are connected.
"Pay Cable," "Pay Service," "Premium- Service" or "Pay Television" means
programming choices (such as movie channels, pay - per -view, video on demand) offered to
Subscribers on a per - Channel, per - program or per -event basis.
"Pedestal" shall mean an above - ground or below - ground enclosure which houses
active and/or passive electronic equipment used to serve Subscribers.
"PEG Channel" means collectively, the channel capacity dedicated to non - commercial
Public, Education or Government access programming.
"Person" means any corporation, partnership, proprietorship, individual, or
organization authorized to do business in the State of California.
"Plant" means the transmitting medium and related equipment which transmits signals
between the Headend and Subscribers, including Drops.
"Public Channel" or "Public Access Channel' means capacity where members of the
public are the primary designated Programmers, and programming is non - commercial
informational programming.
"Public Right -of -Way" means any public street, public way, public place or rights -of-
way, now laid out or dedicated, and the space on, above or below it, and all extensions
thereof, and additions thereto, under the jurisdiction of Grantor.
"Resident" means any person residing in the Franchise Service Area, or as otherwise
defined by applicable law.
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November 12, 2003
Page 17
"Residential Dwelling Unit" or "Dwelling Unit" means a home, mobile home,
condominium, apartment, cooperative unit, and any other individual dwelling unit.
"Residential Subscriber" means a Subscriber who receives a Service in a Dwelling
Unit.
"Service Area" or "Franchise Service Area" means the entirety of the City of Newport
Beach, or as further defined in the Franchise.
"Service Interruption" means the loss of picture or sound on one or more cable
channels.
"Service Tier" or "Tier" means a category of Cable Service or other Services provided
by a Cable Operator and for which a separate rate is charged by the Cable Operator, other than
per channel or per event programming or legitimate packages of per channel or per event
programming.
"Streets and Public Ways" means the surface of, and the space above and below, any
public street, sidewalk, alley, or other public way or right -of -way of any type whatsoever.
"Subscriber" means any Person that lawfully subscribes to and receives, a Cable
Service provided by Grantee by means of or in connection with its Cable System.
"Tap" means the point of interconnection between that portion of the Cable System
located in the Public Rights -of -Way and a Drop.
"Telecommunications Act" means the Telecommunications Act of 1996.
"Unit" means a discrete place where System Services are used, such as a residence,
apartment, office, store, etc.
Terms Not Defined. Words, terms, or phrases not defined herein shall first have the
meaning as defined in the Cable Act, and then the special meanings or connotations used in
any industry, business, trade, or profession where they commonly carry such special
meanings. If those special meanings are not common, they will have the standard definitions
as set forth in commonly used and accepted dictionaries of the English language.
Grant of Franchise.
b. Authority to Grant Franchises. The Grantor may grant a Franchise to provide Cable
Service to any Person who offers to provide a System pursuant to this Ordinance.
c. Form. A Franchise may, at Grantor's sole option, take the form of an Ordinance,
license, permit, contract, resolution, or any other form elected by Grantor.
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November 12, 2003
Page 18
d. Grants Not Required. Consistent with applicable state and federal law, no
provision of this Ordinance requires the granting of a Franchise when, in the opinion of the
Grantor, it is in the public interest not to do so.
e. Purpose. The purpose of a Franchise is to identify and authorize the operation of a
Cable Communications System by a specific Grantee, and to identify and specify those terms,
conditions, definitions, itemizations, specifications and other particulars of the agreement
between the Grantor and a Grantee. In so doing, a Franchise may clarify, extend, and interpret
the provisions of this Ordinance. Where a Franchise and this Ordinance conflict, both shall be
liberally interpreted to achieve a common meaning or requirement. In the event this is not
possible within reasonable limits, the Franchise shall prevail.
f. Compliance with Law. Neither this Ordinance nor a Franchise granted under it
relieves a Grantee of any requirement of Grantor, or of any Ordinance, rule, regulation, or
specification of Grantor now or hereafter in effect pursuant to Grantor's police power,
including, but not limited to, the obtaining of a business license, and the payment of all permit
and inspection fees required from time to time by the Grantor.
g. Franchise Non - Exclusive. Grantor may, at its option, grant one or more Franchises
to construct, operate, maintain, and reconstruct a System. Said Franchises shall constitute
both a privilege and an obligation to provide the System and Cable Services required by this
Ordinance and the Franchise.
h. Duration. The term of any Franchise, and all rights, privileges, obligations and
restrictions pertaining thereto, shall be specified in the Franchise. The effective date of any
Franchise shall be as specified in the Franchise.
i. Use of Public Streets and Rights- of -Way. For the purposes of operating and
maintaining a System in the franchised Service Area, a Grantee may place and maintain
within the public rights -of -way such property and equipment as conforms to the standards of
the City and as are necessary and appurtenant to the operation of the Cable Communications
System. Prior to construction or alteration of the Plant in public rights -of -way, a Grantee shall
apply for, pay all applicable fees, and receive all necessary permits as required by law.
j. Use of Other Utilities. Any Person who provides a System or Services as defined
herein shall be deemed a Grantee and must obtain a Franchise. If such Grantee uses
distribution channels furnished by any telephone company, other public utility, or any other
entity which are functionally equivalent to those used by a Cable Operator, said Grantee shall
be required to comply with all of the provisions of this Ordinance.
k. Restrictions Against Transfers. Neither the franchise nor any rights or obligations
of the Grantee in or pursuant to the franchise, or the System shall be transferred in part or as a
whole, by assignment, trust, mortgage, lease, sublease, pledge or other hypothecation, and
shall not be sold, transferred, leased, assigned, or disposed of in part or as a whole, either by
forced sale, merger, consolidation, or otherwise, nor shall title thereto, either legal or
Cable Communications Franchise Ordinance
November 12, 2003
Page 19
equitable, or any right or interest therein, pass to or vest in any Person, nor shall a transfer of
Control of the Grantee or the System occur, either by act of the Grantee, by operation of law
or otherwise, in each such case without the prior written consent of the Grantor, which
consent shall not be unreasonably withheld, and which shall be expressed by Resolution and
then only under such conditions as maybe therein prescribed.
1. Effect of Unauthorized Action.
1. The taking of any action described in the foregoing Section (a) hereof
without the prior consent of the Grantor shall: (i) be deemed a material breach of Franchise;
and (ii) among other remedies available to the Grantor, be subject to a liquidated damages
assessment, which assessment shall be up to $5,000.00 a day until the taking of an action
described in the foregoing Section 0) is approved, or if not approved, until the prior
ownership, Control or other status quo ante is restored to a condition satisfactory to the
Grantor. The amount of such assessment shall be determined by the Grantor.
2. If the Grantor denies its consent to any such action and such action has
nevertheless been effected, the Council may revoke the Franchise unless the ownership of the
Franchise and/or System or Control of the Grantee, the System or the Franchise is promptly
restored to its status prior to such unauthorized action or to a status acceptable to the Grantor.
3. The grant or waiver of any one or more of such consents shall not render
unnecessary any subsequent consent or consents, nor shall the grant of any such consent
constitute a waiver of any other rights of the Grantor.
m. Additional Restrictions.
1. The Grantee shall not enter into any management contract or other
arrangement for the management of the System, or sell or otherwise transfer the System, or
any material portion thereof, with or without the Franchise, without the prior written consent
of the Grantor.
2. Any use by the Grantee of its own or an existing MATV, SMATV, MDS,
DBS, or other system in any structure located in the Service Area for the distribution of any
Service which would otherwise be distributed over the System, shall not relieve the Grantee of
its obligation to construct, operate, and maintain the System in said structure pursuant to this
Ordinance and applicable law.
n. Approval Procedure.
1. The Grantee shall promptly notify the Grantor action or proposed action
requiring consent of the Grantor pursuant to this Section. The Grantee shall submit to the
Grantor an original and four copies, unless otherwise directed, of its petition on FCC Form
394, requesting such consent, which petition shall fully describe the action or proposed action
and clearly state the basis on which the petition should be approved. The petition shall also
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November 12, 2003
Page 20
contain all reasonably appropriate documentation. The 120 -day period to review a transfer
request under Section 617 of the Cable Act shall not commence until all of the information
required by FCC Form 394, any applicable State law, the Franchise and this Ordinance is
submitted to the Grantor:
2. Name and address of the proposed transferee and identification of the
ownership and control of the transferee, including: the names and addresses of the ten (10)
largest holders of an ownership interest in the transferee and its cable affiliates and all persons
with twenty (20) percent or more ownership interest in the transferee and its cable system; the
Persons who Control the transferee; all officers and directors of the transferee and its cable
affiliates; and any other Cable System ownership interest or each named Person;
3. A demonstration of the transferee's technical ability to construct, maintain,
upgrade and operate the System, including identification of key personnel.
4. A demonstration of the transferee's legal qualifications to construct,
maintain, upgrade and operate the System;
S. The transferee must show that it, as well as any person which Controls the
transferee, has not, at any time during the ten (10) years preceding the submission of the
petition, been convicted of any act or omission of such character that the transferee cannot be
relied upon to deal truthfully with the Grantor and the Subscribers of the System, or to
substantially comply with its lawful obligations under applicable law;
6. The transferee must certify that no elected official of the Grantor holds an
interest, other than shares in a publicly traded company, in the transferee or an Affiliated
Person of the transferee;
7. Current financial statements showing the financial condition of the System
as of the date of the petition. If Grantee does not maintain financial records at the System
level, then the Grantee may provide such financial statements of the smallest reporting entity
which includes the System;
8. A statement prepared by a certified public accountant or responsible official
of the transferee regarding the transferee's or assignee's financial ability to Construct,
upgrade, maintain and operate the System;
9. A description of the transferee's prior experience in Cable System
ownership, construction and operation and identification of communities in which the
transferee or assignee or entities under common Control with the transferee have a cable
franchise or license.
10. A description of the transferee's plans for meeting any System obligations
under the Franchise, including, but not limited to, any upgrade obligations, upgrade
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November 12, 2003
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completion schedules, channel capacity requirements, technical design requirements, and
performance characteristics;
11. An affidavit or declaration of the transferee or authorized officer certifying
the truth and accuracy of the information in the petition or other written request,
acknowledging the enforceability of the commitments of the petition or other written request,
and certifying that the proposal meets all federal and state law requirements; and
12. A summary of the plans and commitments of the transferee to remedy
specific and known defaults and violations, if any, in the operation of the System under the
Franchise.
13. At any time during the review process, the Grantor reserves the right to
require additional supporting documentation from the Grantee or any other Person involved in
the action or proposed action. The Grantee shall provide all reasonably requested assistance to
the Grantor in connection with any such inquiry and, as appropriate, shall use its best efforts
to secure the cooperation and assistance of all other Persons involved in such action.
o. Conditions. As a condition to the granting of any consent required by this Section
31 the Grantor may require that the transferee execute an agreement, in a form and containing
such reasonable conditions as may be required by the Grantor, specifying that said transferee
assumes and agrees to be bound by all applicable provisions of the Franchise. The execution
of said agreement by the transferee shall in no way relieve the Grantee, or any other transferor
involved in any such action, of its obligations pursuant to the Franchise during its tenure as
the franchisee up to and including the date of execution of such Agreement without the
consent of the Grantor.
p. Reimbursement of Processing and Review Costs. To the extent not prohibited by
applicable law, Grantee shall reimburse Grantor for Grantor's reasonable processing and
review expenses in connection with a transfer of the Franchise or a change in Control of the
Franchise, including without limitation, costs of administrative review, financial, legal, and
technical evaluation of the proposed transferee, costs of consultants (including technical and
legal experts), notice and publication costs, and document preparation expenses. A reasonable
deposit in an amount determined by the City may be required by the City. In addition, prior to
any transfer or change in Control, Grantee shall reimburse Grantor for all of Grantor's
expenses in connection with evaluating or negotiating a renewal of Grantee's franchise,
whether or not said renewal was ever finalized or granted. Grantor may send Grantee an
itemized description of all such charges, and Grantee shall pay such amount within thirty (30)
days after the receipt of such description.
Rights Reserved to the Grantor.
q. Reservation. The grant of the Franchise does not limit the rights of Grantor under
state law with respect to its power of eminent domain.
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r. Non - waiver or Bar. Neither the granting of any Franchise, nor any provisions of
this Ordinance, shall constitute or be construed as a waiver or bar to the exercise of any
governmental right or power by Grantor.
s. Delegation of Powers. Any right or power in, or duty retained by or imposed upon
Grantor, or any commission, officer, employee, department, or board of Grantor, may be
delegated by Grantor to any officer, employee, department or board of Grantor, or to such
other person or entity as Grantor may designate to act on its behalf.
t. Right of Inspection of Construction. The Grantor shall have the right to inspect and
approve all construction, installation, or other physical work performed by Grantee in the
Public Rights -of -Way and on private property consistent with its generally applicable building
codes, so long as said inspection and testing does not unreasonably interfere with Grantee's
operations.
u. Right to Require Removal of Propert y. Consistent with applicable law, upon the
lawful revocation, expiration, or termination of the Franchise, the Grantor shall have the right
to require a Grantee to remove, at Grantee's expense, all portions of its System and any other
property from all streets and public rights -of -way within the Franchise Service Area within a
reasonable period of time.
v. Right of Intervention. The Grantor shall have the right of intervention in any suit,
proceeding or other judicial or administrative proceeding in which the Grantor has any
material interest, and to which a Grantee is party.
w. Place of Inspection. The Grantor shall have the right to inspect Grantee's local
premises, and to request copies of all relevant information that is reasonably necessary for the
exercise of Grantor's regulatory authority, upon reasonable notice at any time during normal
business hours. Any Grantee records kept at another place shall, within twenty (20) days of
Grantor's request, be made available at Grantee's local premises within the County of Orange
for Grantor's inspection and copying. All reports and records required pursuant to this
Ordinance shall be furnished at the sole expense of Grantee, except as otherwise provided in
this Ordinance or the Franchise.
Rights of Subscribers.
X. Discriminatory Practices Prohibited. A Grantee shall not deny Cable Service or
otherwise discriminate against Subscribers or others on the basis of race, color, religion,
national origin, sex, age, handicap, or other protected classes.
y. Tapping and Monitoring. A Grantee shall not tap or monitor, or permit any other
person controlled by Grantee to tap or monitor, any cable, line, signal input device, or
subscriber outlet or receiver, to collect personally identifiable information (as defined in
Section 631 of the Cable Act) concerning any Subscriber whatsoever without the prior written
consent of the Subscriber or a court order therefor; provided, however, that a Grantee may
Cable Communications Franchise Ordinance
November 12, 2003
Page 23
monitor customer service calls for quality control purposes and may conduct system -wide or
individually addressed "sweeps" for the purpose of verifying system integrity, monitoring
signal levels, or checking for unauthorized connections to the Cable System, service levels, or
billing- for -pay services.
z. Data Collection.
1. Except for its own use, or in connection with the provision of Cable
Services or for release of data to the Grantor, the Grantee shall not permit its system to be
used for data collection purposes, nor shall it otherwise collect data which would reveal the
commercial product or other preferences or opinions of an individual Subscriber, members of
their families, or their guests, licensees or employees, unless the Grantee shall have received
the prior written consent of such Subscriber.
2. In any event, the Grantee shall not disclose or permit the release or sale of
data on individual Subscribers or groups thereof, but may disclose or permit the release or sale
of aggregate data only.
3. Disclosure of Subscriber Lists. The Grantee shall not disclose, or sell, or
permit the disclosure or sale of its subscriber list without the prior written consent of each
Subscriber on such list; provided that Grantee may use its subscriber list as necessary for the
construction, marketing, and maintenance of the Grantee's services and facilities authorized
by a Franchise, and the billing of Subscribers for Cable Services; and provided further, that
consistent with applicable law, Grantor may use Grantee's subscriber list for the purpose of
communication with Subscribers in connection with matters relating to the operation,
management, and maintenance of the Cable System and for the audit of financial and other
obligations pursuant to this ordinance, any franchise, or other applicable law.
4. Grantee shall not disclose individual Subscriber preferences, viewing habits,
beliefs, philosophy, creeds, or religious beliefs to any third person, firm, agency,
governmental unit, or investigating agency without court authority or the prior written consent
of the Subscriber.
aa. Terms of Subscriber Consent.
1. Any written consent, if given, shall be limited to a period of time not to
exceed one year, or a term agreed upon by the Grantee and the Subscriber.
2. The Grantee shall not condition the delivery or receipt of Cable Services to
any Subscriber on any such consent
3. A Subscriber may at any time revoke, without penalty or cost, any consent
previously given by delivering to the Grantee in writing a statement of the Subscriber's intent
to so revoke.
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November 12, 2003
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bb. Other Persons Affected. The prohibitions contained in paragraphs (a) through (d),
inclusive, of this Section 5.44.050 apply to Grantee, as well as to all of the following:
1. Officers, directors, employees, agents, and general and limited partners of
the Grantee;
2. Any person or combination of persons owning, holding, or controlling any
corporate stock or other ownership interests in the Grantee;
3. Any affiliated or subsidiary entity owned or controlled by Grantee, or in
which any officer, director, stockholder, general, or limited partner, or person or group of
persons owning, holding or controlling any ownership interest in the Grantee, shall own, hold
or control any corporate stock or other ownership interests; and
4. Any person, firm, or corporation acting or serving in the capacity of a
holding or controlling company of the Grantee.
cc. Subscriber Bill of Rights. Grantee shall provide to all Subscribers, at the time of
initial connection and annually thereafter, a notice in a form previously approved by Grantor
(which approval shall not be unreasonably withheld) describing, in understandable language,
the Subscriber's rights and obligations that are generally provided under the Franchise and
federal law, including a description of how to contact the Grantee and, if necessary, the
Grantor, in the event of an unresolved Subscriber complaint.
dd. Notice to New Subscribers. Before providing Cable Service to any Subscriber,
Grantee shall provide a written notice to the Subscriber containing substantially the following
information:
"Subscriber understands that Company uses public rights -of -way and other
facilities of the City of Newport Beach in providing service and that this
continued use cannot be guaranteed. Subscriber agrees not to make any claims
against the City of Newport Beach or its officers or employees in the event that
such use is denied for any reason, and Company is unable, in its discretion, to
provide service over alternate routes."
Finance.
cc. Payments to the Grantor.
1. As compensation for any Franchise to be granted, and in consideration of
permission to use the Grantor's streets and public rights -of -way for the construction,
operation, maintenance, and reconstruction of a System, the Grantee shall pay to the Grantor
the amounts specified in the Franchise.
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November 12, 2003
Page 25
2. Payments due the Grantor shall be computed quarterly, and shall be paid
within forty -five (45) days after the close of each calendar quarter. The payment shall be
accompanied by a report showing the basis for the computation and such other relevant facts
as may be required by the Grantor to determine the accuracy of the payment. A final annual
reconciliation, and payment if any, shall be delivered to Grantor by Grantee within ninety (90)
days after the end of each calendar year.
3. If any franchise payment or recomputed amount is not made on or before
the dates specified above in subsection 2, Grantee shall pay as additional compensation the
greater of the following:
(a) An interest charge, computed from the applicable due date, at an
annual rate equal to the prevailing commercial prime interest rate in effect upon the due date,
plus one percent (1 %).
(b) A sum of money equal to $5,000 for each month, or part thereof, of
delay, which sum shall also bear interest from the due date at an annual rate equal to the
prevailing commercial prime interest rate in effect upon the due date, plus one percent (1 %).
4. In addition to any late payment made pursuant to subsection 3 above, if a
payment is late by sixty (60) days or more, Grantee shall pay a sum of money equal to five
percent (5 %) of the amount due in order to defray additional expenses and costs incurred by
Grantor as a result of such delinquent payment
5. No acceptance of any payment shall be construed as a release of, or an
accord, or satisfaction of, any claim that the Grantor might have for further or additional sums
payable under the terms of this Ordinance, or for any other performance by Grantee of an
obligation hereunder.
6. Payments of compensation made by a Grantee to the Grantor pursuant to the
provisions of this Ordinance are in addition to, and exclusive of, any and all authorized taxes,
business license fees, and other fees, levies, or assessments now in effect, or subsequently
adopted in accordance with state and federal law.
ff. Security Fund.
1. Except as provided in the Franchise, within thirty (30) days after the
effective date of the Franchise, a Grantee shall deposit into a bank account established by a
Grantee, for the benefit of Grantor, and shall maintain on deposit through the term of the
Franchise, a sum specified in the Franchise as security for the faithful performance by Grantee
of all of the provisions of the Franchise, and compliance with this Ordinance and with all
orders, permits and directions of the Grantor, or any designated representative of the Grantor
having jurisdiction over Grantee's acts or defaults under the Franchise or this Ordinance, and
as security for the payment by a Grantee of any claims, fees, liens, or taxes due the Grantor
which arise by reason of the construction, operation, maintenance or reconstruction of the
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November 12, 2003
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System pursuant to the Franchise or this Ordinance, and to satisfy any actual or liquidated
damages arising out of a Franchise breach.
2. Except as otherwise provided in the Franchise, if a Grantee fails, after
twenty (20) days written notice, to pay to the Grantor any fees that are due and unpaid, or fails
to repay within such twenty (20) days, any damages, costs or expenses which the Grantor is
compelled to pay by reason of any act or default of grantee in connection with its Franchise; or
if Grantee fails to comply with any provision of the Franchise or this Ordinance and the
Grantor determines that such failure was without just cause and, in a manner consistent with
the procedures specified in this Ordinance, Grantor reasonably determines it can be remedied
by a withdrawal from the security fund or is nevertheless subject to liquidated damages, then,
in any such event, the Grantor may immediately withdraw the amount thereof from the
security fund, with interest and any liquidated damages. Upon such withdrawal, the Grantor
shall notify a Grantee of the amount and the date of withdrawal.
3. Within thirty (30) days after notice to Grantee that any amount has been
withdrawn by Grantor from the security fund, a Grantee shall deposit a sum of money
sufficient to restore such security fund to the original amount.
4. Grantee shall be entitled to the return of the security fund, or portion
thereof, with interest, that remains on deposit at the expiration or termination of the Franchise,
once all amounts due to the Grantor have been paid. Grantee shall also retain its right to
challenge any withdrawal from such security fund.
5. The rights reserved to the Grantor with respect to the security fund are in
addition to all other rights of the Grantor, and no action, proceeding or exercise of a right with
respect to such security fund shall affect any other right the Grantor may have.
gg. Faithful Performance Bond. Except as provided in the Franchise, within thirty
(30) days after the effective date of the Franchise, a Grantee shall furnish proof of the posting
of a faithful performance bond in favor of the Grantor, with corporate surety approved by the
Grantor in the sum specified in the Franchise and conditioned that a Grantee shall well and
truly observe, fulfill, and perform each term and condition of the Franchise; provided,
however, that such bond shall not be required after certification by Grantor of the completion
of construction of Grantee's Cable System. The corporate surety must be authorized to issue
such bonds in the State of California, and the bond must be obtained and secured through an
authorized agent in the County of Orange. During the course of construction, the amount of
the bond may from time to time be reduced, as provided in the Franchise. Written evidence of
payment of premiums shall be filed with the Grantor.
hh. Letter of Credit.
1. As required by the Franchise, a Grantee shall post an irrevocable letter of
credit, issued by a bank approved by the Grantor, in the amount specified in the Franchise.
Said letter of credit shall incorporate wording approved by the Grantor enabling it to draw
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November 12, 2003
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from time to time such funds as the Grantor may determine to be necessary to satisfy any
material defaults of Grantee or to make any payments due Grantor under or in connection with
this Ordinance or Grantee's Franchise, upon not more than ten (10) days written notice to the
issuer of the letter of credit with a copy by certified mail to the Grantee. Said letter of credit
shall further provide for sixty (60) days written notice by certified mail from its issuer to
Grantor of any pending expiration or cancellation, and said notice shall without further cause
constitute reason for the Grantor to draw the full sum to be held in its own accounts until such
letter of credit is reestablished in a form satisfactory to Grantor.
2. If Grantor requires such a letter of credit, Grantee shall pay all fees or other
charges required to keep it in force and shall, within thirty (30) days of any draw by Grantor,
restore its face value to the original amount.
3. All provisions herein applicable to bonds or security funds shall also apply
to letters of credit.
Services.
ii. Services to be Provided. A Cable System shall provide, as a minimum, the broad
programming categories specified in the Franchise.
J. Changes in Services. Grantee shall inform Grantor and its Subscribers at least
thirty (30) days in advance of making any changes in rates, programming services or channel
position in the System.
kk. Non - discrimination. Grantee shall not discriminate between or among
Subscribers within one type or class in the availability of services, at either standard or
differential rates according to published rate schedules, except as otherwise authorized by law.
No charges may be made for services except as listed in published schedules which are
available for inspection by anyone at Grantee's office, quoted by Grantee on the telephone,
and displayed or communicated to all potential Subscribers.
11. Prepayment. Grantee may not charge Subscribers for services more than one (1)
month in advance unless an individual Subscriber requests a longer period. Bills may be due
and payable upon mailing but shall not be delinquent, and no late charge penalties shall be
assessed, except as provided in state law. All bills and billing statements shall clearly indicate
the billing period, and the actual due date.
mm. Disconnect for Cause. Grantee may disconnect a Subscriber only for cause,
which shall include, without limitation, the following:
1. Payment delinquency in excess of forty -five (45) days.
2. Willful or negligent damage to or misappropriation of Grantee's property.
service.
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November I Z 2003
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3. Monitoring, tapping, or tampering with Grantee's system, signals, or
4. Threats of violence to Grantee's employees or property.
nn. Reconnection. Grantee shall, upon Subscriber's written request, reconnect service
that has been disconnected for payment delinquency when payment has removed the
delinquency. If authorized by applicable law, a published standard charge may be made for
reconnection. Grantee shall not be required to make more than three (3) reconnections for the
same subscriber if the disconnections involved were caused by payment delinquency within
any previous twenty -four (24) month period. Reconnection for disconnects covered by
Section 5.44.070(e)(2), (3), and (4) shall be at Grantee's sole discretion.
oo. Installations.
1. Grantee shall promptly provide and maintain service as specified in the
Franchise to the residential, commercial, and industrial structures in the Franchise Service
Area, as defined in the Franchise, upon request of the lawful occupant or owner.
2. Where a new Drop is required to provide service, Grantee shall advise each
Subscriber that the Subscriber has the right to require that installation be done over any route
on the Subscriber's property, and in any manner the Subscriber may elect which is technically
feasible and consistent with proper construction practices. If the Subscriber requests
installation other than a standard installation, then the Subscriber may be required to pay the
fee required in subparagraph (h) below related to Non - standard Installations.
3. For purposes of this paragraph, a standard installation shall include
installation of drop cable with fittings up to one hundred and fifty feet (150) feet from the
CATV distribution system measured along the cable from the center line of the street or utility
easement through the house wall or, at the Subscriber's option, through the floor from a house
vent or crawl space directly to the Subscriber's television set with five feet of cable from the
wall or floor entry to the TV set. Also included as part of a standard installation is the
grounding cable, fine tuning of the television set in order to insure the reception of Cable
Service, and the provision by the Grantee of the appropriate literature and information.
4. After Cable Service has been established by activating trunk or distribution
cables for any area, Grantee shall provide Cable Service to any person requesting Cable
Service in that area within nine (9) calendar days from the date of request, provided that the
Grantee is able to secure all access rights necessary to extend service to that potential
Subscriber within that nine (9) day period on reasonable terms and conditions.
pp. Non - Standard Installations. For each non - standard installation, a Grantee may
charge the Subscriber for the cost of material and labor in excess of that required for a
Standard Installation. Grantee shall provide each Subscriber a written estimate of all charges
Cable Communications Franchise Ordinance
November 12, 2003
Page 29
for a non - standard installation prior to installation and obtain Subscriber's written
authorization in advance for all nonstandard installation charges.
qq. Converters /Terminals. At such time as a converter or terminal is required for
Subscribers to have access to all services on its System, Grantee shall make them available to
Subscribers for a fee. Grantee may require each Subscriber who elects to install a converter or
terminal to furnish a security deposit therefor.
1. Each converter or terminal device shall be and remain the property of the
Grantee. Grantee shall be responsible for maintenance and repair of all equipment owned by
Grantee and may replace it as Grantee may from time -to -time elect, except that Subscriber
shall be responsible for loss of or damage to any such device while in the Subscriber's
possession.
2. Upon termination or cancellation of Subscriber's service, Subscriber shall
promptly return Grantee's property to Grantee in the same condition as received, reasonable
wear and tear excepted.
3. Grantee may apply the security deposit against any sum due from
Subscriber for loss of or damage to such converter or terminal exceeding reasonable wear and
tear. In the event that no security deposit has been required, the Grantee may charge the
Subscriber for any such damage exceeding reasonable wear and tear.
4. If Grantee has no claim against the Subscriber's security deposit, Grantee
shall return it, or the balance, to the Subscriber within thirty (30) days of return of the
converter or terminal.
Design and Construction.
rr. System Construction. The System shall be constructed in accordance with the
provisions of the Franchise.
ss. Construction Components and Techniques. Construction components and
techniques shall be in accordance with the Franchise and all applicable law.
tt. Construction Notice. Grantee shall give at least forty -eight (48) hours advance
written notice to all property owners and to the Grantor prior to installing any above - ground or
underground structures upon easements located on private property. Grantee shall be a
member of Underground Service Alert ( "USA ") and comply with its requirements and
procedures.
uu. System Construction.
1. The Grantee shall begin to offer Cable Service and any other service
authorized by the Franchise no later than the date specified in the Franchise.
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November 12, 2003
Page 30
2. A Grantee shall provide a detailed construction plan including an estimated
progress schedule, area construction or reconstruction maps, a System Testing Plan, and
projected dates for offering service to Subscribers.
3. A Grantee shall remove or relocate, at the request of the Grantor and
without expense to the Grantor, any facilities installed, used and maintained under any
franchise if and when made necessary by any lawful change of grade, alignment or width of
any public street, way, alley or place, including the construction of any subway or viaduct by
the Grantor.
4. The City Engineer shall be authorized to direct a Grantee to locate any
conduits and appurtenances as may be reasonably necessary to avoid sewers, waterpipes,
conduits or other structures lawfully in or under the streets; and before the work of
constructing any pipes and appurtenances is commenced, the Grantee shall file with said
Engineer plans showing the location thereof, which shall be subject to the approval of said
Engineer; and all such construction shall be subject to the inspection of said Engineer and
done to his reasonable satisfaction. All street coverings or openings of traps, vaults, and
manholes shall at all times be kept flush with the surface of the streets; provided, however,
that vents for underground traps, vaults and manholes may extend above the surface of the
streets when said vents are located in parkways, between the curb and property lines. All
above - ground facilities including, but not limited to, pedestals, nodes, and boxes shall only be
placed in those locations as reasonably specified by the City Engineer. Installations shall not
interfere with pedestrian and traffic flow and shall be consistent with ADA requirements.
5. If any portion of any street shall be damaged by reason of defects in any of
the conduits and appurtenances maintained or constructed pursuant to a franchise, or by
reason of any other cause arising from the operation or existence of any pipes and
appurtenances constructed or maintained under any other grant, said Grantee shall, at its own
cost and expense, immediately repair any such damage and restore such street, or portion of
street, to as good condition as existed before such defect or other cause of damage occurred,
such work to be done under the direction of the City Engineer, and to his or her satisfaction.
6. A Grantee shall guarantee the integrity, durability and structural integrity of
any street cut repairs necessary for the installation or repair of grantee's facilities for the life of
the street. Grantee shall repair or replace, at no expense to the City, any failed street cut
completed by Grantee or Grantee's subcontractor, as determined by the City Engineer.
vv. Geographical Coverage. A Grantee shall construct the Cable System so that it is
capable of providing Cable Service to every Residential Dwelling Unit and other structures
specified in the Franchise within the Franchise Service Area. A Grantee shall take reasonable
steps to accommodate future annexations to the Franchise Service Area (as defined and
provided by the Franchise), with any exceptions requiring specific Grantor approval. Cable
Service shall be provided to Subscribers in accordance with the schedules specified in the
Franchise.
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November 12, 2003
Page 31
ww. Construction Default. Upon the failure, refusal or neglect of Grantee to cause
any construction, repair, or the terms of any construction permit, or other necessary work to
comply with the terms of the Franchise, thereby creating an adverse impact upon public
safety, Grantor may (but shall not be required to) cause such work to be completed in whole
or in part, and upon so doing shall submit to Grantee an itemized statement of costs. Grantee
shall be given reasonable advance notice of Grantor's intent to exercise this power, and fifteen
(15) days to cure the default. Grantee shall, within thirty (30) days of billing, pay to Grantor
the actual costs incurred.
xx. Vacation or Abandonment. In the event any street, alley, public highway, or
portion thereof used by a Grantee shall be vacated by the Grantor, or the use thereof
discontinued by a Grantee, upon written notice a Grantee shall forthwith remove its facilities
therefrom unless specifically permitted to continue the same. On the removal thereof, Grantee
shall restore, repair or reconstruct the area where such removal has occurred, to such condition
as may be required by the Grantor. In the event of any failure, neglect or refusal of a Grantee,
after thirty (30) days' notice by the Grantor, to do such work, Grantor may cause it to be done,
and Grantee shall, within thirty (30) days of billing, pay to Grantor the actual costs incurred.
yy. Abandonment in Place. Grantor may, upon written application by Grantee,
approve the abandonment of any property in place by Grantee, under such terms and
conditions as Grantor may approve. Upon Grantor - approved abandonment of any property in
place, Grantee shall cause to be executed, acknowledged, and delivered to Grantor such
instruments as Grantor shall prescribe and approve, transferring and conveying the ownership
of such property to Grantor.
zz. Removal of System Facilities. In the event that Grantee's Plant is deactivated for
a continuous period of thirty (30) days, without prior written notice to and approval by
Grantor, then Grantee shall, at Grantor's option and demand, and at the sole expense of
Grantee, promptly remove from any streets or other areas all property of Grantee. Grantee
shall promptly restore the streets or other areas from which such property has been removed to
its condition existing prior to Grantee's use thereof; provided that Grantee shall not be
required to remove conduit from underground, where Grantor has determined that no damage
to the surface of any structures will result from such nonremoval.
aaa. Movement of Facilities. In the event it is necessary, at Grantor's discretion, to
temporarily move or remove any of a Grantee's property for a public purpose, Grantee, upon
reasonable notice, shall move, at the expense of Grantee, its property as may be required to
facilitate such public purpose. No such movement shall be deemed a taking of Grantee's
property. Nothing herein shall limit the right of Grantee to seek reimbursement from any
party other than Grantor.
bbb. Underaounding of Cable. Cables shall be installed underground at Grantee's
cost in areas where other like facilities are installed underground. Previously installed aerial
cable shall be installed underground at Grantee's pro rata cost in concert with other utilities,
when those other utilities convert from aerial to underground construction provided that
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November 12, 2003
Page 32
Grantee is given reasonable notice and access to the underground facilities of such other
utilities or other users of the poles at the time such utilities are placed underground.
ccc. Facility Agreements. No Franchise shall relieve Grantee of any obligations
involved in obtaining pole or conduit space from any department of Grantor, any utility
company, or from others maintaining utilities in Grantor's streets.
ddd. Repair of Streets and Public Ways. Grantee shall not cut, trench, or excavate any
street which has been constructed or overlaid for five (5) years or slurry- sealed for two (2)
years from said construction, overlay, or slurry -seal, as the case may be, without the advance
written permission of the City Engineer. The City Engineer's consent may be conditioned,
among other things, upon a requirement that Grantee overlay or slurry -seal, as determined by
the City Engineer, the entire width of the affected street for the entire length of the project.
Any and all streets and public ways, and improvements located within such streets and public
ways, disturbed or damaged by a Grantee or its contractors during the construction, operation,
maintenance, or reconstruction of the System, shall be restored at Grantee's expense, and
within the reasonable time frame and limits specified by Grantor, to their original condition
unless otherwise authorized in writing by Grantor. Grantee may be required subsequent to
completion of construction, from time to time as determined by the City Engineer, to overlay
or slurry -seal the affected street in order to maintain the structural integrity and/or aesthetics
of the street. All decorative sidewalks (pavers, tiles, etc.) shall be replaced in like kind
pursuant to the written direction of the City Engineer.
eee. Erection of Poles Prohibited. Grantee shall not erect any pole on or along any
street or public way. If additional poles in an existing aerial route are required, Grantee shall
negotiate with the public utility for their installation. Any such installation shall require the
advance written approval of the Grantor. Subject to applicable federal and state law, a
Grantee shall negotiate the lease of pole space and facilities from the existing pole owners for
all aerial construction, under mutually acceptable terms and conditions.
fff. Reservation of Street Rights. Nothing in a Franchise shall prevent the Grantor
from constructing, repairing, or altering any public work. All such work shall be done, insofar
as practicable, in such manner as not to unnecessarily obstruct, injure or prevent the free use
and operation of any Property of Grantee. However, if any Property of Grantee shall interfere
with the construction, maintenance, or repair of any public improvement, that property shall
be removed or replaced in such manner as directed by Grantor so that the same shall not
interfere with the public work, and such removal or replacement shall be at the expense of a
Grantee.
ggg. No Interference.
Grantee shall not place equipment where it will interfere with existing and future uses
of the streets, public right -of -way, or public property, with the rights of private property
owners, with gas, electric, or telephone fixtures, with water hydrants or mains, with
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November 12, 2003
Page 33
wastewater stations, with any traffic control system, or any other service or facility that
benefits the Grantor's or its residents' health, safety or welfare.
hhh. Protection of Streets.
Grantee, at its own expense and in a manner as directed by the City Engineer, shall
protect streets and public rights -of -ways, easements, and support or temporarily disconnect or
relocate at its sole cost in the same street or other street or public right -of -way, any property of
such Grantee when necessitated by reason of:
1. Traffic conditions;
2. Public safety;
3. Temporary or permanent street closing;
4. Street construction or resurfacing;
5. A change or establishment of street grade; or
6. Installation of sewers, drains, water pipes, storm drains, lift stations, force
mains, power or signal lines, and any traffic control system.
iii. Marking of Facilities.
It shall be the responsibility of a Grantee to locate and mark or otherwise visibly
indicate and alert others to the location of its underground cable before employees, agents, of
independent contractors of any entity perform work in the marked -off area. A Grantee shall
participate in and adhere to the practices of Underground Services Alert ( "USA ") and provide
at least forty -eight (48) hours prior notice to USA prior to any excavation.
jjj. Construction Standards.
1. All construction, installation, maintenance and repair shall not substantially
affect the appearance or the integrity of the structure, and shall not be installed on private
property without the property owner's permission subject to Section 621 of the Cable Act.
2. All underground drops shall follow (to the greatest extent possible) property
lines, and cross property only at right angles unless otherwise permitted by the property
owner, or required due to the physical characteristics of the subsurface, or required under
applicable law. The Grantor may, either by way of a generally applicable resolution or
through the imposition of routing conditions in any Franchise determine the routing or
placement of cable, conduit, Nodes, pedestals, power supplies, vaults, and other equipment
relating to the System.
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November 12, 2003
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3. All construction shall be accomplished between the hours specified by the
Grantor in the approved permit or ordinances.
kkk. Payment of Fees.
1. Grantee and any and all subcontractors thereof shall obtain, at its own
expense, all permits and licenses required by local law, rule, regulation or applicable
ordinance.
2. As a condition of obtaining all necessary permits and licenses, the Grantee
shall pay all applicable permit fees and, in addition, all of the Grantor's direct labor and
supervisory costs, including customary and reasonable overhead (the "Labor Payment "). The
City Council may, from time to time by resolution, establish the amount of said permit fees.
To the extent not inconsistent with applicable law, the permit fees shall be sufficient to
reimburse the Grantor for its costs, including the costs of staff, independent consultants, and
related overhead, to review the proposed project, processing permits, plan check, inspecting
the project including the costs of an outside inspector and, where applicable, the costs of an
outside soils engineer or compaction testing expert, and the costs of any required testing to
ensure that the construction adheres to standards of this Ordinance, any Franchise, any permit,
and any other requirement of the Grantor.
3. Grantor may hire contractors, at Grantee's sole expense, to carry out any
required work under this Ordinance. Grantee shall make payment within thirty (30) days of
billing from the Grantor. Grantee shall be responsible for any damage caused by the
construction including, but not limited to, damage to the public right -of -way, private property,
streets, existing utilities, curbs, gutters and sidewalks. Grantee shall pay the Grantor any costs
incurred as a result of such damages including repairs made by the Grantor except for costs
incurred as a result of the Grantor's sole negligence or its employees' and agents' sole
negligence. Grantee shall complete restoration of or repairs to any damage caused by its
construction within thirty (30) days from the date of written notice from the Grantor.
4. In lieu of the inspection portion of the Labor Payment or permit fees
described above, at the Grantor's sole option, the Grantor may require Grantee at Grantee's
sole expense, to hire a consultant, who is acceptable to and under the supervision of the
Grantor ( "Consultant "), to inspect the installation of the facilities on behalf of the Grantor, or
provide other services as mutually agreed to by the parties.
111. Progress of the Construction.
Prior to the underground construction of any of the facilities or the installation of any
of the above - ground facilities, unless otherwise agreed to, Grantee shall furnish detailed plans
of the proposed construction and changes thereto to the Grantor. The proposed above - ground
sites must be approved by the Grantor prior to construction of the underground plant.
Depending on health and safety issues, and input from residents, the Grantor, at its sole
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November 12, 2003
Page 35
discretion, may require proposed above - ground sites to be relocated by Grantee. Grantee shall
comply with the Grantor's standard construction requirements as they exist from time to time.
mmm. Construction Notification.
1. Construction Plan. Unless otherwise governed by Grantor's construction
regulations and Ordinances, at least ninety (90) days prior to any construction, and from time
to time thereafter, Grantee shall file with the City Manager or other designated employees of
the City, a general construction plan describing in detail the Facilities construction plans,
areas to be served, and an estimated time schedule for such construction ( "Construction
Plan "). Grantee reserves the right to modify or change its Construction Plans at any time in its
sole discretion, provided Grantee provides written notice to the Grantor. Any modifications to
construction plans must be reviewed and approved by the Grantor before modifications can be
implemented by Grantee.
2. Notice to the Grantor. The Grantor shall have thirty (30) days following
receipt of the Construction Plan, or changes thereto, to approve or disapprove the
Construction Plan.
3. Notice to Other Providers. Grantee shall provide the Grantor with general
engineering base maps identifying existing underground and aerial utility routes, streets,
parcels, poles, and construction needs including points of connections for existing residences,
potential trench routes, and potential locations for facilities at least ninety (90) days in
advance of any underground construction, unless otherwise agreed to, which may be reviewed
in advance by any interested party for the purpose of reducing the impact on the Grantor's
infrastructure and for the public's convenience and shall be approved or disapproved by the
Grantor within sixty (60) days of receipt.
4. Traffic Control Plans. Grantee shall furnish detailed traffic control plans,
which shall include site - specific hours of construction, to the City Engineer no later than thirty
(30) days prior to the commencement of any construction activities which may affect or
impact traffic (the "Traffic Control Plan"). The City Engineer shall provide (if any)
comments to Grantee within ten (10) business days of receipt. The City Engineer may specify
and limit hours of construction in order to avoid traffic congestion during peak periods. No
construction related activities may be conducted in the Public Right -of -Way without an
approved traffic control plan.
5. Telephone Contact. During construction, Grantee shall provide the Grantor
a telephone contact number, and staff it during regular business hours, to enable the Grantor to
report any concerns regarding construction of the Facilities. After business hours such calls
will be routed to an on -call supervisor. In the event that the Grantor reports any concerns to
Grantee, Grantee shall respond in a timely manner. Grantee shall correct within two (2)
business days any adverse impact to the Grantor's use or operations or the use or operations of
a third party caused by Grantee's construction activities in the Public Right -of -Way at no cost
to the Grantor.
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November 12, 2003
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6. Daily Notice. Every working day during construction, Grantee shall notify
the designated Grantor staff member of the location of that next day's construction activities.
The number of concurrent construction locations may be limited by the Grantor.
7. Proiect Overview.
No later than one hundred and ninety (90) days prior to commencement of
construction, Grantee shall file with the City Manager or other designated employee of the
Grantor a Project Overview which shall contain an assessment of the operation of the
facilities, including without limitation, a noise study prepared by a licensed engineer approved
by the Grantor documenting noise generated from the Facilities.
Once the project has been satisfactorily defined by Grantee as determined by
the Grantor, the Grantor will conduct an initial study to determine the appropriate level of
environmental review. Grantee will submit the final engineering plans to the Grantor for
review and approval prior to the issuance of any permits.
8. Public Communication Plans.
(a) Grantee agrees to develop a public communication plan
( "Communication Plan ") and submit it to the Grantor for the Grantor's review at least ninety
(90) days prior to commencement of construction. The Grantor shall approve or disapprove
the Communication Plan within thirty (30) business days of its receipt. The Communication
Plan shall include the following:
(1) A written mailed or hand delivered notification of property
owners adjacent to all Facilities not less than thirty (30) days prior to the installation
indicating the proposed location, a photograph of all above - ground visible equipment from
which their size must be apparent, and a detailed description of the equipment included within
the node including: the electronic components, natural gas generator, electrical fans, and the
anticipated noise levels during winter and summer months and emergency backup operations.
Grantee will provide its non -toll telephone number and a telephone number of the Grantor that
may be called if the property owner is concerned about the installation.
(2) The hanging of door hangers on all residences in the
construction area at least seven (7) days prior to immediate construction activity.
(b) Grantee agrees to participate in any public hearings or meetings
scheduled by the Grantor and will be prepared to answer questions concerning Grantee's
proposed construction of the above- ground visible equipment. Grantee shall have available at
such meetings visual aids as appropriate such as slides, maps and diagrams. All above - ground
equipment locations in the City must be approved by the Grantor prior to construction of the
underground cable plant. Depending upon health and safety issues, and input from residents,
the Grantor, at its sole discretion, may require proposed above -ground visible equipment sites
be relocated by Grantee.
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November 12, 2003
Page 37
9. Maps and Plans.
Grantee shall maintain accurate maps and improvement plans of the Facilities,
in a manner consistent with telecommunications industry standards and which can be
integrated into the Grantor's Geographic Information System ( "GIS "). Grantee shall furnish
to the Grantor two complete sets of as -built construction drawings within sixty (60) days of
completion of the construction of the Facilities. Maps and improvement drawings shall be
furnished to the Grantor and other parties interested in performing work within the Public
Right -of -Way, upon request, at no cost to the Grantor. Grantee shall pothole its Facilities, at
its expense, within fifteen (15) days of receipt of a written request from the Grantor unless
Grantee can certify, with an associated indemnity approved by the City Attorney, the exact
location and depth of the Facilities at the location where potholing is requested.
10. Certification of Completed Facilities.
Grantor shall provide Grantee written notice of any street improvement project
within Grantor's Service Area. Upon receipt of said written notice unless, Grantee shall
certify in writing to Grantor that its Facilities located in the street improvement project are
complete and require no further construction for a period of three (3) years, other than
maintenance , Grantee shall apply for all necessary permits and authorizations so that any
necessary facilities will be installed and completed prior to completion of the street
improvement project.
Operations And Maintenance.
mm. Customer Service.
1. A Grantee shall maintain an office in the Service Area, or at such other
location as is approved by the Grantor in writing. That office must be open during all usual
business hours, but in no case less than forty eight (48) hours per week, including during at
least one weekend day per week. Grantor shall have a publicly listed, non- long - distance-
charge telephone number that is in operation to receive Subscriber Complaints and requests on
a 24 -hour basis. Current information shall be maintained of all Complaints and their
disposition, and a summary thereof shall be submitted to Grantor.
2. The Grantee shall respond to requests as follows: (i) within eight (8) hours
after receipt of a request for repairs relating to a Cable Service Interruption affecting at least
ten (10) percent of the Subscribers of the System; (ii) within twenty-four (24) hours after
receipt of requests for service related to all other Cable Service Interruptions; (iii) and within
forty -eight (48) hours for all other complaints and requests for repair. All Cable System
related problems shall be resolved within five (5) business days unless technically infeasible.
No charge shall be made to a Subscriber for such service or repairs, except that Grantee may
charge for service calls not related to its Cable System, or that are caused by the Subscriber or
members of its household, or the Subscriber's agents or guests.
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November 12, 2003
Page 38
3. The Grantee shall provide a telephone service system to receive all
construction and service complaints. A sufficient number of customer service representatives
shall be provided so that callers are not required to wait more than thirty (30) seconds before
being connected to a customer service representative ninety percent (90 %) of the time,
measured quarterly, or to receive busy signals more than three (3) percent of the time,
measured quarterly. The telephone number of the local office shall be listed in the telephone
directory serving the City of Newport Beach. The telephone service system shall accept
complaints twenty-four (24) hours a day, seven (7) days a week. The telephone service
system shall be capable of generating reports relating to answer times, response times, hold
times, and abandoned calls.
4. Customer service personnel shall identify themselves immediately.
5. Customers shall have the right to speak with a supervisor, and if none is
available, a supervisor shall return the customer's call within one working day.
6. All officers, agents, or employees of the Grantee, including its contractors
or subcontractors, who come into contact with members of the public shall wear on their outer
clothing a photo - identification card in a form reasonably acceptable to Grantor. Grantee shall
account for all identification cards at all times. Every vehicle of Grantee, or its major
subcontractors, shall be clearly identifiable as working for Grantee.
000. Biennial Audit of Performance.
1. Grantor may require that performance audits of the System be conducted
every two (2) years by an independent technical consultant selected by Grantor to verify that
the System complies with all technical standards and other specifications of the Franchise.
2. Upon completion of a performance audit, the Grantor and Grantee shall
meet to review the performance of the Cable System. The reports required by this Ordinance
regarding Subscriber complaints, the records of performance audits and tests, and the opinion
survey report shall be utilized as the basis for review. In addition, any Subscriber may submit
complaints prior to or during the review meetings, either orally or in writing, and these shall
also be considered.
3. Within thirty (30) days after the conclusion of the System performance
review meetings, Grantor shall issue findings with respect to the adequacy of System
performance and quality of service. If areas of non - compliance are found, Grantor may direct
Grantee to correct the non - compliance within such period of time as Grantor determines is
reasonable.
4. Participation by the Grantor and the Grantee in this process shall not waive
any rights they may possess under applicable federal or state law.
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November 12, 2003
Page 39
5. In addition to the Biennial Audit described above, Grantor may conduct an
annual audit of the same or lesser magnitude, at its sole expense, when and if determined
necessary or appropriate by Grantor.
ppp. System Technical Data. Grantee shall provide Grantor with a computer disk or
other data storage device requested by Grantor, in format approved by Grantor, which details
and documents all of Grantee's equipment and facilities and their geographic location in the
City. Such computer disk or other device shall be updated at least annually and whenever
there have been significant changes in the location of Grantee's equipment and facilities. In
addition, Grantee shall maintain in its local office a complete and up -to -date set of as -built
system maps upon completion of construction or reconstruction, equipment specification and
maintenance publications, and signal level diagrams for each active piece of electronic
equipment in the system. As -built drawings shall show all lines and installed equipment, and
tap values and spigots. The scale of maps and drawings shall be sufficient to show the
required details in easily readable form and size. Technical data at the local office shall also
include approved pole applications, details and documentation of satellite and microwave
equipment, mobile radio units, heavy construction vehicles and equipment, and video and
audio equipment normally used in the operation of the system. If Grantor requires use of
technical data in its own offices, it may make copies of any items.
qqq. Availability of Technical Data. All technical data reasonably necessary to
demonstrate a Grantee's compliance with FCC regulations, this Ordinance, and the Franchise
shall be available for Grantor's inspection during normal business hours upon two (2)
business days notice. In the event of System failure or other operating emergency, the
technical data will be made available at any time, so long as the provision of said data does
not unreasonably interfere with Grantee's operations.
rrr. Emergency Repair Capability. It shall be Grantee's responsibility to assure that its
personnel, qualified to make repairs, are available at all reasonable times and that they are
supplied with keys, equipment location instructions, and technical information necessary to
begin repairs upon notification of the need to maintain or restore continuous service to the
System.
sss. Refund. When a Subscriber voluntarily discontinues service, Grantee shall
refund, within thirty (30) days of the discontinuance of service, the unused portion of any
advance payments after deducting any charges currently due through the date of such
discontinuance. Unused payment portions shall be the percentage of time for which
Subscriber has paid for service and will not receive it because of the Subscriber's
discontinuation of service.
ttt. Disabled Access.
1. The Grantee shall provide maximum practicable availability of the Services
and facilities of the System to disabled persons. At a minimum, the Grantee shall provide a
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November 12, 2003
Page 40
single remote control device for each television set connected to the Service to those
Subscribers who are paraplegic or quadriplegic.
2. Upon initiation of Service in the Grantee, the Grantee shall submit to the
Grantee a plan and/or report describing the equipment, facilities, and ongoing services the
Grantee intends to or does make available to disabled persons. Such information regarding the
facilities, equipment, and ongoing services for disabled persons shall be kept updated and the
Grantee shall promptly submit to the Grantee Manager notification of any deletions or
additions to such information.
3. The Grantee shall provide within forty-five (45) days of a request from a
Subscriber, for rental or purchase, equipment which facilitates the reception of all cable
channels by hearing- impaired Subscribers in accordance with the FCC's regulations regarding
Closed Captioning. The Grantee shall also provide TDD (or equivalent) equipment at the
Grantee office that will allow such Subscribers to contact the Grantee for any reason related to
the System.
uuu. Employee Identification. All personnel of the Grantee contacting Subscribers or
potential Subscribers outside the office of the Grantee must be clearly identified as associated
with the Grantee.
vvv. Installations.
1. All installations will include appropriate grounding, adjustment of the
television set in order to receive Service, and the provision of required Subscriber information
and literature to instruct the Subscriber in the utilization of the Services.
2. The Grantee shall offer Subscribers the option to receive an AB switch at
the time of initial Service installation for no additional installation cost, and shall provide
Subscribers with written information on how to use such a switch.
3. Upon Subscriber request, the Grantee shall provide an AB switch after the
initial installation of Service. If the Subscriber requests installation of such a switch, the
Grantee may charge reasonable fees for such installation which fee shall not exceed the
maximum rate permitted by applicable law.
4. When applicable, if the Grantee cannot perform standard installations
within nine (9) calendar days of request by a Subscriber (provided that the schedule or
preferences of the person requesting installation have not been responsible for the delay), the
Subscriber may request and is entitled to receive a credit equal to one month of Basic Service.
If the Grantee fails to provide this credit and the request was made by the Subscriber within
sixty (60) days of the installation request, the Grantee may direct the Grantee to issue the
credit. Repeated failure to perform standard installations within the nine (9) calendar days or
to provide the credit for late installations shall be grounds for Franchise revocation or other
enforcement actions.
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November 12, 2003
Page 41
Service Interruptions And Other Service Problems
1. The Grantee shall render efficient service, make repairs promptly, and
interrupt Service only if unavoidably necessary and for the shortest period possible. Such
interruptions, insofar as possible, shall be preceded by reasonable notice to each affected
person and shall occur during periods of minimum System use.
2. The Grantee shall promptly notify the Grantor of any significant "Service
Interruption" in the operation of the System. For the purposes of this Section, a "significant
Service Interruption in the operation of the System" shall mean any interruption of Cable
Services of a duration of at least four (4) continuous hours to at least ten percent (10 %) of the
Subscribers in the area or areas of the Grantee served by the Grantee.
3. The Grantee shall exercise its best efforts to limit any Service Interruption
for the purpose of maintaining, repairing, or reconstruction of the System to periods of
minimum use. Except in an emergency or other situation necessitating a more expedited or
alternative notification procedure, the Grantee may schedule a Service Interruption for a
period of more than four (4) hours during any twenty -four (24) hour period only after the
Grantee and each affected Subscriber in the Grantee have been given twenty -four (24) hours
prior notice of the proposed interruption.
4. Technicians employed by the Grantee and capable of performing Service -
related emergency repairs and maintenance must be available twenty -four (24) hours a day,
every day, including weekends and holidays.
5. The Grantee must acknowledge complaints from Subscribers within twenty -
four (24) hours (excluding weekends and holidays except in the case of Service Interruptions).
6. Excluding conditions beyond the control of the Grantee, the Grantee will
begin working on Service Interruptions promptly and in no event later than twenty -four (24)
hours after the interruption becomes known (including weekends and holidays). "Working on"
constitutes taking positive steps toward rectifying the problem not merely acknowledging the
problem.
7. The Grantee must begin actions to correct Cable Service problems other
than Service Interruptions the next business day after notification of the Cable Service
problem.
8. Verification of Subscriber complaints, including but not limited to billing
complaints, and resolution must occur within forty -eight (48) hours (provided that the
schedule or preferences of the person requesting installation have not been responsible for the
delay); and in any event, resolution must occur within one (1) week. Those matters requiring
additional maintenance, repair, or technical adjustments that are documentable as
necessitating in excess of one (1) week to reasonably complete, must be finally resolved
within thirty (30) days of the initial complaint. The Grantee Manager's office may require
Cable Communications Franchise Ordinance
November 12, 2003
Page 42
reasonable documentation to be provided by the Grantee to substantiate the request for
additional time to resolve a complaint.
9. The Grantee shall provide an automatic credit to all Subscribers when there
is an Outage of all channels for a period of twenty-four (24) consecutive hours or more which
affects an entire service area, franchise area served by the Grantee, regardless of the cause of
the Outage. The credit for such an Outage shall equal, at a minimum, the value of one - thirtieth
(1/30) of each Subscriber's monthly bill for the first twenty-four (24) consecutive hour period
and prorated for each additional four (4) hour period or portion thereof that the Outage
continues.
10. The Grantee shall provide an automatic credit to all affected Subscribers
when there is an Outage of any Premium Service for a period of twenty-four (24) consecutive
hours or more which affects an entire franchise area, or other discrete area of the Grantee
served by the Grantee, regardless of the cause of the Outage. The credit shall equal, at a
minimum, the value of one - thirtieth (1/30) of each Subscriber's monthly bill for that Premium
Service for the first twenty-four (24) hour consecutive hour period and prorated for each
additional four (4) hour period or portion thereof that the Outage continues.
11. Upon request of the Subscriber, the Grantee shall provide a credit to a
Subscriber whenever an Outage or Outages of four or more hours in a twenty-four (24) hour
period has affected any of the non - premium channels received by a Subscriber as part of their
Service. The credit shall equal the value of one - thirtieth (1/30) of each Subscriber's monthly
bill for Outages of four (4) hours or greater duration occurring in a twenty-four (24) hour
period. In the event that a premium channel is affected by the Outage, the credit shall equal
the value of one - thirtieth (1/30) the Subscriber's monthly premium rate for each Outage of
four (4) hours or greater duration occurring in a twenty-four (24) hour period.
12. Repeated failure to provide the proper credit for Outages shall be grounds
for Franchise revocation or other enforcement actions.
xxx. Service Aonointments.
1. The "appointment window" alternatives for installations, service calls for
Cable Service, and other installation activities will be either a specific time or, at maximum, a
four -hour time block during normal business hours. (The Grantee may schedule services calls
for Cable Service and other installation activities outside or normal business hours for the
express convenience of the Subscriber).
2. If the Grantee does not arrive for appointments for installations or service
calls within a designated 4 -hour time frame agreed to by the Subscriber, the Subscriber may
request and is entitled to receive a credit equal to one month of Basic Service. If the Grantee
fails to provide such credit, and the request was made by the Subscriber within 60 days of the
missed appointment, the Grantee may direct the Grantee to issue the credit. Repeated failure
to provide the credit shall be grounds for Franchise revocation.
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November 12, 2003
Page 43
3. The Grantee may not cancel an appointment with a Subscriber after the
close of business on the business day prior to the scheduled appointment.
4. If the Grantee's representative is running late for an appointment with a
Subscriber and will not be able to keep the appointment as scheduled, the Grantee will
document a diligent effort to contact the Subscriber directly. If, however, the Subscriber is
unavailable at the time the contact attempt is made, the Grantee will attempt a second
documented contact at least one more time during the previously agreed upon appointment
window. The appointment will be rescheduled, as necessary, at a time which is convenient to
the Subscriber. Contacting the Subscriber will not necessarily excuse a missed appointment.
In the event that it is necessary for Grantee to contact the Subscriber regarding the scheduled
appointment and Subscriber is not available, Grantee will use its best efforts to provide the
Subscriber with a phone number to contact Grantee.
yyy. Notices & Customer Communications.
1. The company shall send annually, written notice to all Subscribers
informing them that any complaints or inquiries not satisfactorily handled by the Grantee may
be referred to the Grantee Manager. Such notification shall be either:
(a) A separate document that may be included with a billing statement
or as part of the Grantee's annual notice; or
(b) Included on the portion of the monthly bill that is to be retained by
the Subscriber.
The Grantee's telephone number for Service and the telephone number for the
Grantee shall be contained in the notice. This notice shall also fully describe the Grantee's
telephone hours and, when applicable, the lobby hours and shall include the telephone
number(s) available to Subscribers after the Grantee's normal business hours through which
Subscribers can obtain, at a minimum, emergency referral information. No promotional
material may be included on the separate document or the portion of the bill containing this
notice.
2. For informational purposes and for the Grantee to ensure nondiscrimination,
the Grantee shall provide the Grantor and Subscribers a complete schedule of all current
programming services, excluding pay - per -view, rates and charges and promotional offers.
3. The Grantee shall notify Subscribers of any pricing changes or additional
charges and/or any changes in programming services as soon as possible through
announcements on the System and in writing. Notice must be given to Subscribers a minimum
of thirty (30) days in advance of such changes if the change is within the control of the
Grantee.
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November 12, 2003
Page 44
4. The Grantee shall notify all Subscribers prior to making available any
channel(s) full or part-time without charge if programming rated NC -17, R, X, or the
equivalents thereof will be available for viewing. This notification shall include the rating(s)
of the programming to be made available for viewing and the right of the Subscriber to have
the Grantee block the programming. The Grantee shall provide, by sale or lease, a device for
blocking this programming.
5. The Grantee shall provide written information to Subscribers on each of the
following areas at the time of installation of Cable Service, at least annually to all Subscribers,
at any time upon request, and at least thirty (30) days prior to making significant changes in
the information required by this Section:
(a) products and services offered;
(b) prices and options for programming services and conditions of
subscription to programming and other services and facilities;
(c) installation and maintenance policies including, when applicable,
information regarding the Subscriber's home wiring rights and information describing
ownership of internal wiring during the period Service is provided;
(d) of programming carried on the System;
(e) billing and complaint procedures, including the name, address and
telephone number of the Grantee Manager's cable television division;
(f) the availability of the signal control device required by Section
624(d)(2) of the Cable Act and AB switches;
(g) the procedures by which the Subscriber will be notified of changes
in fees, charges, deposits, or associated terms and conditions for any Service;
(h) the Grantee's practices and procedures for protecting against
invasions of privacy as required by Section 631 of the Cable Act, and Section 637.5 of the
California Penal Code;
(i) the address and telephone number of the Grantee's office to which
complaints may be reported; and
0) when applicable, the Grantee's Community Unit Identifier as
specified by the FCC.
6. Notices of changes in rates shall indicate the new rate inclusive of all fees
and/or other fees and the amount the rate has increased or decreased from the current rate.
Specific words such as "increase" or "decrease" must be used to describe the changes (as
opposed to less specific terms, such as "adjustment").
Cable Communications Franchise Ordinance
November 12, 2003
Page 45
7. Notices of changes of programming services and/or channel locations shall
include a description of the new programming service, the specific Dial Location, and the
hours of operation of that programming service. In addition, should the Dial Location, hours
of operation, or existence of other programming services be affected by the introduction of a
new service, such information must also be included in the notice.
8. In order that Subscribers are fully apprised of the charges they may incur,
the Grantee shall advertise rates that include all costs and fees.
9. Every notice of termination of Service shall include all of the following
information:
(a) the name and address of the Subscriber whose account is
delinquent.
(b) the amount of the delinquency.
(c) the date by which payment is required in order to avoid termination
of Service.
(d) the telephone number of a representative of the Grantee who can
provide additional information and handle complaints or initiate an investigation concerning
the Service and charges in question.
10. For informational purposes only, a listing of the Grantee closings or
holidays (e.g. "no business" days) will be provided to the Grantee Manager annually, by no
later than July 1 and by no later than every anniversary thereafter.
zzz. Disconnections/Denial Of Service.
1. The Grantee shall not terminate residential Service for nonpayment of a
delinquent account unless the Grantee furnishes a notice of the delinquency and impending
termination at least fifteen (15) day prior to the proposed termination. The notice shall be
mailed, postage prepaid, to the Subscriber to whom the Service is billed. This notice shall not
be mailed until the sixteenth (16th) day after the date the bill for Services was mailed to the
Subscriber. The notice of delinquency and impending termination may be part of a billing
statement.
2. The Grantee shall not assess a late fee any earlier than the twenty- second
(22nd) day after the bill for Services has been mailed.
3. The Grantee shall only terminate Cable Service on days when the
Subscriber can reach a representative of the Grantee either in person or by telephone. Cable
Service terminated without good cause must be restored without charge for the Cable Service
restoration. Good cause includes, but is not limited to, failure to pay, payment by check for
Cable Communications Franchise Ordinance
November 12, 2003
Page 46
which there are insufficient funds, theft of Service, abuse of equipment or System personnel,
or other similar Subscriber actions.
4. The Grantee shall furnish and maintain Cable Services to each person who
makes a bona fide request to receive any programming service. Nothing in this Ordinance
shall limit the right of the Grantee to deny Cable Service to any household or individual which
has a negative credit or service history with the Grantee, which may include non - payment of
bills or theft or damage to the Grantee's equipment, or who has threatened or assaulted
employees of the Grantee in the course of their employment.
aaaa. Deposits, Refunds, And Credits.
1. The Grantee may require refundable deposits in circumstances where such
deposits are necessary to protect equipment or to ensure payment where there is reasonable
evidence of a risk of nonpayment, provided that the Grantee shall be required to pay simple
interest at a rate of one -half percent (1/2 %) per month (6% per year). Such interest shall be
accrued and payable upon termination of Service. Upon termination of Service for any reason,
Subscribers will be entitled to receive a refund or credit against amounts owed the Grantee
equal to the deposit plus accumulated interest.
2. Refund checks will be issued promptly following the resolution of the event
giving rise to the refund; and by the earlier of either:
(a) the Subscriber's next billing cycle; or
(b) forty -five (45) days.
3. If the Grantee does not mail a check for a refund (including applicable
interest) to any Subscriber disconnecting Service with an outstanding credit within 45 days of
the date Cable Service is ended, and the Subscriber has returned all Grantee owned
equipment, the Subscriber may request and is entitled to receive a $4.75 payment, in addition
to the total refund (and applicable interest) due. If the Grantee fails to provide the $4.75
payment and the request was made by the Subscriber within 60 days after failure to receive the
refund, the Grantor may direct the Grantee to provide the $4.75 payment as well as any
outstanding refund (and applicable interest) due. Repeated failure to provide the $4.75
payment shall be grounds for Franchise revocation and/or other enforcement actions.
4. Credits for Cable Service will be issued no later than the Subscriber's next
billing cycle following the determination that a credit is warranted.
bbbb. Rates, Fees, And Charges.
1. The Grantee shall not except to the extent expressly permitted by law,
impose any fee or charge on any Subscriber for: (A) any service call to said Subscriber's
premises to perform any repair or maintenance work related to Grantee, installed equipment
Cable Communications Franchise Ordinance
November 12, 2003
Page 47
necessary to receive Service, except any such work which was necessitated by a negligent or
wrongful act of said Subscriber; or (B) the disconnection of any Services to a Subscriber,
provided that the Grantee may impose appropriate charges if, at the time of disconnection,
some or all of the Grantee's equipment is not returned to the Grantee or the Subscriber has not
paid all outstanding fees and charges due to the Grantee; or there is damage to the equipment
of the Grantee, excluding normal wear and tear and the circumstances described in the next
paragraph.
2. Where the actions of the Grantee, its agent(s) or subcontractor(s) can be
shown upon a reasonable demonstration of evidence to have contributed to the theft, loss or
damage of a converter or other equipment lawfully used by a Subscriber, the Subscriber's
liability with respect to said converter or other equipment shall be reduced to the extent of
such contributing actions.
3. All charges for Services must be applied on a nondiscriminatory basis
recognizing that the Cable Act allows for reasonable discounts to senior citizens and/or the
economically disadvantaged and that the Grantee may, upon reasonable notice to Subscribers,
conduct promotional campaigns in which rates are discounted or waived, and may offer bulk
rate discounts for multiple dwelling units, hotels, motels, and similar institutions.
4. The Grantee shall assess late fees in accordance with applicable state law.
cccc. Enforcement.
1. Repeated failure to comply with any or all of the provisions delineated
above shall be grounds for Franchise revocation in accordance with the Franchise revocation
procedures and/or other enforcement actions.
2. The Grantor may seek injunctive relief or any other judicial remedy
available pursuant to state or federal law in order to enforce compliance with these standards.
dddd. Rights Reserved By The Grantor.
1. The Grantor reserves the right to establish additional, reasonable Subscriber
Cable Service standards from time to time, as may be necessary, after making a finding of
need and after notice to and opportunity to be heard from the Grantee has been afforded.
2. The Grantor reserves the right to regulate rates for Cable Service to the
fullest extent permitted by law. Notwithstanding anything in these standards to the contrary, in
the event that the Cable Act is amended or repealed, or restrictions on the authority of the
Grantor to regulate rates are otherwise removed or lessened, or the FCC or any court permits
the Grantor to regulate such rates, the Grantor may, at its discretion, establish additional
procedures and standards for rates and regulate such rates to the fullest extent of its regulatory
authority under federal, State, and local laws.
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November 12, 2003
Page 48
eeee. Performance Meetings. Upon request of the Grantor, the Grantee will meet with
the Grantor to review the requirements set forth in this Appendix C. The Grantee's operational
and technical personnel shall review with the Grantor such items as trouble calls and outage
reports, installation records, system performance standards, new product rollout progress
reports and other items required by the Grantor.
Violations.
ffff. Use of Public Streets. From and after the effective date of this Ordinance, it shall
be unlawful for any person to construct, install, or maintain in any public place within
Grantor's territory, or upon any easement owned or controlled by a public utility, or within
any other public property of Grantor, or within any privately -owned area within Grantor's
jurisdiction which is not yet, but is designated as, a proposed public place on a tentative
subdivision map approved by Grantor, any equipment, Facilities, or System for distributing
signals or services through a cable television system, unless a Franchise has first been
obtained hereunder, and is in full force and effect.
gggg. Unauthorized Connections. It shall be unlawful for any person to make or use
any unauthorized connection to, or to monitor, Tap, receive or send any signal or service via a
franchised System, or to enable any Person to receive or use any service, television or radio
signal, picture, program, or sound, or any other signal without payment to the owner of said
System.
hhhh. Tampering with Facilities. It shall be unlawful, without the consent of the
owner, to willfully attach to, tamper with, modify, remove or injure any physical part of or
signals on a franchised System.
Termination and Related Rights.
iiii. Material Breach.
1. In the event that the Grantee fails to comply with a material provision of any
franchise, then, in accordance with the procedures provided herein, the Grantor may revoke
the franchise granted herein and terminate any franchise in accordance with the procedure set
forth below.
2. A failure to comply with a material provision of any Franchise shall include,
without limitation, any of the following acts or failures to act by the Grantee, an Affiliated
Person or the Guarantor of any of the following events, unless excused by the Grantor.
(a) Substantial failure to provide required financial information;
(b) Substantial failure to satisfy the requirements regarding System
characteristics or repeated failure to meet the technical performance standards, as provided in
any franchise;
Cable Communications Franchise Ordinance
November 12, 2003
Page 49
(c) Substantial or repeated failure to provide any Cable Service to any
Person as required by any franchise;
(d) Substantial failure to maintain the mix, level, and quality of
Services within the broad categories of video programming and other services as set forth in
any franchise;
(e) Abandonment of the System, in whole or in material part, without
the prior written consent of the Grantor;
(f) Substantial failure to supply the PEG Channels and related facilities
and equipment after the date by which said items must be supplied, as provided in any
franchise;
(g) Substantial failure to comply with the interconnection
requirements, as provided in any franchise;
(h) Substantial and repeated imposition of any nonstandard Installation
and other charges for Basic Service which are discriminatory,
(i) Substantial and repeated failure to comply with consumer service
standards and
0) Substantial failure to comply with the privacy rights of Subscribers
as provided in this Ordinance, any franchise, or Section 631 of the Cable Act or Section 637.5
of the California Penal Code;
(k) Substantial failure to make any of the Franchise Fee compensation
payments as provided herein, or any other payments required by this Ordinance or any
franchise, or to maintain the bond or other instrument in the amount required herein;
(1) Substantial failure to comply with any rules, laws, regulations,
orders or other directives of the Grantor issued pursuant to the police powers or pursuant to
this Ordinance or any franchise;
(m) The taking of any material action which requires the approval or
consent of the Council without having first obtained said approval or consent, as provided in
Section 5.44.0300) of this Ordinance;
(n) Substantial failure to furnish and maintain throughout the term of
any franchise the liability and indemnification insurance coverage;
(o) To engage in a course of conduct intentionally designed to practice
any fraud or deceit upon the Grantor, any Subscriber, or any other use of the System;
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November 12, 2003
Page 50
(p) Failure to cooperate fully and faithfully with any lawful
investigation, audit or inquiry conducted by a governmental agency;
(q) Any material written misrepresentation, intentionally made by or on
behalf of the Grantee in its proposal for the franchise granted pursuant to any franchise, or in
connection with the negotiation or renegotiation of, or any amendment or other modification
to any franchise, to the extent that any such misrepresentation was relied upon by the Grantor;
(r) The conviction or determination of factual guilt, of the Grantee, any
Affiliated Person, any director or executive officer of the Grantee or of an Affiliated Person,
any Person holding Control of or a Controlling Interest in the Grantee, or any employee or
agent of the Grantee or of any Affiliated Person acting under the express direction or with the
actual consent of the Grantee, its directors or officers, of any criminal offense, including,
without limitation, bribery, fraud or misrepresentation arising out of or in connection with the
award, transfer, application for rate increase, or other regulation of any franchise, provided
that the right to terminate any franchise in the event of said convictions shall arise only with
respect to any of the foregoing convictions of the Grantee itself and, in the event of the
conviction of any other Persons specified in this subsection, if the Grantee fails to disassociate
itself from, or terminate the employment of, such other Persons with respect to activities in the
Franchise Area or any other activities affecting the System, within thirty (30) days after the
time in which appeals from such conviction may be taken, or within thirty (30) days following
the final determination of all appeals which are in fact taken;
(s) The conviction of any Grantor officer, Grantor employee, or
Grantor agent of the offense of bribery or fraud which arises out of or in connection with any
intentional action by the Grantee, any Affiliated Person, any director or executive officer of
the Grantee or of any Affiliated Person, any Person holding Control of or a Controlling
Interest in the Grantee, or of any employee or agent of the Grantee or of any Affiliated Person
acting under the express direction or actual consent of the Grantee or any of the foregoing,
which act was undertaken for the benefit of the Grantee;
(t) Any material false entry knowingly made in the books or accounts
or records of the Grantee, or any substantial false statements knowingly made in any report or
filing to the Grantor or any governmental agency or otherwise by the Grantee, any director,
officer, or other Person holding a Controlling Interest in the Grantee, any Affiliated Person, or
any employee or agent of the Grantee acting under the express direction or with the actual
consent of the Grantee;
(u) Failure to comply with a duly constituted lawful order or ruling of
any Grantor regulatory body having jurisdiction over the Grantee; or
(v) Substantial failure to comply with the access origination point
requirements as set forth in any franchise.
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November 12, 2003
Page 51
(w) Substantial failure to comply with the construction requirements
set forth in any franchise.
Notwithstanding the foregoing, if, as a result of a failure or alleged failure to
comply with a material provision of any franchise as delineated in the foregoing subsections,
the Grantee is unable to comply with any other material provision(s) which necessarily and
directly arise(s) out of said failure or alleged failure as delineated in said subsections, such
inability to comply with such other provision(s) shall not be deemed to be an independent
failure to comply with a material provision of any franchise.
3. The Council may exercise its right to revoke and terminate the franchise for
a failure by the Grantee to comply with a material provision of this Ordinance and/or any
franchise in accordance with the following procedures:
(a) The Grantor shall noti fy the Grantee, in writing, of an alleged
failure to comply with a material provision of any franchise which notice shall specify the
alleged failure with reasonable particularity. The Grantee shall, within forty -five (45) days
after receipt of said notice or in the event such failure cannot be reasonably cured within said
forty -five (45) days, within a reasonable time, provided the Grantee commences to cure within
said forty -five (45) days and diligently pursues such cure to completion, either cure such
alleged failure or, in a written response to the Grantor, either present facts and arguments in
refutation or excuse of such alleged failure or state that such alleged failure will be cured and
set forth the method and time schedule for accomplishing said cure.
(b) The Grantor shall investigate: (i) whether a failure to comply with a
material provision has occurred; (ii) whether said failure is excusable; and (iii) whether said
failure has been cured or will be cured by the Grantee.
(c) If the Grantor determines that a failure to comply with a material
provision has occurred and that either said failure is not excusable or has not been or will not
be cured by the Grantee, then the Grantor shall so notify the Grantee.
(d) At the conclusion of or in the event that the investigation is not
concluded, as provided- above, the Grantor shall, within thirty (30) days, provide notice of a
public hearing at which the Grantee shall have the opportunity to respond to the claim that a
material breach has occurred and to present facts and arguments in refutation or excuse of
such alleged breach, or to demonstrate that such failure shall be cured as provided in any
franchise.
(e) All final Grantor determinations with respect to revocation or
termination must be made by the City Council. Notwithstanding any final determination by
the City Council, the Grantee maintains its rights of appeal, if any, under applicable law.
4. Circumstances Beyond Control of the Grantee. The Grantee shall not be
subject to sanction when its performance is prevented for reasons beyond its control, unless
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November 12, 2003
Page 52
such occurrences or conditions are intentionally caused or created by the Grantee, or by an
Affiliated Person at the Grantee's express direction.
5. Except when enjoined by a court of law, litigation pending against the
Grantee shall not excuse the Grantee from the performance of its obligations under this
Agreement. The Grantee may petition the Grantor to be excused from the performance of its
obligation under this Ordinance because of pending litigation which the Grantor may grant or
deny in the exercise of its discretion.
jjjj. Termination and Related Rights.
1. The termination of any franchise and the Grantee's rights therein shall
become effective upon the earliest to occur of (i) the revocation of the franchise by action of
the Council; (ii) the abandonment of the System, in whole or material part, by the Grantee
without the express prior approval of the Grantor; or (iii) the expiration of the term of the
franchise, if not renewed or extended. In the event of any termination, the Grantor shall have
all rights as provided in any franchise, including, without limitation, the right to order the
Grantee to continue to operate the System or to then or thereafter remove the System, or to
acquire or effect a transfer of the System. In any event, the Grantee maintains its rights of
appeal, if any, under applicable law.
2. In the event of any termination of any franchise, the City Council may direct
the Grantee to operate the System on behalf of the Grantor pursuant to the provisions of this
Ordinance and such additional terms and conditions as are equitable and mutually agreeable to
the Grantor and the Grantee or a third party, for a period of up to twelve (12) months, in
which event the Grantee or third party, as applicable, shall be entitled to all revenues
generated by the System during such period of continued operation. In the case of operation of
the System by a third party, the Grantee shall be entitled to a fair rental for use of the System.
3. Upon the termination of any franchise due to the expiration of the term of
the franchise granted herein, if not renewed or extended, the Grantee shall be entitled to
cancel the performance bond or letter of credit, after account is taken for all offsets necessary
to compensate the Grantor for any uncured failure to comply with any provision of any
franchise as herein provided. If the Grantee continues to operate the System following the
termination of any franchise, the Grantee shall not be entitled to cancel such bond or letter of
credit until the end of such continued operation. In the event of a termination of any franchise
for cause due to a material breach by the Grantee or otherwise, said bond or letter of credit
shall become the property of the Grantor to the extent necessary to cover any costs, loss, or
damage incurred by the Grantor as a result of said termination or material breach, provided
that any amounts in excess of said costs, loss or damage shall be refunded to the Grantee or
surety, as applicable.
4. In the event of any termination, the Grantor may purchase the Cable System
in accordance with the procedures of this paragraph. In such event, the price to be paid for the
Cable System to Grantee shall be the price the Cable Act requires.
Cable Communications Franchise Ordinance
November 12, 2003
Page 53
5. Upon any such acquisition or transfer, and, if applicable, receipt of payment
by the Grantee from the Grantor, the Grantee shall:
(a) Cooperate with the Grantor in maintaining the distribution of all
Services over the System during such acquisition transfer of ownership;
(b) Promptly execute all appropriate documents to transfer to the
Grantor or third party, free of any and all encumbrances, title to the System, as well as all
contracts, leases, licenses, and rights necessary to maintain the System and the distribution of
Services over the System; and
(c) Promptly supply the Grantor with all necessary records to operate
the System, including, without limitation, all Subscriber records and plant equipment layout
documents.
6. Upon any termination of any franchise, if so directed by the Council, the
Grantee shall, at its own cost and expense, promptly remove that part of the System located in
the Streets and Public Ways and shall replace or repair and restore to serviceable condition
each affected Street, Public Way, and governmental structure therein, in such manner as set
forth in this Ordinance.
7. In the event of any acquisition of the System by the Grantor pursuant to this
Section 13, and subject to the requirements of applicable law: (i) the Grantor shall not be
required to assume any of the obligations of any collective bargaining agreements or any other
employment contract held by the Grantee or any other obligations of the Grantee to any of its
officers, employees, or agents, including, without limitation, any pension or other retirement,
or any insurance obligations; and (ii) the Grantor may lease, sell, operate, or otherwise dispose
of all or any part of the System in any manner, provided that the Grantee may seek the award
of any franchise to construct, operate, or maintain the System in connection with any such
sale.
Franchise Applications.
Applicants for an initial Franchise shall submit to the Grantor, or to its designated
representative, written application in a format provided by the Grantor, at the time and place
specified by the Grantor for accepting applications, and accompanied by the designated
application fee. A nonrefundable application fee, established by resolution of the Grantor,
shall accompany the application for an initial Franchise to cover all costs associated with
processing the application, including without limitation, costs of administrative review,
financial, legal and technical evaluation of the applicant, the costs of consultants (including
technical and legal experts), notice and publication requirements, and document preparation
expenses. In the event such costs exceed the application fee, the applicant shall pay the
difference to Grantor within twenty (20) days following receipt of an itemized statement of
such costs. This provision is procedural and shall not constitute the grant of any right to a
Cable Communications Franchise Ordinance
November 12, 2003
Page 54
Grantee to renewal or otherwise. This provision does not apply to any renewal of an existing
Franchise.
Records; Reports; Right to Inspect and Audit; Experts.
kkkk. Grantee to Provide Records. All reports and records required under this Section
shall be furnished at the sole expense of Grantee.
1111. Records. Grantor must maintain in its local office in the franchise area, and make
available for inspection during normal business hours, a separate and complete set of business
records for the Franchise. The Grantee shall provide that information in such form as may be
required by the Grantor, as well as copies of any records of Grantee upon Grantor's request, so
long as said information is related to the scope of Grantor's rights under this Ordinance, the
Franchise, or Grantor's proper regulatory functions.
mmmm. Maintenance and Inspection of Records. Grantee shall keep true and
accurate books and records in conformity with generally accepted accounting principles,
consistently applied, located in the Franchise Area that reasonably demonstrate a Grantee's
compliance with the obligations set forth in its Franchise. Grantor shall, upon two (2)
business days notice, have the right to inspect said records and receive copies thereof to the
extent said information is reasonably related to the scope of the Grantor's rights under this
Ordinance, the Franchise, or the Grantor's regulatory functions. Any Grantee records kept at
another place shall, within thirty (30) days of Grantor's request, be made available at
Grantee's local premises within the County of Orange.
nnnn. Reports of Financial and Operating Activit
1. No later than ninety (90) days after the close of Grantee's fiscal year,
Grantee shall submit an audited written report to the Grantor which shall include:
(a) A financial report, audited and certified by a financial officer of
Grantee, for all Cable System activity in the City during the previous fiscal year, including
Gross Annual Receipts from all sources and gross subscriber revenues from each service. The
report must set out separately all gross receipts from all sources in the City and gross
subscriber revenues from each Cable Service in the City, and all payments, deductions, and
computations of franchise fees.
(b) A summary of the previous year's activities, including, but not
limited to, subscriber totals and new services offered and System construction activity.
(c) A current list of Grantee's officers, directors, and other principals if
there has been any change in the previous year.
Cable Communications Franchise Ordinance
November 12, 2003
Page 55
(d) A list of stockholders or other equity investors holding five percent
(5 1/6) or more of the voting interests in Grantee if there has been any change in the previous
year.
(e) A summary of complaints received and remedial actions taken.
2. Performance Tests and Compliance Reports. Upon written requests of
Grantor, the Grantee shall provide a written report of any FCC or other performance tests
required or conducted. In addition, the Grantee shall provide reports of the test and
compliance procedures required by its Franchise, or by this Ordinance, no later than thirty (30)
days after the completion of those tests and compliance procedures.
3. Additional Reports. The Grantee shall prepare and furnish to the Grantor in
writing, at the times and in the form prescribed by Grantor, such additional reports or
information as Grantor may reasonably require to confirm and verify Grantee's compliance
with the provisions of its Franchise and this Ordinance.
0000. Examination of Facilities. Upon two (2) business days notice, and during
normal business hours, Grantee shall permit examination, by any duly authorized
representative of Grantor, of all Franchise property and facilities, together with any
appurtenant property and facilities of Grantee situated within the Public Rights -of -Way which
are related to the Cable System.
pppp. Right to Audit.
1. In addition to any other inspection rights under this Ordinance or the
Franchise, upon thirty (30) days prior written notice, Grantor shall have the right to inspect,
examine, or audit, during normal business hours, all documents pertaining to a Grantee or any
Affiliated Person which are reasonably necessary to ascertain a Grantee's compliance with its
Franchise or this Ordinance. Grantor may not exercise said right more frequently than once in
any twelve (12) month period. All such documents shall be made available at the local office
of a Grantee. All such documents pertaining to financial matters which may be the subject of
an audit by the Grantor as set forth herein shall be retained by a Grantee for a minimum of
five (5) years during the term of and following the termination of a Franchise. Access by the
Grantor to any of the documents covered by this paragraph f shall not be denied by the
Grantee on grounds that such documents are alleged by the Grantee to contain proprietary
information.
2. Grantor may require written certification by a Grantee's directors, officers,
or other employees with respect to all documents referred to in this paragraph f.
3. Any audit conducted by the Grantor pursuant to this paragraph g shall be
conducted at the sole expense of the Grantor, and the Grantor shall prepare a written report
containing its findings, a copy of which shall be mailed to a Grantee; provided, however, that
a Grantee shall reimburse the Grantor for the expense of any such audit if, as the result of said
Cable Communications Franchise Ordinance
November 12, 2003
Page 56
audit, it is determined that there is a shortfall of more than two percent (2 %) in the amount of
franchise fees or other payments which have been made or will be made by a Grantee to the
Grantor pursuant to the terms of the Franchise.
qqqq. Retention of Experts. In the exercise of its rights under this Ordinance, the
Grantor shall have the further right to retain technical experts and other consultants on a
periodic basis for the purpose of monitoring, testing, and inspecting any construction,
operation, maintenance or reconstruction of the System, and all parts thereof, or to ensure
compliance with and enforcement of the provisions of this Ordinance and the Franchise. The
Grantor shall bear the cost of retaining such experts, provided that, unless prohibited by
applicable law, the Grantee shall reimburse the Grantor for all expenses related to the
retention of said experts where this Ordinance or the Franchise so provide, or under either of
the following circumstances:
1. The Grantee has initiated proceedings which would normally require the
Grantor to retain such experts, such as the filing of a request for approval of a transfer or
change in Control, renewal to the extent allowed by law, expansion of the Franchise Service
Area, or the modification or amendment of the Franchise; or
2. The reports of such experts submitted to the Grantor reveal that the Grantee
has failed to substantially comply with the terms and conditions of this Ordinance or of the
Franchise.
If Grantee is required to reimburse Grantor pursuant to this paragraph g, Grantor shall
send Grantee an itemized description of such charges, and Grantee shall pay such amount
within twenty (20) days after the receipt of such description.
Miscellaneous Provisions.
rrrr. Captions. The section, subsection, paragraph, and subparagraph numbers and
letters, and the captions throughout this Ordinance, are intended to facilitate reading and
reference. Such numbers, letters, and captions shall not affect the meaning or interpretation of
any part of this Ordinance.
ssss. Franchise References. A Franchise which cites, refers to, or otherwise
incorporates this Ordinance, or portions thereof, shall be deemed to be a Franchise issued
under and subject to this Ordinance.
tttt. Filing. When not otherwise specified in this Ordinance, all documents required to
be filed with Grantor shall be filed with the Grantor's representative as designated by Grantor.
uuuu. Non - enforcement by the Grantor. A Grantee shall not be relieved of its
obligation to comply with all provisions of this Ordinance, and of its Franchise, and all laws
and regulations, by reason of any failure of the Grantor to demand prompt compliance.
Cable Communications Franchise Ordinance
November 12, 2003
Page 57
vvvv. Continuity of Service. It is the right of all Subscribers to receive Cable Services
so long as their financial and other obligations to a Grantee are honored. In the event that a
Grantee elects to rebuild, modify, or sell the System, a Grantee shall use due diligence and
reasonable care to ensure that all Subscribers receive continuous, uninterrupted service. In the
event of a transfer of the System by Grantee, the current Grantee shall cooperate with the
Grantor or new Grantee to operate the System for a temporary period, in order to maintain
continuity of service to all Subscribers. In the event that Grantee, through its own fault,
discontinues system -wide service for seventy-two (72) continuous hours, and Grantee is in
material default of its Franchise, or if the Franchise is revoked by Grantor (but not if Grantor
fails to renew the Franchise), Grantor may, by resolution, when it deems reasonable cause to
exist, assume operation of the System for the purpose of maintaining continuity of service.
Grantor's operation of the System may continue until the circumstances which, in the
judgment of the Grantor, threaten the continuity of service are resolved to Grantor's
satisfaction. Grantor shall be entitled to the revenues for any period during which it operates
the System.
wwww. Operation By Grantor. During any period when the System is being operated
by Grantor pursuant to paragraph a above, Grantor shall, as it may deem necessary, make any
changes in any aspect of operations that, in Grantor's sole judgment, are required for the
preservation of quality of service and its continuity.
xxxx. Management By Grantor. Grantor may, upon assuming operation of a System
franchised hereunder, appoint a manager to act for it in conducting the System's affairs. Such
manager shall have such authority as may be delegated by Grantor and shall be solely
responsible to Grantor for management of the System. Grantee shall reimburse Grantor for all
its reasonable costs, in excess of System revenues, incurred during Grantor's operation if the
Franchise is in full force and effect during the period of Grantor's operation.
yyyy. Notices. All notices and other communications to Grantee shall be addressed to
it at the local address at which Grantee conducts its business or as otherwise set forth in the
Franchise. All notices and other communications to Grantor shall be addressed to Newport
Beach City Hall, or such other address as maybe designated by Grantor.
zzzz. Force Maieu= Grantee's Inability to Perform. In the event Grantee's
performance of any of the terms, conditions, obligations, or requirements of this Ordinance, or
any Franchise granted hereunder, is prevented or impaired due to any cause beyond its
reasonable control and not reasonably foreseeable, such inability to perform shall be deemed
to be excused, and no penalties or sanctions shall be imposed as a result thereof. Such causes
beyond Grantee's reasonable control and not reasonably foreseeable shall include, but not be
limited to, any acts of God, civil emergencies, labor unrest, strikes, utility interruptions,
inability to obtain access to an individual's property on reasonable terms, and any inability of
a Grantee to secure all required authorizations or permits to utilize necessary poles or
conduits, so long as Grantee uses due diligence to timely obtain said authorization or permits.
Cable Communications Franchise Ordinance
November 12, 2003
Page 58
aaaaa. Application. All of the provisions of this Ordinance shall be applicable to all
Cable Operators, Cable Systems, OVS Operators and OVS Systems to the greatest extent
permissible under applicable law.
bbbbb. Severability. If any provision of this Ordinance is determined to be void or
invalid by any administrative or judicial tribunal, said provision shall be deemed severable
and such invalidation shall not invalidate the entirety of this Ordinance or any other provision
thereof.
Section 2. The City Clerk is directed to certify to the passage and adoption of this
Ordinance and to cause it to be published or posted as required by law.
PASSED, APPROVED and ADOPTED this day of 2003.
Mayor
ATTEST:
City Clerk
STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss.
CITY OF NEWPORT BEACH )
I, , City Clerk of the City of Newport Beach, do hereby certify that the
foregoing Ordinance No. was introduced at a regular meeting of the City Council of
the City of Newport Beach held on the day of 2003, and was
thereafter duly and regularly passed and adopted by the Council of the City of Newport Beach
at its regular meeting held on the day of 2003, by the following
vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
Cable Communications Franchise Ordinance
November 12, 2003
Page 59
Said Ordinance has been published or posted pursuant to law. Witness my hand and
official seal of the City of Newport Beach this day of , 2003.
City Clerk
Nov -07 -03 12:58pm From- Razional EnaineerinQ
deiphia
Honorable Mayor and Council Members
City of Newport Beach
3300 Newport Blvd.
Newport Beach, CA 92658-
818 867 8031 T-039 P.001 F -022
ATTACHMENT "C" — AGENDA ITEM 15
November 7, 2003
Via U.S.Mail and Facsimile: 949 - 644 -3020
Re: Proposed Newport Beach Cable Ordinance
Dear Mayor Bromberg:
Newport Beach Communications, LLC, locally known as Adelphia Cable
Communications ( "Adelphia'l appreciates the opportunity to present the City with the
following comments regarding the City's proposed amendment to Chapter 5.44 of the
Newport Beach Municipal code entitled "Cable Communications Franchises" (the
"Ordinance"). As you know, we previously provided a copy of the proposed Ordinance,
marked to show those provisions to which Adelphia objected. Although some of our
concerns were addressed in the latest draft Ordinance that we received, there are many
areas where our concern were not addressed. If the City chooses not to make further
changes to address our concerns, please be advised that Adelphia will be raising these
issues and expect to resolve them in the context of negotiation of a renewal franchise.
Furthermore, in previous conversations with the City, we have clearly stated our position
that the proposed ordinance cannot apply to Adelphia's current operations, but would
only be applicable upon the conclusions of a franchise renewal on terms and conditions
that are acceptable to both parties. Application of the proposed ordinance to Adelphia's
current operations, absent a franchise renewal, would constitute a fimdamental unilateral
amendment of Adelphia's franchise, and as such would violate state and federal
constitutional protections against impairment of contracts and taking of property without
due process and just compensation.
As a threshold matter, Adelphia is disappointed at the unnecessarily regulatory nature of
the proposed Ordinance. The proposed Ordinance is over 40 single- spaced pages long.
Many of the provisions have added cumbersome procedures for construction,
maintenance and upgrading that will make it nearly impossible to accomplish any
expedient work on our cable system. Adelphia questions whether these procedures also
apply to other users of the public rights -of -way in the City. Because these procedures are
in a cable television ordinance instead of an ordinance of general applicability, we
believe such procedures are unduly discriminatory against cable operators. To the extent
these procedures impose additional costs on Adelphia, which most of them do, that are
not imposed on other users of the rights -of -way, Adelphia believes such assessments
would be deemed franchise fees, causing the City to violate the federal cap on franchise
fees set forth in Section 622 of the Cable Act.
5720 FI Cemino Rezl
Csnmed, CA 92006 -7201
9usineSS Office (760) 438 -7741
custome Service (760) 631 -7000
Fe (760) 436 -8461 1
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Letter to Mayor Steve Bromberg
November 7, 2003
Furthermore, certain provisions are entirely impracticable and would cause Adelphia to
incur extraordinary costs that appear unrelated to an actual problem. For example,
Section 5.44.080 (v)(8) of the Ordinance requires Adelphia to provide a communication
plan that includes the following:
-A written mailed or hand delivered notification of property owners adjacent to all
Facilities not less than thirty (30) days prior to the installation indicating the proposed
location, a photograph of all above - ground visible equipment from which their size must
be apparent, and a detailed description of the equipment included within the node
including: the electronic components, natural gas generator, electrical fans, and the
anticipated noise levels during winter and summer months and emergency backup
operations"
Compliance with this requirement would mean that anytime Adelphia constructed any
facilities that involved above ground visible equipment, it would have to send a written
letter 30 days prior to construction to each adjacent property owner, including a
photograph of the cable or other equipment to be installed, a detailed description of such
equipment and anticipated noise levels. To prepare a letter with attachments as required
by the proposed Ordinance and mail it to an unidentified number of property owners
would be unduly burdensome and extraordinarily expensive without any measurable
benefit. Additionally, the provision raises a number of questions. Who are the property
owners who must receive this letter and photograph? If such property owners decided
that they did not want such equipment in their neighborhood, how would the City make
such determinations on a neighborhood-by-neighborhood basis? The placement of above
ground visible equipment is appropriate for the City's generally applicable permitting
process, not a public forum. In addition to our previous comments about unduly
discriminatory procedures, compliance with many of the requirements in the Ordinance,
as discussed herein, will impose substantial additional costs that may have to be
recovered through increased subscriber rates.
Adelphia is additionally concerned because some of the proposed provisions are
inconsistent with the federal Cable Act. For example, in many cases the Ordinance seeks
to impose requirements in cable franchises that should be a matter for negotiations during
the franchise renewal negotiations under Section 626. As such, the provisions seek to
unilaterally set the terms of Adelphia's renewal without compliance with the standards
and processes of Section 626. City staff has informed us that they do not expect the
franchise renewal negotiations to include any matters already covered in the proposed
Ordinance, except to the extent the proposed Ordinance refers to the franchise agreement.
This further reinforces our concern that the -City is trying to unilaterally set the terms of
the franchise renewal in violation with existing law.
Efforts by local franchise authorities to unilaterally dictate the terms of renewal
franchises have been stuck down as illegal in federal court. For example, in Time Warner
Enrertainmenr Co., L.P. v. Briggs, the federal district court evaluated an ordinance which
sought to dictate the terms of a franchise renewal in advance of the renewal process. The
Court held the ordinance to be preempted by the renewal standards of the federal Cable
F -022
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Letter to Mayor Steve Bromberg
November 7, 2003
Act. The following comments outline, on a section -by- section basis, Adelphia's specific
concerns and the various legal and practical problems raised by the proposed provisions
of the Ordinance:
Section 5.44.020 Definition of Affiliate.
This provision is inconsistent with the definition of "Affiliate" as it appears in
Section 602 (2) of the Cable Act.
Section 5.44.020 Definition of Gross Revenues
The amount of a franchise fee, including the definition of gross revenues, is part
of a cable operator's overall renewal proposal under Section 626 and as such cannot be
unilaterally dictated by the City. In addition, the City's definition is inconsistent with and
exceeds the parameters of a permissible franchise fee under Section 622 of the Cable Act.
Section 5.44.030 (e) Purpose
Under applicable federal law, the franchise agreement should cover all significant
areas of cable operations and will most accurately reflect the meeting of the mind of
Adelphia and the City with respect to renewal. Adelphia believes that any conflict
between the two should be resolved by specifying that the Franchise should control in all
instances, especially as the City is unilaterally adopting the proposed Ordinance and may
again unilaterally adopt amendments to such that would create conflicts with the
negotiated franchise agreement.
Section 5.44.030 (k) Restrictions Against Transfers
This provision attempts to restrict the subleasing of a portion of the Cable System
in violation of Section 621 (b)(3)(B) of the Cable Act. Adelphia has the right under
federal and state law to sublease capacity on its system as a telecommunication or
information service and the City may not impose any requirement in a cable franchise
that has the effect of prohibiting, limiting, restricting or conditioning the provision of a
telecommunication service by a cable operator.
In addition, the City has reserved the right to impose any conditions on the transfer
without limiting such conditions to those that are necessary to insure compliance with the
franchise by the transferee. This would allow the City to unilaterally amend the
franchise, in violation of Adelphia's contractual rights. Franchise agreements are
binding contracts between the City and the cable operator. Through this provision, and
others like it, the City is attempting to preserve for itself the ability to unilaterally dictate
and amend the material terms on which the operator must do business. Such power to
unilaterally dictate or amend the material terms of the agreement between the parties
would render the franchise agreement illusory, and would violate the cable operator's
constirutional rights against impairment of contracts and taking of property.
Accordingly, the provisions, and other like it, are unlawful and must be removed.
F -022
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Letter to Mayor Steve Bromberg
November 7, 2003
Lastly, Adelphia requested two very reasonable provisions that were not included in the
proposed Ordinance. One would have permitted Adelphia to provide a security interest
in the system for the purpose of seeking financing and the other would have permitted a
transfer of the system or franchise to an entity controlling, controlled by or under
common control with Adelphia. Both of these exceptions from the transfer restrictions
are often included in franchises and enabling Ordinances. Adelphia's request that the
Ordinance be modified so that the restrictions in this section apply to the transfer of the
franchise itself and not to the system, that the conditions the City could impose in the
event of a transfer are related to compliance with the franchise and that the two
exceptions requested by Adelphia be inserted in the proposed Ordinance.
Section 5.44.030 (1) Effect of Unauthorized Action
This provision allows the City to impose liquidated damages of up to $5,000 a day for
any unauthorized transfer. The City cannot unilaterally require the imposition or
payment of liquidated damages. Liquidated damages are matters agreed upon by the
parties as a good faith measure of an estimate of the actual harm incurred in the event of a
breach of contract when the actual harm cannot be determined. Indeed, to the extent that
the City seeks to impose "liquidated damages" as a penalty for an alleged failure of
compliance without regard to the actual damage, if any, incurred by the City, those may
constitute unlawful penalties. Resrat. 2d of Contracts, § 356, ("A term fixing .
unreasonably large liquidated damages is unenforceable on grounds of public policy as a
penalty.'). Adelphia does not agree that $5,000 a day is a measure of the actual harm the
City will incur as a result of a breach of the transfer provisions, especially considered the
unwillingness of the City to consider any of the reasonable modifications proposed by
Adelphia, and thus constitutes an unlawfiil penalty.
Section 5.44.030 (n) Approval Process
Federal law permits the local franchise authority and the operator to negotiate in a
franchise the additional information that may be required in a Form 394 related to
transfers and changes of control. The City may not unilaterally dictate the specific
additional information that an operator may be obligated to provide through the adoption
of an Ordinance or modifications to an existing Ordinance. Some of the specific
additional information required by this section, such as the name of each community in
which the transferee or any affiliate owns a franchise, is unduly burdensome and exceeds
the scope of information reasonably necessary to establish the legal, financial and
technical qualifications of the transferee. Furthermore, the City has reserved the right to
delay the start of the federally mandated transfer process until Adelphia has provided all
of the information required by the Ordinance in violation of federal law. if the City is
unwilling to make the changes requested by Adelphia, revisions to this section will be the
subject of franchise renewal negotiations.
Section 5.44.030 (o) Conditions
W
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Letter to Mayor Steve Bromberg
November 7, 2003
This provision again allows the City to impose conditions in the event of a
transfer. See comments to Section 5.44.030 (k) above. In addition, Adelphia has
requested that the requirement that the transferee sign a document agreeing to assume all
the terms of the franchise be modified in the case of a change of control. In a change of
control transaction, the franchise entity does not change, only its controlling parent.
changes. In such a case, it is unreasonable to expect the parent company to directly
assume all the conditions of a franchise that it will not directly own.
Section 5.44.030 (p) Reimbursement of Processing and Review Costs
The City cannot unilaterally require the operator to reimburse it for expenses
incurred in transfer or renewal, as such payment would constitute a franchise fee in
violation of Section 622 of the Cable Act and applicable law. The tote inclusion of
introductory phrases, such as "to the extent not prohibited by applicable law ", does not
alter the fact that the requirements of this section are prohibited by applicable law and
may not be adopted, since that would essentially require the operator to either challenge
the Ordinance or risk a claim of violation for failure to pay the City's costs under the
terms of this section. See Time Warner Entertainment Co. v. Briggs, C.A. No. 92-
40117-GN, 1993 U.S. Dist. LEXIS 1196 (D. Mass. Jan. 14,1993); Robin Cable Systems
v. The City of Sierra rista, 842 F.Supp. 380 (D.Ariz. 1993); Birmingham Cable
Communications v. City of Birmingham, CV 87- L- 0755 -S, 1989 U.S. Dist. LEXIS 7475
(N.D. Ala. May 5, 1989); Application of Garden State Cablevision, L.P. for Renewal of a
Certificate of Approval for the Borough of Hadden Heights, OAL Docket No. CTV-
022115 -93S; BRC Docket No. CE 92090108 (N.J. Office of Admn. Law, Feb. 22, 1994.
Section 5.44.040 Place of Inspection
This provision gives the City the right to demand access to Adelphia's book and
records "reasonably necessary for the exercise of Grantor's regulatory authority"
Adelphia is willing to provide access to books and records that are necessary to "monitor
compliance with the terms of the franchise and Ordinance" and objects to the broad
standard for access mandated by this provision. At a minimum, this provision should be
modified so that it applies to Grantor's regulatory authority "pursuant to this Ordinance
and the franchise."
Section 5.44.050 Rights of Subscribers
Cable companies are subject to comprehensive federal regulation concerning
consumer privacy that requires any local regulation to be consistent with the federal
scheme. In particular, Section 631 of the Cable Act allows local franchise authorities to
enact laws "consistent with this section for the protection of subscriber privacy." This
section violates federal law as it contains provisions that are inconsistent with such
federal law. Furthermore, this provision applies to persons and entities that are not the
cable operator in the City, including any director or stockholder who may "own, hold or
control any corporate stock." There is no rational basis for making this provision
F -022
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Letter to Mayor Steve Bromberg
November 7, 2003
binding upon third parties whose only relationship with AdeIphia is through ownership of
stock.
Section 5.44.050 (f) Subscriber Bill of Rights
Federal law requires that the operator provide an annual privacy notice to
subscribers. Adelphia provides this notice in accordance with such law. This provision
requires Adelphia to obtain the approval of the City to the contents of its federal privacy
notice, which imposes additional operational costs and burdens on Adelphia without any
measurable benefit to subscribers from this micromanagement by the City.
Section 5.44.060 Finance
This provision allows the City to charge the greater of an interest rate of the prime
rate plus 1% or $5,000 per month, or any portion of a month, for any late payment of
franchise fees, plus an additional 5% if such payments are more than 60 days late. If a
franchise fee payment was one day late under this provision, the City could charge
Adelphia $15,000 for the three months that each quarterly franchise fee payment
includes. As Adelphia's quarterly payments are approximately $170,000 per quarter, this
would amount to a quarterly interest rate of approximately 8% (or an annual rate of 32 %)
in violation of state law. Adelphia does not agree that this is a reasonable measure of the
City's damages for late payment of franchise fees and, accordingly, such requirement is
an unlawful penalty in violation of applicable law. See comments on Section 5.44.030 (1)
above_
Section 5.44.070 (g)(2) and (3) Installations
These provisions require Adelphia to advise each subscriber that such subscriber
has the right to require that installation be done over any route on the subscriber's
property and in any manner, which is technically feasible and consistent with proper
construction practices. Adelphia has objected to this provision as unduly burdensome
and unnecessary. Asa practical matter, we discuss the proposed route with the
subscriber in advance and if the subscriber has a concern -with the route, we work with
the subscriber to work out an acceptable solution_ If the subscriber chooses a route that is
different from a standard installation route, the subscriber is informed of the additional
costs and can choose such route or the original route proposed by the Company.
Furthermore, subsection (3) sets forth the terms of a standard installation that are contrary
to federal law and constitute impermissible rate regulation.
Section 5.44.080 (d)(6) System Construction
This provision unreasonably requires the operator to guarantee the integrity,
durability and structural integrity of any street cuts for the life of the street. Adelphia
questions whether this is a requirement for all users of the public rights -of -way and
believes that is a discriminatory requirement that is being applied to Adelphia in the
proposed Ordinance. There are many factors, other than street cuts made by Adelphia,
F -022
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Letter to Mayor Steve Bromberg
November 7, 2003
that affect the life of a particular street and Adelphia should not be obligated to guarantee
something over which it has no control.
Section 5.44.080 (m) Repair of Streets and Public Ways
This provision is another discriminatory requirement imposed on Adelphia in the
proposed Ordinance. This section allows the City Engineer to require Adelphia to
"overlay or slurry-seal" the entire width of a street in which it has made a street cut,
trench or excavation for the entire length of the project, or, after completion of such
work, to subsequently overlay or slurry-seal to streets to maintain the "aesthetics or
structural integrity" of the streets. Thus, if Adelphia cut a 6-inch trench right next to a
curb, the City Engineer could require the company to overlay or slurry -seal the entire
street at the time of construction and again subsequent to such construction_ This could
add enormous costs to Adelphia's construction. Furthermore, these costs can be passed
on to subscribers as franchise related external costs. While Adelphia objects to these and
other unduly discriminatory provisions in the Ordinance regarding use of the rights -of-
way, we would suggest to the City that these provisions be removed from the cable
Ordinance and put into an ordinance that would be generally applicable to all users of the
public rights -of -way.,
Section 5.44.080 (t)(2) Payment of Fees
This provision requires Adelphia to pay the City's permit fees and additional costs
to cover the City's labor, supervisory and overhead costs. Adelphia objects to these
payments and questions whether the City isn't recovering its costs twice, once through
the permit fees and once Through these so -called "Labor Payments." Cable operators pay
franchise fees of 5% of gross revenue as compensation for use of the rights -of -way. To
the extent this assessment is applied to cable operators and not other utilities, it would be
deemed a franchise fee under Section 622 of the Cable Act and violate the 5% limitation
set forth therein.
Section 5.44.080 (t)(3) Payment of Fees
This provision allows the City to hire contractors to carry out any required
work under the Ordinance and obtain reimbursement from Adelphia for these costs. If
this provision is intended to give the City this right, after it has given Adelphia written
notice of its obligation to make necessary repairs and Adelphia has failed to make such
repairs on a timely basis, the provision should be redrafted accordingly. Otherwise, this
provision gives the City the right to hire contractors at any time, at Adelphia's sole
expense, to perform work that Adelphia would otherwise be capable of performing.
Section 5.44.080 (t)(4) Payment of costs
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Letter to Mayor Steve Bromberg
November 7, 2003
This provision allows the City to hire an independent contractor, at Adelphia's
expense, in lieu of making the Labor Payments to which Adelphia has previously
objected. See our objections to Section 5.44.080 (t)(2) above.
Section 5.44.080 (v) Construction Notification
Adelphia objects to many provisions of this section of the proposed Ordinance. In
general, Adelphia believes that the requirements of this section are unduly
discriminatory, as they appear to apply only to cable operators and not other users of the
rights -of -way. See comments to Section 5.44.080 (t). In addition, the provisions of this
section create unduly burdensome procedures for construction which we believe are
unnecessary, will delay any construction and add excessive costs without any real
corresponding benefit to our customers, whose rates may rise due to these requirements.
Specific objections include subsection 3, which requires Adelphia to provide maps 90
days in advance of underground construction, which the City can share with other parties.
Adelphia is concerned that this provision duplicates other mapping requirements in
subsection 9 and may require it to provide proprietary information that the City can share
with other parties, including competitors. Adelphia also objects to subsections 4 and 7,
which require that traffic control plans and noise studies be submitted, sometimes up to
190 days in advance of construction and subsection 10 which requires Adelphia to certify
that its facilities located within any street improvement project undertaken by the City
require no further construction for a period of three years.
Subsection 8 is the most troubling of these provisions, as described in the beginning of
this letter and represents unnecessary micromanagement of our business by the City. This
subsection requires the operator to mail or hand deliver notification to property owners
adjacent to all "Facilities" — defined in the proposed Ordinance as any equipment,
including conduits, cable, cabinets, nodes, structures, headed equipment, receive only
earth stations, down link equipment and antennas, electronics, fiber cable, coaxial cable,
drops and switching equipment— whenever it proposes to install any above ground
equipment. The notification must include the proposed location, and a photograph of all
above ground visible equipment, together with a detailed description of the equipment
and anticipated noise levels during winter and summer and emergency backup operations.
First, who are the property owners adjacent to all such "Facilities? Does Adelphia have
to provide photographs of all above ground visible electronics, such as amplifiers, that
may be placed on poles? How will the City respond to objections from such notified
property owners? Does the City require all other users of the rights -of -way to notify
adjacent property owners when such users install any above - ground equipment? Adelphia
does not believe that it will be able to comply with this overly burdensome and
unnecessary regulation and, if forced to, will pass onto its cable customers the additional
costs that it incurs in attempting to comply.
Lastly, Adelphia objects to subsection 9 regarding maps and plans. This requires
Adelphia to furnish as -built construction drawing, which can be integrated in the City's
GIS system. while we do maintain as -built maps at our. system, which the City can come
and inspect, we consider such maps to be proprietary as they contain information about the
location of our electronics, which competitors could use to their advantage in building a
NOU -07 -2003 14:20 ei e967e031 99%
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Letter to Mayor Steve Bromberg
November 7, 2003
T -039 P- 009/012 F-022
competing system. These maps, if publicly available, also raise issues of the security of our
cable system from vandalism. Furthermore, Adelphia can provide maps in a Focus format
and has provided such maps in this format for many years to the City, but not in a GI.S
format. Lastly, this subsection requires Adelphia to "pothole its Facilities." Given the
extraordinary broad definition of "Facilities ", as discussed above, we are unsure what this
requirement means.
Section 5.44.090 (a) Customer Service
There are several issues raised in this section that are matters for determination
during renewal under the standards of Section 626 of the Cable Act and thus cannot be
unilaterally imposed by the City. For example, the requirement in (a)(1) for an office
located in the City is an issue for evaluation under Section 626, as it is effected by the
community need and impacts the level of investment necessary and the cost to the operator.
In addition, the customer service standards exceed the FCC customer service standards.
For example, the standards proposed in the Ordinance do not measure these standards under
"normal operating conditions ", as do the FCC regulations, thus exposing Adelpbia to
liability for issues outside of its control. Under FCC regulations, Adelphia may pass through
to subscribers any costs incurred in order to meet customer service standards in excess of the
federal standards.(C.F.R.76.925)
Section 5.44.090 (c) System Technical Data
This provision requires Adelphia to provide the City data, in a form approved by the
City, which details all of the company's equipment and facilities and their geographic
location in the City. Adelphia objects to this provision, as it requires it to provide
proprietary information and is duplicative of other requirements in the proposed Ordinance.
-See comments to Section 5.44.080 (v)(9) above_
Section 5.44.090 (i) Installations
The requirements of this section, which obligates Adelphia to provide a credit of one
month of basic cable service if it is unable to perform an installation within 9 days of a
request by a subscriber, imposes an unlawful penalty and may have the City unlawfully
exercising regulation of Adelphia's rates. A free month of basic cable service is not
necessarily related to the actual halm incurred by a subscriber for an installation that is not
performed within 9 days. Adelphia previously proposed a $20.00 credit for installations that
are scheduled more than 9 days after a subscriber's request and suggests that the City
substitute this proposed credit for the penalty provision of this section.
Section 5.44.0900)(10) Automatic Credits
This provision obligates Adelphia to provide an automatic credit to subscribers who
experience an outage of any premium service for 24 hours or more that affects the entire
franchise area or "other discrete areas ". Adelphia is able to provide an automatic credit for
such outages when they occur in the entire franchise area, but is not able to provide
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Letter to.Mayor Steve Bromberg
November 7, 2003
automatic credits on a neighborhood basis, which this section would require. Adelphia is
willingo to accept this provision, and is able to comply.with it, if it refers to outages that
affect the entire franchise area.
Section 5.44.090 (6)(11) Credits
This requires Adelphia to provide credits upon the request of subscribers for outages
of four or more hours. Adelphia requested a slight modification to this provision so that if it
has provide an automatic credit to a subscriber under the preceding subsections 9 or 10, it
would not be obligated to provide an additional credit under subsection 11. We are puzzled
as to why the City has refused to add this reasonable additional sentence to this provision_
Section 5.44.090 (k) Service Appointments
Adelphia objects to the requirement that it provide a credit equal to one free month
of basic cable service for missed appointments instead of the $20 credit that it has
voluntarily provided. See comments to Section 5.44.090 (i) above.
Section 5.44.090 0) Notices and Customer Communications
Federal law requires Adelphia to send out an annual notice to subscribers containing
information about a variety of system practices. This section repeats many of the
requirements of the federal notice, but adds additional provisions in subsections b., c.; g., i.
and j, which are not part of the annual notice but are otherwise provided to subsoribers'as
part of their installation packets (subsection b.), monthly bills (subsections i. and j.) or rate
notifications (subsection g.) or are inapplicable (maintenance policies in subsection c.). To
the extent Adelphia has to create a customized annual notice for subscribers in Newport
Beach, it will pass the costs of such customization on to its subscribers. We recommend that
the City conform this provision to federal law or refer to the federal law requirement in lieu
of this provision_
Section 5.44.090 (m) Disconnection of Service
This provision sets forth limitations on assessment of late fees. Late fees are a
matter of California state law, which may change from time to time during the life of this
Ordinance, and specific requirements with respect to late fees should not be part of this
proposed Ordinance.
Section 5.44.090 (o) Rate, Fees and Charges
This section restricts Adelphia from charging fees for service calls to subscribers in
certain instances and, as such, involves unlawful rate regulation. The inclusion of the phrase
"except to the extent expressly permitted by law" does not alter the fact that this section is
prohibited by Section 623 of the Cable Act and may not be adopted, as it would require the
operator to prove that such fees are expressly permitted by law.
10
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Letter to Mayor Steve Bromberg
November 7, 2003
Section 5.44.090 (r)
Pursuant to our meeting of several weeks ago, the reference to "Appendix C" was
to have been replaced with "Ordinance" as there are no Appendices to this Ordinance.
Section 5.44.110 Termination and Related Rights
Adelphia objects to this entire section and has suggested reasonable modifications
that would permit the City to assess liquidated damages in amounts to be negotiated in the
franchise for violations of material provisions of the franchise. Revocation provisions
would be limited to breaches of the most essential provisions of the franchise. This Section,
however, would permit the City to seek revocation for any number of issues under the
franchise or proposed Ordinance, which we believe is a violation of due process as it allows
arbitrary revocation for Ordinance provisions unilaterally adopted by the City. We urge the
City to review our proposed changes, as provided previously.
Section 5.44.110 (bx2) Termination and Related Rights
The City may not unilaterally dictate that an operator continue to provide service
after terminating of the franchise and certainly may not dictate the terms and conditions
under which the operator provides such service if it agrees to continue operating. While
Adelpbia may agree to do so, it is a matter for negotiation between Adelphia and the City,
not for unilateral imposition.
Section 5.44.110 (b) (7)
We do not understand the reference to Section 13 in this subsection. Furthermore,
the City may not unilaterally dictate its ability to acquire ownership of the system in the
event of termination and may not dictate the terms of such acquisition, such as the
requirement that the City not be obligated to assume any "collective bargaining
agreements." While Section 627(b) of the Cable Act addresses what price would be paid if
the City did acquire the system in the event of termination, it is not an affirmative grant of
authority to acquire the system under such circumstances. The ability of the City to
purchase the assets of the system would be a matter for negotiation.
Section 5.44.130 Records, Reports, Right to Inspect, etc.
Adelphia objects to provisions of this section that give the City broad authority to
inspect and copy its books and records, specifically prohibits any exceptions for confidential
and proprietary information, requires certifications of books and records from officers,
directors and employees of Adelphia, obligates Adelphia to pay the costs of auditing
consultants in violation of the franchise fee limitations of Section 622 of the Cable Act,
allows the City to employ consultants at Adelphia's expense (also in violation of Section
622) and requires Adelphia to provide certified financial statements. The provisions are
11
NOU -07 -2003 14:22 BieeS78031 99,
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Letter to Mayor Steve Bromberg
November 7, 2003
overly burdensome, unnecessary and violate the franchise fee limitations of Section 622 of
the Cable Act See also comments to Section 5.44.030 (p).
Section 5.44.140 (e-g) Continuity of Service and Operation by Grantor
The City may not unilaterally dictate that an operator provide continuity of service
after revocation and may not dictate the terms and conditions of such service, nor give the
City the right to manage and make changes in the System, if the system is down for 72 hours
through the fault of the operator. See comments to Section 5.44.110 (b)(2).
As indicated, Adelphia objects to the City's approach to seek to govern cable
television through unilateral actions in an Ordinance. In the Cable Act, Congress
recognized that franchise agreements, which are by definition bilateral documents reached at
the agreement of both parties, were to be the mechanisms for local regulation of cable
television. The City's desire to unilaterally control many of the terms and conditions by
which cable operators do business is inconsistent with Congress' intention that bilateral
franchise agreements be the mechanism for local involvement and the fundamental goal of
assuring stability and certainty to cable operator's operations.
We appreciate the opportunity to comment on the proposed Ordinance. As we hope these
comments make clear, however, there are problematic provisions in the current draft We
appreciate the changes that the City did make from the first draft of the proposed Ordinance
and urge the City to table the Ordinance and allow for further communication regarding
appropriate resolution of these issues.
If you have any questions regarding this matter, please contact me at 760-438-7741,
extension 241.
Cc: Mayor
City Council
William Marticorena, Esq.
Ms. Nancy Stinson
Martha Hudak, Esq.
12
77Z,��2
Phil Urbina
Government Affairs Manager
Adelphia Communications
NOU -07 -2003 14:22 8188678031 gel
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5. Laguna Beach. Cable TV Franchise Coordinator, City Hall, 505 Forest Ave., Laguna,
Beach, CA 92651. (949) 497 -0731.
6. Laguna Hills: City Clerk, City Hall, 25201 Paseo de Alicia, #150, Laguna Hills, CA 92653.
7. Laguna Niguel: Director of Recreation and Administrative Services, City Hall, 27801 La
Paz Road, Laguna Niguel, CA 92677. (949) 3624300.
8. Lake Forest: Director of Administrative Services, City Hall, 23161 Lake Center Dr., Lake
Forest , CA 92630. (949) 461 -3400.
9. Mission Viejo: Assistant to the City Manager, City Hall, 200 Civic Center Dr., Mission
Viejo, CA 92691 (949) 470 -3000.
10. Newport Beach: Assistant to the City Manager, City Hall, 3300 Newport Blvd., Newport
Beach, CA 92663. (949) 644 -3309.
11. Orange: Assistant to the City Manager, City Hall, 300 E. Chapman Ave., Orange, CA
92666 (714) 744 -2222.
12. Orange County unincorporated areas, including Coto De Caza, Dove Canyon, El Morro,
Emerald Bay, Ladera Ranch, Silverado Canyon, Trabuco Canyon, and Tustin Ranch:
CAN Franchise Coordinator, 300 N. Flower St., Santa Ana, CA 92702. (714) 834 -2115.
13. Rancho Santa Margarita: City Clerk, City Hall, 30211 Avenida De Las Banderas, Rancho
Santa Margarita, CA 92688. (949) 635 -7950.
14. San Clemente. City Clerk, City Hall, 100 Avenida Presidia, San Clemente, CA 92672.
(949) 361 -8200.
15. San Juan Capistrano. Administrative Services, City Hall, 32400 Paseo Adelanto, San
Juan Capistrano, CA 92675. (949) 443 -6359.
16. Tustin: Public Works Depl., 300 Cenlennial Way, Tustin, CA 92780. (714) 573 -3160.
The franchise authority in each area is authorized to provide a schedule of penalties for fail-
ure to comply with provisions in this notice.
II. SERVICE LEVELS:
The goal of Cox Communications is to provide a level of cable television customer service
that meets the needs of its customers. The following summarizes some of the customer
service standards that we have set for ourselves and the actual performance for the 12
months of August 2002 through July 2003:
A. Customer telephone calls are to be answered with an average speed of 30 seconds or
less
During the past 12 months, Cox Communicalions'average speed of answer was 29 sec-
onds.
B. Customers will receive a busy signal less than 3% of the time when they call the Cox
customer service phone numbers.
Cox Communications customers received busy signals 0% of the lime during the past 12
months.
C. New customers requesting cable television service will have an average wait of less than
7 business days for installation.
During the past 12 months, the average wait for installation of cable service was 3.1
days.
III. EOUIPMENT
In the event the equipment is not returned to Cox in good condition, Customer agrees to pay
to Cox as liquidated damages, the sum of $18.00 for each analog converter, $258.00 for
each digital converter, $419.00 for each HDTV converter and $73.00 for each modem.
IV, INDECENT LEASED ACCESS
Indecent programming carried on leased access channels, if any, will be scrambled and
available to subscribers, upon request, al no charge. If you wish to receive such program-
ming (when available), please call our customer service numbers, (949) 720 -2020 for
Central Orange County and (949) 240 -1212 for South Orange County.
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COMMUNICATIONS
29947 Avenida De Las Banderas
Rancho Santa Margarita, CA 92688
P78480 6400 -0350
2003
CABLE TELEVISION CUSTOMER RIGHTS
I. CUSTOMER SERVICE STANDARDS FOR CABLE TELEVISION SERVICE
1. The service will operate in an accurate, efficient manner and will meet or exceed FCC
specifications and current local and state requirements.
2. Except in circumstances beyond our control, repairs to or replacement of our equipment
will be made: (A) within 24 hours of receiving a customer's notification of a service disrup-
tion, or (B) within 36 hours of a customer's notification of all other system malfunctions.
3. Cox Customer Service personnel shall identify themselves by first name upon respond-
ing to any service inquiry. Customers shall have the right to speak with a supervisor or if
none is available, a supervisor will return the call within one working day.
4. All customer inquires will be investigated as soon as possible but not later than 24 hours
from the time of receipt.
Planned interruptions of service other than interruptions between the hours of midnight and
8:00 a.m., will be preceded 48 hours by detailed announcements appearing on your local
cable channel or in writing where possible. For planned interruptions exceeding twelve
hours, written notice will be provided and will include information regarding any applicable
billing adjustments.
5. Except in circumstances beyond our control, or that have prior franchisor approval, inter-
ruptions of service shall not exceed three (3) hours of the total of service available in any
one week, calculated from 6:00 a.m, until 12:00 midnight daily. Service interruptions are
defined as the loss of picture and sound on one or more channels.
6. All customer requests for new service shall receive a response within five working days.
7. Cox Communications maintains compliance with all of the requirements listed above.
8. These procedures were developed in accordance with the requirements of franchises
with the following franchise authorities: Aliso Viejo.. Camp Pendleton, County of Orange,
Dana Point, Irvine, Laguna Beach, Laguna Hills, Laguna Niguel, Lake Forest, Mission Viejo,
Newport Beach, Orange. Rancho Santa Margarita, San Clemente, San Juan Capistrano,
Tustin. These procedures are also in accordance with California Legislation AB 2388 and SB
1010. Each customer will receive these procedures upon installation of service and on
request thereafter, and at anytime upon request,
9. In addition, at the time of installation and on request, we will provide a written descrip-
tion of our service that instructs you in its use.
10. When appropriate. the following billing adjustments will be available: A) A 10% credit of
the monthly fee may apply if requested, in the event that one third or more channels of your
service is interrupted for four (4) consecutive hours or a total of twenty -four (24) hours with-
in a thirty day period: B) a 20% credit of the monthly fee may apply, if requested, in the event
the service is interrupted for forty -eight (48) or more consecutive hours in any seven (7) day
Period , Cl a 251/ credit or the monthly fee will appN i` Coa fails to meet franchise perform-
ance standards for any period of three consecutive months.
11. Refunds will be issued no later than thirty (30) days following the resolution of a billing
dispute or the next billing cycle, whichever is less. Bills are issued once each month for the
upcoming thirty (30) day period.
12. Unpaid bills are considered past due on the thirtieth (30th) day after billing and may be
assessed a late fee of $4.75 on the 45th day after billing. Termination of service may occur
22 days after the bill becomes delinquent and proper notification has been given. Proper
notification consists of a notice delivered by the U.S. Postal Service or by hand at least fif-
teen (15) calendar days prior to the stated date of disconnection, with the word "Termination
Nofire" or similar language prominently displayed on the notice. The notice shall include the
name of the customer, amount of delinquency, date the payment is required, the number of
days until termination and the hours, address and telephone number where payment may
be made. Once service has been involuntarily terminated, service can be restored after pay -
mers (cash, cashier check or money order), plus a reconnection fee, have been received at
a Cox business office. Lobby hours at our Cox business offices, located at 29947 Avenida
De Las Banderas, Rancho Santa Margarita, are from 9:00 a.m. until 6:00 p.m. Monday
through Friday and 9:00 a.m. until 1:00 p.m. Saturday. Requests for more than three (3)
reconnections because of payment delinquency within twenty -four (24) months may not be
rowed.
13. All customers will receive a thirty (30) day notice of deletion or addition of programming
service, change of channel assignments, or price increase except in circumstances beyond
Durcontrol.
14. Cox makes available to all customers a parental control channel blocking device that can
block viewing of a particular cable channel during periods selected by that customer.
15. Discounted Senior Citizen IDisabled Persons prices may be available depending on indi-
vidual circumstance.
16. When the presence of the customer is required for service work, a four (4) hourtime peri-
od wdl be offered at the time the customer calls for service connection or repair. Cox may
notcancel appointments after the close of business on the business day prior to the sched-
uled appointment.
17. k the time of installation and annually thereafter, Cox will notify all customers of its prac-
ticesregarding the protection of customer privacy.
18. M field personnel and contractors will carry or wear photo identification tags.
19. If requested, Cox will provide descrambling equipment that will allow simultaneous
reception of dual scrambled or encrypted signals while tuned to alternative channels on a
pre - programmed schedule. Direct reception of all other signals that do not need to be
processed through decryption circuitry will be provided.
In accordance with our franchise agreements, we are required to Portly you that, by providing
television service, we are making use of the public rights -of -way which use is in no way guar-
anteed. In the event continued use of such rights -of -way is denied us for any reason, we will
make every reasonable effort to provide service over alternate routes. By accepting Cox
Communications television service, the customer agrees that he/she will make no claim, or
undertake any action, against the franchisor, its officers, or its employees if the services to be
provded are interrupted or discontinued. For additional services, billing inquiries or service
problems, please call our customer service numbers: (949) 240 -1212 for South Orange
County and (949) 720 -2020 in Central Orange County. If callers to our customer service are
required to wait, they will receive a recorded message explaining that lines are busy and
requesting that the caller wait for the next available representative. If the concern you report-
ed is not resolved to your satisfaction. please call (949) 546 -2000.
ShoWd your reported concern require further attention, you have the right to send written
notice to the appropriate franchisor. They are
1. Mso Viejo. City Clerk, City Hall, 12 Journey, Aliso Viejo, CA 92656. (949) 425 -3800.
2, Camp Pendleton. Franchise Administrator, PO Box 1609, Oceanside, CA 92501.
gi 725 -3233.
3. Dana Point: City Clerk, City Hall, 33282 Golden Lantern, Dana Point, CA 92629. (949)
248 -9890.
4, Irvine: City Clerk, City Hall, 1 Civic Center Dr., Irvine, CA 92714. (949) 724 -6040.