Public Knowledge and the New America Foundation ("PK and NAF") respectfully submit these reply comments in response to the Notice of Proposed Rulemaking released in the above-captioned docket. PK and NAF oppose a proposed rule that MVPDs must give notice to subscribers in the event of a potential programming blackout, and disagree with commenters that assert that the Cable Act prevents the Commission from adopting mechanisms to ensure fair retransmission consent negotiations. In addition, PK and NAF argue that 1) their proposed interim carriage system will not hurt local broadcasters; 2) the Commission has authority to reevaluate earlier determinations on the validity of program "tying" arrangements, and 3) the proposed requirement of mandatory arbitration need not pose undue burdens on broadcasters or MVPDs.

To view the rest of these reply comments, download the entire transcript by clicking the PDF icon on the right.