William D. Bradford
4 Subway Avenue
Chelmsford, MA 01824
23 July, 2019

Ms. Marlene H. Dortch, Secretary
Federal Communications Commission 445 12th Street, SW
Washington, District of Columbia 20554

RE: Implementation of Section 621(a)(1) of the Cable Communications Policy Act of 1984 as Amended by the Cable Television Consumer Protection and Competition Act of 1992, Third Report and Order - MB Docket No. 05-311

Dear Ms. Dortch,

I have been a volunteer cameraman for my local access TV organization, Chelmsford Telemedia (CTM), for more than 10 years. I'm alarmed to learn of the  FCC’s proposed Third Report and Order, wherein Local Franchising Authorities (“LFA’s”) must treat cable-related, in- kind contributions as franchise fees subject to the statutory five percent franchise fee cap. I believe that this order threatens the continued operation of an irreplaceable civic and cultural resource in our community.

During all my time in Chelmsford, CTM has broadcast most town meetings and important local debates. In this way it provides the kind of transparent access to our government that exemplifies New England democratic tradition. Our residents create many local TV shows using CTM's facilities and production expertise, sharing a wide range of cultural and political points of view. This weekend CTM will film musical performances at the Lowell Folk Festival, enabling thousands of citizens who cannot attend to enjoy this nationally-renowned event at home, and CTM covers many other cultural and sports events all year round. Finally, CTM collaborates with our public schools by training students to produce all this high-quality programming, providing valuable training and experience for our young people.

Cable providers like ours operate as effective monopolies that generate ample profits for them. That is why there is no justification for giving them the means to stop the modest level of financial support for PEGs that they have been customarily required to provide. On the contrary, their freedom from market competition is all the more reason why they need to be held accountable by the FCC, whose stated mission includes protecting consumers. T

Sincerely,

William D. Bradford