Before the

Federal Communications Commission

Washington, D.C. 20554

In the Matter of                                                              )


Implementation of Section 621(a)(1) of the Cable   )                                    MB Docket No. 05-311

Communications Policy Act of 1984 as Amended    )

by the Cable Television Consumer Protection and  )

Competition Act of 1992                                              )



Brookline Cable Community Trust dba Brookline Interactive Group (BIG)  appreciates the opportunity to file comments on the Second Further Notice and Proposed Rulemaking (“FNPRM”) in the above-referenced docket.  

Brookline Interactive Group (BIG) serves over 58,000 residents and has done so for the past 34 years in Brookline, part of the greater Boston metro area. We are an independent, nonprofit, 501(c)(3) organization, and our membership is free and open to all. And we are deliberately, explicitly, a nonpartisan organization. All political opinions, popular or otherwise, are welcome, as well as all forms of expression.

BIG’s community media resources have enabled thousands of local residents, hundreds of nonprofit organizations, and countless youth, seniors, municipal and school committees, and government departments to gain economy-building traditional and new media skills, to create and distribute critical, timely and compelling community information, and to provide news, information and emergency services to the town of Brookline and its residents, including health and safety alerts, and over 700 hours of government meetings, town meetings, and local proceedings annually over two community cable access channels.

With a small but dedicated team of nonprofit media professionals, BIG offers extensive educational programming such as local film festivals, community and school screenings, collaborative filmmaking, community forums, training programs for educators, and administers educational grants for innovation for teachers and local filmmakers. BIG annually operates over thirty-five traditional and emerging media training programs for adults annually; a hands-on job training program for high school age youth (averaging twenty students per year, 60% low-income students, many of whom have now gone on to college level and vocational programs); and twenty-seven after school media literacy and media production programs for students ages 7-18. BIG provides out-of-school time educational services, much needed in our community, and in-school media support at several school sites to teachers, administrators, and to many departments within Brookline’s Town and Public Schools.

BIG and its members provide non-partisan election coverage, and coverage of public election forums, coverage of town meeting warrant articles, training programs for town meeting members, as well as offering all local and national elected officials air time throughout the year to reach their constituency with information about critical issues affecting the district.

During BIG’s most recent negotiations with RCN and Comcast, over 125 individual letters from residents indicating their support and appreciation for the unique work and contributions of BIG to Brookline. Not only did they write letters, but they also attended public hearings in the middle of the day, and spoke for over six hours recording their public comment for Town Officials in support of the extensive community media services provided by the Brookline Interactive Group (BIG). BIG is the only organization providing community media services to Brookline in this way, and there is no other local community-based or corporate content provided for our community like BIG’s.

ANY reduction of local franchise fees will make these services impossible to deliver to the town of Brookline, as BIG has already lost funds recently from the decrease in cable funding while the demand for our media services to the community, to businesses, to nonprofits, to local government, and our memberships, our studio and facilities usage is increasing greatly. (Note: attached is our 2017 annual organizational report and highlight video to this effect) BIG operates at 75% capacity in our studios, editing suites, and facilities. We run an extremely efficient and professionally-managed nonprofit, with a laser focus on mission, resource management and providing exceptional public media services to the community.

We very strongly oppose the tentative conclusion in the FNPRM that cable-related in-kind contributions, such as those that allow our programming to be viewed on the cable system, are franchise fees. These franchise fees are not only the life blood and support of organizations such as ours, but they are the right of the community as it exchanges its own public right of way, owned by all of the community, in exchange for private commercial cable operators to use public land for their own personal profits. This is a reasonable exchange, that must be locally-controlled, and extended to include Internet services, not reduced.

Franchise fees are not, and should not be taxes, nor are capital payments or in-kind donations. These are the cost of doing business across public land. The community itself agrees to and embraces the pass-through of these fees. They should not be controlled by government entities. They should not be controlled by business interests. They are and should be controlled by independent, nonpartisan community organizations. They belong to the community. A decision supporting FNPRM only undermines and attacks the freedom and independence of communities and individuals. To be clear, these funds do not belong to cable providers. They are the property of the community. A decision for FNPRM only takes community funds and gives them directly to cable providers who have no right to them.

We invite the Commission to view for themselves the important benefits provided by local content in PEG programming.  The link below is to BIG’s annual highlight reel and a digital copy of BIG’s annual report for FY 2017.

Located at: [

This link leads you to see for yourself the extensive public comment in 2015, and again in 2017, in support of and highlighting the need for, BIG’s community media resources and demonstrates the perceived and real value of PEG programming to our community.

BIG has won many national and regional awards for our locally-produced content, its leadership team members are frequent speakers at regional and national conferences, and in 2017, BIG was invited to present at the United Nations to highlight our most innovative storytelling work as an example to over 800 world leaders.

We appreciate this opportunity to add to the record in this proceeding and to have our voice heard. We strongly encourage you to look at the work we do, work whose existence is threatened by FNPRM. Thank you for your time and consideration.

                                                                                                    Respectfully submitted,

                                                                                                    Ann K. Bisbee
                                                                                                    Executive Director,
                                                                                                    submitting on behalf of Brookline Interactive Group (BIG)

                                                                                                    Brookline, MA, U.S.A