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HomeMy WebLinkAboutMINUTES - 01231996 - SD2 TO: BOARD OF SUPERVISORS �•``�" 5''L" °F_ Contra FROM: Phil Batchelor, County Administrator Costa County DATE: January 18; 1996 [D .:...: '�T UN SUBJECT: APPROVE THE TRANSFER OF BAY CABLEVISION, INC. LICENSE TO HERITAGE CABLEVISION OF DELAWARE, INC. SUBJECT TO THE FOLLOWING TERMS AND CONDITIONS. SPECIFIC REQUEST(S)OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION RECOMMENDATION: 1. Subject to the following terms and conditions, CONSENT to the transfer from the Lencomm,Inc., doing business as Bay Cablevision, Inc. ("Transferor") to Heritage Cablevision of Delaware, Inc. ("Transferee") of the license for the cable system operated by Transferor in the unincorporated Richmond area: (a) On or before February 15, 1996, the Transferor shall pay to the County all license fees due for the period through December 31, 1995, and shall deliver to the County the statement of gross annual receipts required under Section 58-6.002(f) of the County Ordinance Code. The Transferee shall be responsible for the payment of license fees accruing after December 31, 1995. (b) The Transferor and Transferee shall be jointly and severally liable for any license fee under- payment that occurred prior to the closing date of the transaction between the Transferor and Transferee ("Closing Date"), including without limitation license fees payable on advertising revenues received indirectly by the Transferor during the period January 1, 1991 through the Closing Date. (c) As provided in the attached agreement, the Transferee will not file a new, amended, supplemented, or modified cost-of-service showing for a period of four (4) years from the date of the Written Decision. CONTINUED ON ATTACHMENT: YES SIGNATURE: RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE APPROVE OTHER SIGNATURES: -79 ACTION OF BOARD ON APPROVED AS RECOMMENDED OTHER VOTE OF SUPERVISORS I HEREBY CERTIFY THAT THIS IS A TRUE _ZUNANIMOUS(ABSENT ) AND CORRECT COPY OF AN ACTION TAKEN AYES: NOES: AND ENTERED ON THE MINUTES OF THE BOARD ABSENT: ABSTAIN: OF SUPERVISORS ON THE DATE SHOWN. ATTESTED Contact: PHIL BA HELOR.CLER F THE BOARD OF CC: SUPERVI ORS AND COUNTY ADMINISTRATOR BY DEPUTY (d) On or before the Closing Date, the Transferee shall file with the Clerk of the Board of Supervisors its written acceptance of the license, in a form satisfactory to the County Counsel, together with all required bonds and insurance certificates, and its agreement to be bound by and to comply with and to do all things required of the Transferee by the provisions of Division 58 of the County Ordinance Code (Ordinance No. 93-55) and license award resolution (Resolution No. 94/363 adopted July 12, 1994) and to expressly assume all obligations of the Transferor, as required by Section 58-4.028(1) and (k) of the County Ordinance Code. (e) The transfer of the license shall not become effective unless the County receives the items specified in paragraphs (a) and (d) by the applicable deadlines. Should these items not be submitted on time, this Resolution shall be of no further force or effect and the application for transfer of ownership shall be deemed to have been denied without prejudice. 2. APPROVE the attached Agreement Relating to the Consent to the Assignment and Transfer of the License Granted to Lencomm, Inc. and AUTHORIZE the Chair of the Board to execute the agreement on behalf of the County. 3. At the conclusion of the hearing, ISSUE a written decision ordering the Transferor to credit individual subscriber accounts with the determined refund and set basic service tier rates as indicated in Exhibit B. FINANCIAL IMPACT: There will be a deduction in the FY1996 franchise fee payment to the County as a result of refunds to subscribers. This should not amount to more than $1,500. BACKGROUND: On October 3, 1995, Bay Cablevision, Inc. (or "Transferor") filed with the County an FCC Form 394 requesting that the County consent to a transfer from Bay Cablevision, Inc. ("Transferor") to Heritage Cablevision of Delaware, Inc. ("Transferee") of the license for the cable system serving the unincorporated Richmond area. Section 58-4.028 of the County Ordinance Code (Ordinance No. 93-55) requires that all proposed transfers of licenses be submitted to the County for review and decision by the Board of Supervisors. Pursuant to Section 617 of the federal Cable Act (47 U.S.C. Section 537), the County has 120 days to act upon any request for approval of a transfer. Following receipt of the FCC Form 394, staff worked with the Cities of Berkeley, EI Cerrito and Richmond to hire a consultant to review the legal, technical and financial qualifications of the buyer. Rutan & Tucker determined that the Transferee was qualified to operate the Richmond system. Then a compliance review of Bay Cablevision, Inc. was conducted by staff. Bay Cablevision, Inc. had renewed their license in 1993. A review of their technical and financial qualifications was conducted at that time. Recently, staff has resolved with Bay Cablevision, Inc. certain issues relating to the payment of license fees on advertising revenues and late fees. However, an outstanding issue still remains over whether license fees are payable on those advertising revenues received indirectly by the Grantee (e.g., revenue used for operating expenses of Bay Cable Advertising and revenue received by the parent(s) of the Grantee). This same issue is currently being pursued by the County and a consortium of eight local cities with TCI's local systems. Appropriate. language has been added to this Resolution to enable the County to continue to pursue this issue with the Transferee. In addition, staff is aware of another jurisdiction in which a cost-of-service showing submitted for rate increases after a transfer included costs for goodwill related to the transfer of the system. This increased basic rates significantly. Currently, FCC regulations exclude the use of goodwill in rate calculations, although some cable operators continue to include it until their dispute with the FCC over this issue is resolved. To avoid any significant rate increase in basic service rates because of goodwill as a result of this transfer, staff has included the attached agreement which conditions the transfer on the Transferee's agreeing not to submit a cost-of-service showing for four (4) years from the date of the Written Rate Decision. Staff believes that these conditions are necessary to assure compliance with the County's cable television ordinance and FCC rate regulations. CONSEQUENCES OF NEGATIVE ACTION: If the Board does not take the action recommended above, the application for consent to transfer would be deemed automatically granted. This could potentially limit the County's ability to recover underpaid license fees and could possible increase rates by the inclusion of goodwill for the citizens in the unincorporated Richmond area. q& S D- EXHIBIT A AGREEMENT RELATING TO THE CONSENT OF THE COUNTY OF CONTRA COSTA TO THE ASSIGNMENT AND TRANSFER OF THE LICENSE GRANTED TO LENCOMM, INC. . This Agreement (the "Transfer Agreement") entered into this 30th day of January, 1996, between and among the County of Contra Costa ("County") , Lencomm, Inc. , dba Bayt'Cabla a.a or ,Inc f (the "Transferor") and Heritage Cablevsion''of DeYaware, Inc. " (the "Transferee") . WHEREAS, on July 12, 1994, the Board of Supervisors (the "Board") of the County approved by Resolution No. 94/363 the granting of a community antenna television (CATV) license (the "License") to the Transferor pursuant to the provisions of the County Ordinance Code (the "Ordinance") for- a term of ten (10) years to operate a cable television system within the County (the "System") ; and WHEREAS, the Transferor has filed a written application to the County, dated October 311995 (the "Application") wherein it has requested the consent of the County to the transfer and assignment of the License to Transferee (the "Asset Transfer") ; and WHEREAS, it is the intent of the County to approve the transaction whereby ownership and control of the License and the System shall be held by the Transferee (said transaction shall be referred to herein as the "Transfer") ; and WHEREAS, the Board of the County has reviewed the Transfer as well as all relevant documents, staff reports and recommendations; and WHEREAS, pursuant to Section 58-4.028 of the Ordinance, the Transfer is subject. to the written consent of the County; and WHEREAS, based upon the evidence presented to the Board, it has determined that it would be in the public interest to conditionally approve the Transfer. NOW, THEREFORE, it is agreed by and between the parties as follows: , 1. The Board of the County hereby gives its consent and approval to the Transfer whereby the License and the System, including all the assets thereof, shall be directly acquired and held by Transferee. 2 . The granting of this consent to the Transfer does not waive the right of the County to approve any subsequent change in the ownership of the License or the ownership or control of the Transferee and there shall be no further material change, amendment 1 or modification of the ownership or equity composition of the Transferee which requires prior consent of the County pursuant to the Ordinance without the further written consent of the Board. 3 . By executing this Transfer Agreement, the Transferee agrees and acknowledges that (1) this Transfer Agreement and the approving resolution- is not a new license agreement, the granting of a license, or the renewal of the existing license, but rather is exclusively an agreement to transfer and assign the License and said Transfer Agreement neither affects nor prejudices in any way the County's rights thereunder; (2) that compliance with the License and Ordinance, as of the date of closing of the Transfer, is neither commercially impracticable as the term is used in Section 625 (e) of the Cable Communications Policy Act of 1984 and/or the Cable Television Consumer Protection and Competition Act of 1992 (collectively the "Cable Act") nor economically infeasible upon closing of the Transfer. 4 . By executing this Transfer Agreement, the Transferee hereby accepts all the terms and conditions of the License, the Ordinance and any orders and directives of any administrative agency relating to the License or the System including, but not limited to the Federal Communications. Commission and this Transfer Agreement and represents and warrants that it has examined the requirements of the License, the Ordinance, this Transfer Agreement, as well -as applicable federal, state or local laws or regulations and agrees to abide by all the terms and conditions thereof. The Transferee agrees and acknowledges that it has found the Ordinance, the License, and the other documents specified herein to be legally sufficient, enforceable, valid, and binding and accept the same without condition or reservation. The Transferee accepts the License, and all obligations thereof, subject to and assuming liability for all existing disclosed and undisclosed breaches and defaults. The Transferee agrees to cooperate and furnish relevant information in relation thereto. The Transferor agrees to cooperate and furnish relevant information in relation to any audit and/or investigation relative to breaches and/or defaults accruing prior to the Transfer. . To the extent that the Transferee, or any related person or entity, challenges -the validity or interpretation of said above- listed documents in the future in any administrative proceeding or court of law, such a challenge shall be subject to all defenses which would have been available to the County had the Transferor, or any related person or entity, brought said challenge (s) including, but not limited to, waiver, estoppel, consent, unclean hands and accord and satisfaction, as well as any and all defenses 2 4• l independently available to the Transferee. 5 . Any violation of this Transfer Agreement shall be deemed to be a violation of the Ordinance and the License. 6. The County hereby gives the Transferee notice that the grant or transfer of the License may create a taxable possessory upon which the Grantee and Transferee may be liable for the payment of certain taxes. . The Transferee hereby acknowledges that it has received actual notice as required by Revenue and Taxation Code Section 107.6. . 7. The Parties hereto acknowledge that the County has issued a Rate Order dated January 23, 1996, a copy of which is attached as Exhibit B (the "Rate Order") . The Transferor and the Transferee hereby agree to accept the Rate Order as a lawful and binding rate order, comply with its terms, agree not to appeal said Rate Order, and waive and relinquish any and all appeal rights which they possess in relation thereto and the right to challenge the legality of the Rate Order, on any grounds, in any judicial or administrative forum. Further, the parties hereto agree, in material consideration for approval of this Transfer Agreement by the County, as follows: (a) If, and to the extent, the County, the Transferor, or the Transferee, violates any of the provisions of the Rate Order, the non-breaching party shall provide the allegedly breaching party with written notice detailing with . specifiCounty the alleged breach. The: allegedly breaching party shall have 30 days following the provision of the notice to either cure the breach or respond in writing detailing with specificity why a breach has not occurred. At any time following this 30-day period, either party may seek relief in a court of competent jurisdiction. In addition, at any time following this 30-day period, the County may, at its option and in addition to any other remedy available to it pursuant to this Transfer Agreement or applicable law, recommence its review of the -Cost. of Service Forms and nothing in the Rate Order shall prejudice either the County or the cable operator's rights with respect to said proceeding. Notwithstanding the date upon which written notice is provided by the County to the Transferor or Transferee, as the case may be, (the "Operator") that the Operator has breached any or all , of the provisions of the Rate Order, refund liability based upon the determination of the Maximum Permitted Rates contained in the Resolution shall extend back to the dated date thereof and, to the extent the Commission upholds the determination of the County as to the Maximum Permitted Rates for County Regulated Rates, the Operator shall pay refunds, in 3 a manner prescribed by the Rules of the Commission back to the dated date of. the Rate Order. (b) The Operator will not file new, amended, supplemented, or modified Cost of Service forms, by way of a - new, amended, supplemented or modified FCC Form 1220 (with or without a related FCC Form 1205 and/or 1210) , or any successor forms, for a period of four (4) years from the dated date of the Rate Order (the "Forbearance Period") . During the Forbearance Period, the Maximum Permitted Rates for County Regulated Services shall be exclusively adjusted, if at all, pursuant to the formula and methodology contained in the current FCC Forms 1210, 1235, and 1240, or their successor forms (the "Rate Adjustment Forms") and the Operator hereby waives, relinquishes, and releases any right which it may possess to seek rate adjustments in excess of the amounts which would be allowed pursuant to the Adjustment Forms. (c) Except as expressly provided in the Rate Order and herein, the Operator and the County shall comply with all applicable Rules of the - Commission including, without limitation, the timely filing and review of the various rate related forms of the Commission including, without limitation, the Rate Adjustment Forms. (d) If the Transferor or Transferee, individually or collectively, or any affiliate or subsidiary or parent thereof, appeal or otherwise challenge the validity or enforceability of the Rate Order, as defined in Paragraph 9 hereof, in any judicial or administrative forum, or otherwise dispute its legal validity or enforceability and is successful in its asserted position(s) , the Transferor and the Transferee, as the case may be, shall be deemed in material breach of the License. 8 . The Transferor shall pay collectively to the County, the Citie/s of Berkeley, E1 Cerrito, Emeryville and Richmond (collectively the "Franchising Authorities") or the agents thereof designated by the Franchising Authorities in writing, within ten (10) days of the Board's approval of this Transfer Agreement the sum of Forty Thousand Dollars ($40, 000) in full satisfaction of all attorney fees and professional consultant fees and costs in relation to this proceeding. If said amount is not sufficient to reimburse the Franchising Authorities for all out-of-pocket expenses, the Franchising Authorities. shall provide written notice thereof to the Transferor and Transferee of the amount of the appropriate expense reimbursement (the "Full Amount") . The Transferor shall pay the Full Amount provided, however, that to the extent that the Full Amount exceeds $40, 000 .00, the obligation of 4 the Transferor and Transferee to pay refunds pursuant to Section 2 of the Rate Order shall decrease by an equivalent amount so that the total obligations pursuant to Section 2 of the Rate Order and this paragraph shall not exceed $340, 000.00 . The County, the Transferor and the. Transferee expressly agree and acknowledge that the payment is settlement of a good faith dispute and is not a "franchise fee" within the meaning of Section 622 (g) (1) of the Cable Act, and that said payment will not be offset or charged against any other license fee owing either prior paid or future owing, or other sum due to the County, and that said payment is a voluntary payment and not a tax, fee, or assessment imposed by a franchising authority on a cable operator or cable subscriber, or both, solely because of their status as such, and that said payment does not constitute a license requirement . or is, in any way, subject to "pass-through" , or externality treatment and will not, under any circumstances, be itemized upon any billing to any subscriber or added, for the purposes of collection, to any other lawful rate. The Transferor agrees to bear the full and total economic burden of this payment. 9. This Transfer Agreement shall be deemed effective upon the closing of the Transfer so long as it has been executed and returned by all parties within ten (10) days after approval by the County (the "Effective Date") . If it is not so executed and returned within ten (10) days, it shall become null and void and the Transfer shall be deemed disapproved as of the date of approval of this Transfer Agreement by the County Board. The signatories hereby affirm that this Transfer Agreement has been entered into on a voluntary basis without duress and has been undertaken in a manner consistent with federal, state and local law. The signatories to this agreement further represent and warrant that they possess full legal authority on behalf of their principals to enter. into this Transfer Agreement. COUNTY OF CONTRA C LENCOMM, INC. By By I Its V PHIL BATCHELOR, Clerk of the Board of Supervisors and County Administrator By Its By Depu Clerk 5 RECOMMENDED FOR APPROVAL: APPROVED AS TO FORM: VICTOR J. WESTMAN, County Counsel HERITAG CABLEVISION OF DELAWAR INC. By By David Schmidt, Deputy County It Counsel Phil Batchelor, County By Administrator Its `c.1 By Patricia Burke, Cable TV Administrator 6 STATE OF COLORADO ) ) ss. COUNTY OF ARAPAHOE ) On May 13, 1996, personally appeared before me, a Notary Public in and for the State and County aforesaid, Stephen M. Brett, Vice President/Secretary, and Madonna Guenthner, Vice President, of Heritage Cablevision of Delaware, Inc., personally known to me to be the persons whose names are subscribed to the above instrument in such capacities, who acknowledged that they executed the same. My commission expires: May 23, 1997. n pyo [SEAL] Notary blic f "a3 - �� Err B J_ WRITTEN DECISION OF THE COUNTY OF CONTRA COSTA (THE "COUNTY") RELATING TO CERTAIN REFUND LIABILITY AND THE PRESCRIPTION OF MAXIMUM PERMITTED RATES WHEREAS, the County of Contra Costa (the "County") has been certified by the Federal Communications Commission (the "Commission") to regulate rates for the Basic Service Tier ("BST") , associated equipment rates, and installation rates; and WHEREAS, the County provided written notice of said certification to Lencomm, Inc. , dba Bay Cablevision, Inc. (the "Operator") ; and WHEREAS, the County adopted procedural laws, and regulations applicable to rate regulation proceedings which provide a reasonable opportunity for consideration of the views of interested parties; and WHEREAS, the County delivered a written request to the Operator to file its schedule of rates for the BST, associated equipment and installation with the County; and WHEREAS, the Operator filed with the County FCC Forms 1220 and 1205 dated November 24, 1994 and March 31, 1995 (the "Cost of Service Forms") ; and WHEREAS, the County timely issued an order pursuant to Section 76.933 (b) of the Rules and Regulations (the "Rules") of the Commission stating that it was unable to determine based upon the materials submitted by the Operator that the existing or proposed rates were within the Commission's Maximum Permitted Rates and that the -County was tolling the thirty (30) day deadline found in Section 76.933 (a) of the Commission's Rules for the purpose of requesting and/or considering additional information for one hundred fifty (150) days; and WHEREAS, the County timely issued an Accounting Order pursuant to Section 76 .933 (c) of the Rules of the Commission requiring the Operator to keep an accurate account of all amounts received by the Operator by reason of the rates and charges for the Basic Service Tier, associated equipment and installation in effect from July 15, 1994 as found in the Cost of Service Forms and to keep full and accurate records indicating on whose behalf such amounts were paid; and WHEREAS, the County retained the services of Public Knowledge, Inc. ("PKI") to review the Cost of Service Forms; and WHEREAS, PKI produced a written report (the "PKI Report") to the County; and WHEREAS, the PKI Report concluded that the Maximum Permitted Rate for the Basic Service Tier, equipment and installation as contained in the Cost of Service Forms, exceeded appropriate amounts as calculated under the Rules of the Commission; and WHEREAS, the Operator disputes the conclusions of the PKI Report as they relate to the Maximum Permitted Rates; and WHEREAS, PKI concluded, without dispute from the Operator, that the Operator was charging equipment and installation rates higher than the Maximum Permitted Rates specified in the Cost of Service Forms; and WHEREAS, a public hearing was held upon the Cost of Service Forms on January 23, 1996 (the "Public Hearing") ; and WHEREAS, the Operator was given the opportunity to present evidence oral and written, in relation to its Cost of Service Forms and did so present evidence at the Public Hearing; and WHEREAS, the Public Hearing was closed and the County is now legally entitled to take final action upon the Cost of Service Forms; and NOW, THEREFORE, County does hereby order as of the date hereof, as follows: Section i_ The Maximum Permitted Rates and Charges for the rates subject to the jurisdiction of the County ("County Regulated Rates") are as indicated on Exhibit 1 to this Agreement. The Benchmark Adjustment Date shall be June 30, 1995 for the purpose of any future rate adjustment. section 2 _ The Operator shall identify all BST subscribers as of December 31, 1995 ("Subscribers of Record") in the Cities of Berkeley, El Cerrito, Richmond and Contra Costa County -2- (collectively the "Franchising Authorities") . The Operator shall pay to Subscribers of Record, by way of direct payment, credit, or refund and without offset or reduction for any alleged undercharge or underpayment of any rate whether or not the Operator is or may be entitled to offset any such refund liability pursuant to the Rules of the Commission, an aggregate refund of $300, 000 . 00 (the "Aggregate Refund") , as potentially adjusted pursuant to paragraph 8 of that Transfer Agreement, dated- as of January 23, 1996, among the Operator, the County, and Heritage Cablevision of Delaware, Inc. (the "Transfer Agreement") . The amount to be credited to individual subscriber accounts shall be computed as the Aggregate Refund divided by the number of Subscribers of Record. Application of said refund credits to Subscribers of Record shall be made over 30 days commencing no later than March 1, 1996 and ending no later than April 1, 1996 . The Operator shall provide to the County written evidence of compliance with the requirements of this provision no later than May 1, 1996 . Gention 3 The Operator shall adjust its existing rates for equipment and installation so as not to exceed the Maximum Permitted Rates for those items as reflected in Exhibit 1 within sixty (60) days of the Operative Date hereof as defined herein. S c ion 4 . This Rate Order shall bind any successor-in- interest to the Operator and shall be effective upon the Effective Date of the Transfer Agreement (the "Operative Date") . Rpntion S. Public notice shall be given of this decision by posting the attached notice in the County Administration Building and the text of this decision shall be released upon request to any interested member of the public, as required by Section 76 .936 (b) of the FCC Cable Regulations. Dated: January 23, 1996 ATTEST: Phil Batchelor, Clerk BOARD OF SUPERVISORS, COUNTY of the Board of Supervisors and OF CONTRA COSTA County Administrator ,,qq � By: By: Depipy Clerk a Chair -3- 'SENT BY:g1,-rAN & TUCKER 1-10-96 10:50 RUTAN & TUCKER- 15106464098;# 2/ 2 bl i SD. Z Exhlbk 1 Bay Cablevialon Munleq railOns Dam th Basic Rate(including fruchise fee} $12.35 Addressable Convartere 1.80 Non-Addreu#ble Convoftra 0.01 Remotes 0.11 irabdWitpn Rates: UnvAred h" 35.83 Pro-Mred hoffo 14.18 AddWanal connection of fimm of InIlfrai IrratMIMon 14.13 8sparate trip additlonai oannaction _ 21.20 E a:?Ja)Dfl.l. '8 NV-f.nN �E31LGif:in[[3 17:g !�Ei�Ili-,I�w. Ne1NDill 1t MV.IAX!kil ASU Commonwealth of Pennsylvania ) COUNTY OF On May. 1996, personally appeared before me, a Notary Public in and for the Commonwealth and County aforesaid, Harry F. Brooks, Vice President, and Samuel W. Morris, Jr., Secretary, of LenComm, Inc., personally known to me to be the persons whose names are subscribed to the above instrument in such capacities, who acknowledged that they executed the same. My commission expires: 1 AL] r tary Pu li Notarial seal Kimberly Ruth,Notary Public Pottstown Boro,Montgomery County My Commission FxpiresAug.11,1997 MOMberPennsTaniaAssociation of Notarkc, � TZ3 EMIT B WRITTEN DECISION OF THE COUNTY OF CONTRA COSTA (THE "COUNTY") RELATING TO CERTAIN REFUND LIABILITY AND THE PRESCRIPTION OF MAXIMUM PERMITTED RATES WHEREAS, the County of Contra Costa (the "County") has been certified by the Federal Communications Commission (the "Commission") to regulate rates for the Basic Service Tier ("BST") , associated equipment rates, and installation rates; and WHEREAS, the County provided written notice of said certification to Lencomm, Inc. , dba Bay Cablevision, Inc. (the "Operator") ; and WHEREAS, the County adopted procedural laws and regulations applicable to rate regulation proceedings which provide a reasonable opportunity for consideration of the views of interested parties; and WHEREAS, the County delivered a written request to the Operator to file its schedule of rates for the BST, associated equipment and installation with the County; and WHEREAS, the Operator filed with the County FCC Forms 1220 and 1205 dated November 24, 1994 and March 31, 1995 (the "Cost of Service Forms") ; and WHEREAS, the County timely issued an order pursuant to Section 76 . 933 (b) of the Rules and Regulations (the "Rules") of the Commission stating that it was unable to determine based upon the materials submitted by the Operator that the existing or proposed rates were within the Commission's Maximum Permitted Rates and that the -County was tolling the thirty (30) day deadline found in Section 76 . 933 (a) of the Commission's Rules for the purpose of requesting and/or considering additional information for one hundred fifty (150) days; and WHEREAS, the County timely issued an Accounting Order pursuant to Section 76 .933 (c) of the Rules of the Commission requiring the Operator to keep an accurate account of all amounts received by the Operator by reason of the rates and charges for the Basic Service -Tier, associated equipment and installation in effect from July 15, 1994 as found in the Cost of Service Forms and to keep full and accurate records indicating on whose behalf such amounts were paid; and WHEREAS, the County retained the services of Public Knowledge, Inc. ("PKI" ) to review the Cost of Service Forms; and WHEREAS, PKI produced a written report (the "PKI Report") to the County; and WHEREAS, the PKI Report concluded that the Maximum Permitted Rate for the Basic Service Tier, equipment and installation as contained in the Cost of Service Forms, exceeded appropriate amounts as calculated under the Rules of the Commission; and WHEREAS, the Operator disputes the conclusions of the PKI Report as they relate to the Maximum Permitted Rates; and WHEREAS, PKI concluded, without dispute from the Operator, that the Operator was charging equipment and installation rates higher than the Maximum Permitted Rates specified in the Cost of Service Forms; and WHEREAS, a public hearing was held upon the Cost of Service Forms on January 23, 1996 (the "Public Hearing") ; and WHEREAS, the Operator was given the opportunity to present evidence oral and written, in relation to its Cost of Service Forms and did so present evidence at the Public Hearing; and WHEREAS, the, Public Hearing was closed and the County is now legally entitled to take final action upon the Cost of Service Forms; and NOW, THEREFORE, County does hereby order as of the date hereof, as follows : RectIan 1 The Maximum Permitted Rates and Charges for the rates subject to the jurisdiction of the County ("County Regulated Rates") are as indicated on Exhibit 1 to this Agreement. The Benchmark Adjustment Date shall be June 30, 1995 for the purpose of any future rate adjustment. section 2— The Operator shall identify all BST subscribers as of December 31, 1995 ("Subscribers of Record") in the Cities of Berkeley, E1 Cerrito, Richmond and Contra Costa County -2- (collectively the "Franchising Authorities") . The Operator shall pay to Subscribers of Record, by way of direct payment, credit, or refund and without offset or reduction for any alleged undercharge or underpayment of any rate whether or not the Operator is or may be entitled to offset any such refund liability pursuant to the Rules of the Commission, an aggregate refund of $300, 000 . 00 (the "Aggregate Refund") , as potentially adjusted pursuant to paragraph 8 of that Transfer Agreement, dated as of January 23, 1996, among the Operator, the County, and Heritage Cablevision of Delaware, Inc. (the "Transfer Agreement" ) . The amount to be credited to individual subscriber accounts shall be computed as the Aggregate Refund divided by the number of Subscribers of Record. Application of said refund credits to Subscribers of Record shall be made over 30 days commencing no later than March 1, 1996 and ending no later than April 1, 1996 . The Operator shall provide to the County written evidence of compliance with the requirements of this provision no later than May 1, 1996 . Section 3 . The Operator shall adjust its existing rates for equipment and installation so as not to exceed the Maximum Permitted Rates for those items as reflected in Exhibit 1 within sixty (60) days of the Operative Date hereof as defined herein. Section 4 . This Rate Order shall bind any successor-in- interest to the Operator and shall be effective upon the Effective Date of the Transfer Agreement (the "Operative Date") . Section 5 . Public notice shall be given of this decision by posting the attached notice in the County Administration Building and the text of this decision shall be released upon request to any interested member of the public, as required by Section 76 . 936 (b) of the FCC Cable Regulations . Dated: January 23, 1996 ATTEST: Phil Batchelor, Clerk BOARD OF SUPERVISORS, COUNTY of the Board of Supervisors and OF CONTRA COSTA County Administrator By: By: ,54-uty Clerk P�a(dl-4 Chair -3-