Cablevision 2014 Annual Report Download - page 18

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issued in February 2015. The FCC has announced that those rules will prohibit providers of broadband Internet access service
from blocking lawful content, applications, services, or nonharmful devices, subject to reasonable network management as defined
by the rules; from impairing or degrading lawful Internet traffic on the basis of content, applications, services, or non-harmful
devices; from favoring some lawful Internet traffic over other lawful traffic in exchange for consideration; and from prioritizing
content and services of their affiliates. The new rules will also create a general Open Internet conduct standard that broadband
Internet access providers cannot harm consumers or edge providers, and will impose greater transparency requirements.
Access For Persons With Disabilities. FCC rules require us to ensure that persons with disabilities have access to "advanced
communications services" ("ACS"), such as electronic messaging and interoperable video conferencing. They also require that
certain video programming delivered via Internet Protocol include closed captioning and require entities distributing such
programming to end users to pass through such captions and identify programming that should be captioned.
Other Regulation. Currently, the Federal Cable Act's limitations on our collection and disclosure of cable subscribers' personally
identifiable information also apply with respect to broadband Internet access service provided by cable operators. In addition, our
provision of Internet services also subjects us to the limitations on use and disclosure of user communications and records contained
in the Electronic Communications Privacy Act. Broadband Internet access service is also subject to other federal and state privacy
laws applicable to electronic communications. As noted above, Congress, the Federal Trade Commission and other lawmakers
and regulators are all considering whether to adopt additional measures that would govern the collection, use, and disclosure of
subscriber information in connection with the delivery of advertising to consumers that is customized to their interests. Additionally,
providers of broadband Internet access services must comply with the Communications Assistance for Law Enforcement Act
("CALEA"), which requires providers to make their services and facilities accessible for law enforcement intercept requests.
Various other federal and state laws apply to providers of services that are accessible through broadband Internet access service,
including copyright laws, telemarketing laws, prohibitions on obscenity, and a ban on unsolicited commercial e-mail, and privacy
and data security laws. Online content we provide is also subject to some of these laws.
Other forms of regulation of high-speed Internet access service currently being considered by the FCC, Congress or state legislatures
include consumer protection requirements; additional privacy and data security obligations, cyber security requirements; consumer
service standards; requirements to contribute to universal service programs; and requirements to protect personally identifiable
customer data from theft.
VoIP Services
The regulatory obligations of VoIP services are the subject of periodic examination and review by the FCC, Congress, and state
public service commissions. In 2004, for instance, the FCC initiated a generic rulemaking proceeding concerning the legal and
regulatory implications of IP-based services, including VoIP services. Also in 2004, the FCC determined that VoIP services with
certain characteristics are interstate services subject to federal rather than state jurisdiction and preempted conflicting state laws.
The FCC's determination was upheld by a federal court of appeals, although the court found that the FCC's order did not squarely
address the classification of cable-provided VoIP services. While the FCC has not concluded its generic rulemaking proceeding,
it has applied some regulations to VoIP service providers that exchange traffic with traditional telephone carriers like Verizon (these
services are known as "interconnected VoIP services"). Some states have asserted the right to regulate cable VoIP service, while
others have adopted laws that bar the state commission from regulating VoIP service.
Universal Service. Interconnected VoIP services must contribute to the federal universal service fund ("USF") used to subsidize
voice services provided to low income households, and voice and broadband services to rural and high cost areas, and other
communications services provided to schools, libraries, and rural health care providers. The amount of universal service
contribution required of interconnected VoIP service providers is based on a percentage of revenues earned from interstate and
international services provided to end users. We allocate our end user revenues and remit payments to the universal service fund
in accordance with FCC rules. The FCC has ruled that states may impose state universal service fees on certain types of VoIP
providers, which may include cable VoIP providers. States in which we operate have not imposed universal service fund
contributions for VoIP providers. In October 2011, the FCC adopted an order that fundamentally revised its federal universal
service fund programs to transition support to broadband networks and services, as well as voice services provided over broadband.
That order was upheld by the U.S. Court of Appeals for the 10th Circuit, though certain parties have requested a writ of certiorari
for parts of the 10th Circuit order to the U.S. Supreme Court.
Local Number Portability. The FCC requires interconnected VoIP service providers and their "numbering partners" to ensure that
their customers have the ability to port their telephone numbers when changing providers to or from the interconnected VoIP
service. The FCC also has clarified that local exchange carriers and commercial mobile radio service providers have an obligation