Washington Post 2009 Annual Report Download - page 26

Emergency 911 Services. The FCC has ruled that an interconnected VoIP provider that enables its customers to make
calls to and from persons who use the public switched telephone network must provide its customers with the same
enhanced 911 (“E911”) features that traditional telephone and wireless companies are obligated to provide. This
requirement was upheld on appeal. The FCC is currently assessing whether additional rules related to the provision of
E911 services by interconnected VoIP service providers should be adopted.
CALEA. FCC regulations require providers of interconnected VoIP service to comply with the requirements of CALEA,
which requires covered carriers and their equipment suppliers to deploy equipment that law enforcement officials can
access readily for lawful wiretap purposes.
Universal Service. The FCC has determined that interconnected VoIP service providers must contribute to the universal
service fund. The amount of a company’s universal service fund contribution is based on a percentage of revenues earned
from end-user interstate and international services. This percentage figure changes from time to time and generally has
been increasing, prompting Congress and the FCC to consider ways in which the universal service fund and the payment
obligations of fund contributors should be reformed. Cable One cannot predict whether and how such reform will occur
and the extent to which it may affect providers of VoIP services, including Cable ONE.
Intercarrier Compensation. The FCC is considering various proposals designed to reform the manner in which
providers of telecommunications and VoIP services compensate one another for transporting and terminating various forms
of network traffic. FCC determinations regarding the rates, terms and conditions for transporting and terminating such
traffic can have a profound and material effect on the profitability of providing voice and data services. It is not possible
to predict what actions the FCC might take in this area or the effect that they will have on Cable ONE.
CPNI. In 2007, the FCC adopted rules expanding the protection of customer proprietary network information (“CPNI”)
and extending CPNI protection requirements to providers of interconnected VoIP. CPNI is information about the quantity,
technical configuration, type, location and amount of a phone customer’s use. These requirements generally have
increased the cost of providing VoIP service, as providers now must implement various safeguards to protect CPNI from
unauthorized disclosure.
Access for Persons With Disabilities. FCC regulations require providers of interconnected VoIP services to comply with
all disability access requirements that apply to telecommunications carriers, including the provision of telecommunications
relay services for persons with speech or hearing impairments. These requirements generally have had the effect of
increasing the cost of providing VoIP services.
Regulatory Fees. The FCC requires interconnected VoIP service providers to contribute to shared costs of FCC
regulation through an annual regulatory fee assessment. These fees have increased Cable ONE’s cost of providing VoIP
services.
Local Number Portability. Providers of interconnected VoIP services and their “numbering partners” must ensure that
their subscribers have the ability to port their telephone numbers when changing service providers, and local exchange
carriers and commercial mobile radio service providers must port numbers that they control to an interconnected VoIP
service provider upon a valid port request. Cable ONE, along with other providers of interconnected VoIP service, must
contribute funds to cover the shared costs of local number portability and the costs of North American Numbering Plan
Administration. The FCC currently is considering whether additional numbering requirements (such as allowing consumers
access to abbreviated dialing codes like 211 and 311) should be applied to interconnected VoIP service providers.
Although consumers’ ability to port their existing telephone numbers to interconnected VoIP service has created additional
opportunities for Cable ONE to gain voice customers, the local number portability and associated rules overall have had
the effect of increasing the cost of providing VoIP service.
Newspaper Publishing
The Company’s newspaper publishing operations include results for its flagship newspaper, The Washington Post, its
website, washingtonpost.com, The Slate Group and a number of additional newspapers and websites.
The Washington Post
WP Company LLC (“WP Company”), a subsidiary of the Company, publishes The Washington Post, which is a morning
daily and Sunday newspaper primarily distributed by home delivery in the Washington, DC, metropolitan area, including
large portions of Maryland and northern Virginia. The Post’s two primary sources of revenue are advertising and
subscription fees, which accounted for 68% and 29% of its total revenue in 2009, respectively. Advertising revenue is
derived from the sale of display and classified advertisements, as well as the insertion of preprinted advertisements.
The following table shows the average paid daily (including Saturday) and Sunday circulation of the Post for 52-week
periods ended September 30, 2007 and September 28, 2008, as reported by the Audit Bureau of Circulations (“ABC”)
12 THE WASHINGTON POST COMPANY