Washington Post 2012 Annual Report Download - page 32

and terminating such traffic can have a profound and material effect on the profitability of providing voice and Internet
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.
Customer Proprietary Network Information (CPNI). In 2007, the FCC adopted rules expanding the protection of
CPNI and extending CPNI protection requirements to providers of interconnected VoIP service. CPNI is information about
the quantity, technical configuration, type, location and amount of a voice customer’s use. These requirements generally
have increased the cost of providing interconnected 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. The FCC also has adopted reporting requirements
associated with disability access obligations. Cable ONE and other interconnected VoIP service providers must also
contribute to the interstate Telecommunications Relay Service Fund to support such access. These requirements generally
have had the effect of increasing the cost of providing VoIP services.
Service Discontinuance and Outage Obligations. In 2009, the FCC adopted rules subjecting providers of
interconnected VoIP services to the same service discontinuance requirements applicable to providers of wireline
telecommunication services. In 2012, the FCC adopted mandatory outage reporting requirements for interconnected VoIP
service providers, which apply when customers of interconnected VoIP service lose service or connectivity and, as a result,
are unable to access 911 service. Along with other FCC actions described in this section, which impose legacy telecom
obligations on interconnected VoIP providers, this development will subject the Company’s interconnected VoIP services to
greater regulation and thus greater burdens and costs.
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. In 2012, the FCC initiated a proceeding to reform the regulatory fee regime in light of marketplace changes.
Certain of the proposals could affect the regulatory fee burden on providers of interconnected VoIP service, but the
Company cannot predict when or the extent to which the FCC will adopt new rules.
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.
Regulatory Reform. The FCC recently initiated proceedings to address requests to end or alter regulation of certain
traditional telecommunications networks. The requests ask the FCC to take a variety of actions to change the nature and
manner in which these networks are regulated. The issues raised in these requests are driven in part by changes in
technology. The Company cannot predict whether or to what extent the FCC will act on these requests, or how that will
affect the Company’s business.
Newspaper Publishing
The Company’s newspaper publishing operations include results for its flagship newspaper and Internet site, The
Washington Post, 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 (the Post) and the
Internet site, washingtonpost.com.
The Post 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 61% and 36% of its total revenue in 2012, respectively.
20 THE WASHINGTON POST COMPANY