In its comments, CDD expressed the importance of addressing a full range of issues connected with multi-channel video franchises:
We welcome this opportunity to comment on the commission's proposed implementation of Section 621(a)(1) of the Communications Act of 1934, as amended, not because we believe that there are a significant number of instances of local franchising authorities "… unreasonably refus[ing] to award an additional competitive [video] franchise,” but rather because of the larger issues that the proposed rulemaking raises. These issues include local authority, localism,broadband deployment, network neutrality, and community media, all of which must be included, we are convinced, within the scope of the commission's present inquiry.
In light of the very real threat to communities' longstanding right to negotiate video franchises that reflect the needs and interests of their residents, CDD's filing underscored the importance of preserving this vital aspect of local democracy:
Cable franchise agreements, clearly, are unique social pacts. More than merely a license for companies to dispense multi-channel video and other services, these documents are crafted with specific community needs and interests in mind. As such, these agreements also contain the building blocks for a genuine community media movement, one that places the power of broadcast and digital technologies in the hands of individuals and nonprofit organizations normally excluded from the market-driven mainstream media.
Failure to ensure meaningful local governance in multi-channel broadband networks will seriously deprive the public of the ability to benefit from advanced communications. It will set back the commission's own goal of promoting localism, reduce diverse sources of programming, and remove one of the last democratically oriented principles of electronic media governance.