HomeMy WebLinkAbout1999-07-26 City Council (15)C ty of Pal Alt
C ty Manager’s Report
STUDY SESSION
TO:HONORABLE CITY COUNCIL
FROM:CITY MANAGER DEPARTMENT: ADMINSTRATIVE
SERVICES
DATE:
SUBJECT:
JULY 26, 1999 CMR:314:99
CABLE CO-OP FRANCHISE RENEWAL AND TRANSFER OF
OWNERSHIP PROCESS
This is an informational report and no Council action is required.
BACKGROUND
In 1983, a Joint Exercise of Powers Agreement (JPA) was entered into by the
cities of Palo Alto, Menlo Park, East Palo Alto, the town of Atherton, and the
counties of Santa Clara and San Mateo for the purpose of obtaining cable service
for the residents, businesses and institutions within these jurisdictions. Also, the
JPA members granted the City of Palo Alto the authority to administer and
coordinate the activities of the franchise and to act on behalf of the JPA. In 1986, a
franchise agreement was executed with Cable Communications Cooperative of
Palo Alto, Inc., (Cable Co-op).
The franchise agreement between the City, representing the JPA, and Cable Co-op
expires on March 24, 2001. During the period that begins thirty-six months prior
to the expiration of the franchise, Cable Co-op may request the City to commence
proceedings to determine whether or not to renew the franchise. On July 20, 1998,
Cable Co-op requested the City to commence renewal proceedings, and the
Council agreed to begin proceedings with its adoption of a resolution in September
1998.
After this request, in late April 1999, Cable Co-op announced that its Board of
Directors had approved a letter of intent to sell the cable system to AT&T
Broadband and Internet Services (AT&T). Currently, it is not known when the
Cable Co-op Board will finalize an agreement with AT&T and vote to approve the
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sale. According to news reports, the Board is currently scheduled to consider the
AT&T offer on August 3. If the Board and shareholders approve the sale to
AT&T, City staff would expect to receive Cable Co-op’s formal request (a
completed transfer application on Federal Communications Commission Form
394) to transfer the franchise and the ownership of the cable system to AT&T.
The franchise agreement stipulates that, prior to any change in ownership of Cable
Co-op, the City Council must approve the change.
DISCUSSION
A transfer of ownership and the renewal of a cable franchise agreement are
processes governed by Federal and State law, and by the current franchise
agreement. Both processes share a similar objective, to ensure the provision of
cable services that meet the programming needs of the majority of the community
at a fair price. However, the two processes differ in some of the procedures that
must be followed and in the timeframes involved. The renewal process is a
lengthy one, and has already been initiated by Cable Co-op even though the
franchise agreement will not expire until March 24, 2001. In contrast, the transfer
process has a much shorter time line. In addition, the transfer process involves a
decision regarding whether or not to exercise the right of first refusal. Both of
these processes, including the right of first refusal, are discussed in more detail
below.
Renewal Process
Due to the evolving nature of the cable industry, the franchise renewal process
offers an opportunity to do more than shape the local cable system. Because cable
now includes the ability to deliver voice and data, as well as video
communications, the franchise renewal process provides an opportunity to
undertake a community-wide communications planning process. The City will
strive to structure a franchise agreement that meets local telecommunications
infrastructure and service needs into the future. The franchise renewal process
also offers an opportunity for the City to ensure that the cable operator is paying
adequate rent (in the form of franchise fees) for the use of the pubic right of way.
The cable franchise renewal process involves an examination of the past
performance of Cable Co-op, including analyzing how well it has complied with
the current franchise agreement; an exploration of future community
telecommunication needs and interests; and actual negotiations for a new
franchise. Most franchise agreements are reached without the issuance of a formal
request for proposals and take approximately 18 to 24 months to complete. If the
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issuance of a formal request for proposals is necessary, it can add an additional
nine months to a year to the renewal process.
In order to proceed with the franchise renewal process, the City has retained the
services of a cable communications consultant. After conducting a competitive
proposal process, in June 1999, the Council awarded a contract to The Buske
Group. The Buske Group has assembled a cable communications consulting team
that includes respected individuals in the areas of cable television refranchising,
cable regulation and policy, engineering, financial analysis, survey research, and
public, educational and government (PEG) access management. The City has also
contracted with a law firm that specializes in cable communications law. A
working group comprised of staff from the City Clerk’s Office, the City
Attorney’s Office, and City Manager’s Office, including the Director of
Administrative Services and the Director of Utilities, has been established to
oversee the efforts of the consulting team. The City is currently in the first stage
of the renewal process.
The objective of Phase One of the renewal process is to develop a renewal plan
and timeline, and to ensure that the process and the applicable laws and
regulations are understood by City staff, elected officials, and key members of the
community. As a part of this effort, The Buske Group will review current
governing documents and franchise agreements from comparable cities. This
stage should be completed in the fall of 1999.
Phase Two establishes the basis upon which the City will negotiate a franchise
renewal or a new agreement. An overall review of the Cable Co-op’s past
performance is conducted. This review encompasses a technical audit of the cable
system, including an assessment of the physical and electrical plant, and will take
several months, beginning in the fall of 1999. The Buske Group’s team of
technical experts in this area will assist in this process.
Phase Two also includes an evaluation of the past performance of Cable Co-op,
including its compliance with the existing franchise and franchise fee provisions; a
review of customer service standards and consumer complaints; and a review of
current public, educational, and government PEG access resources and services.
In addition, future community cable-related needs and interests will be identified,
using surveys, focus group workshops, and public hearings. The Buske Group
will provide expertise in the of areas of surveying methods and needs assessment.
This part of the review will take longer, up to twelve months, but will occur at the
same time as the technical review.
Phase Three builds upon the information gathered in Phase Two. After the review
of past performance and the needs assessment are completed, the City will
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establish its desired outcomes for the renewal process. Typically, the desired
outcomes fall within the following areas: cable system upgrades/rebuild;
contributions of television channels, facilities, and equipment for public,
educational and government access; an institutional network to link schools,
libraries, and government buildings; and franchise fees. Federal law also permits
the City to identify requirements for cable system capacity, functionality, and
customer service. During this phase the City will identify its franchise renewal
outcomes (goals), develop a renewal strategy, and conduct actual renewal
negotiations. A model franchise agreement and enabling ordinance would also be
drafted. The renewal negotiations can be expected to take several months. Once a
new franchise agreement has been negotiated, the City will provide the community
with an opportunity to comment on the agreement before it is finally granted.
If a renewal agreement cannot be reached through informal negotiations, the City
would issue a formal request for proposal. The formal proposal and negotiations
process involves set procedures, time schedules, and established criteria for denial
of a renewal. The City would utilize the information that has already been
gathered (e.g., the assessment of community-wide telecommunication needs and
interests) in support of the formal proposal process, should it be initiated. The
formal proposal process can take up to one year to complete.
The City may deny Cable Co-op’s request for renewal only if one or more of the
following applies:
¯substantial noncompliance with the terms of the existing franchise agreement
¯service quality has not been reasonable in light of community needs
¯lack of financial, legal and technical ability to provide the services, facilities
and equipment
the proposal does not meet the cable-related community needs and interests,
taking into consideration the cost of meeting such needs
Transfer Process
The City’s review of the proposed transfer of the franchise to AT&T will be
initiated when Cable Co-op formally requests the City’s approval of a transfer of
the franchise and cable system ownership. This is accomplished through the
submission of a transfer application on Federal Communications Commission
(FCC) Form 394, along with supporting documentation. The documentation
should include sufficient detail to enable the City to review and evaluate the
transfer and to exercise its reasonable judgment with respect to the transfer. Under
FCC rules, the City has 30 days to notify Cable Co-op concerning any questions
related to the transfer application and supporting documentation, including
questions regarding the accuracy and completeness of the information provided.
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After ensuring the transfer application is complete, the City would begin its review
of the transfer request with a primary focus on ensuring that the transfer benefits
the community. The franchise was originally granted to Cable Co-op based upon
its unique ability to provide the services desired by JPA members and the City has
the discretion to deny the transfer if it poses a risk that the community will not
receive what it anticipated when it selected Cable Co-op. The City would inquire
into the qualifications of AT&T to ensure that it has the ability to meet the City’s
cable service requirements. The City would utilize consulting services provided
by The Buske Group to perform a review of Cable Co-op’s transfer application,
with specific focus on the technical and financial qualifications of AT&T. The
City’s law firm would conduct a legal review of the transfer application. An
evaluation would also be conducted to identify any areas of noncompliance with
the existing franchise agreement, either in the past or currently.
After conducting its review of the transfer request, the City would draft a consent
to transfer agreement. As part of this agreement, AT&T would be required to
assume all of the terms and conditions, and the responsibilities of the Cable Co-op.
For example, AT&T would be responsible for complying with all provisions in the
franchise agreement related to PEG access, maintaining the extensive local
programming provided by Mid-Peninsula Access Corporation (MPAC). In
addition, the City would require AT&T to maintain Cable Co-op’s current service
offerings not detailed in the franchise agreement (e.g., cable modem services). The
City would also expect AT&T to assume responsibility for any areas of non-
compliance with the existing franchise agreement, both known and unknown.
Federal law requires the City to determine whether to grant or deny the transfer
within 120 days of receipt of a completed transfer application which includes the
information required by the City. Under Federal law, if the City does not act
within 120 days, the transfer request will be considered approved.
The franchise agreement appears to provide 90 days for a review of the transfer
application. In addition, under the franchise agreement, within 15 days from
receipt of a completed transfer application, the City Manager must submit it to the
City Council with a recommendation for action. A public hearing must be
scheduled within 30 days of receipt of the transfer application, and the City
Council must act within 60 days after the public hearing. Both Federal law and
the franchise agreement allow both parties to agree to an extension. During the
transfer process, the City will work with Cable Co-op, as necessary, to reconcile
any time issues if there is insufficient time to render a decision.
Applicable law provides a basis for denial of a transfer request. A franchising
authority may deny the transfer request based on the buyer’s unique financial,
legal, technical, and character qualifications, and its ability to provide the required
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cable service. A franchise authority also may deny a transfer request if the buyer
owns or controls another cable system in the cable franchise area or if the
proposed transfer would eliminate or reduce competition in the delivery of cable
service.
Right of First Refusal
The franchise agreement grants the City the right of first refusal provided the City
exercises this option within 90 days after it receives the formal notice of the
transfer and the detailed terms and conditions of sale. This provides the City the
right to acquire the franchise under the same terms and conditions agreed to by
Cable Co-op and AT&T. The City would have to match the agreement between
Cable Co-op and AT&T in all respects. In addition, the City would assume the
financial and operational risks and responsibilities inherent in providing cable
services and managing the cable system.
Finally, if the City were to exercise the right of first refusal, it would be doing so
on behalf of the City itself and not on behalf of the Joint Powers Agencies. This
means the City would pay Cable Co-op the entire monetary consideration, and no
contributions from the Joint Powers Agency members would be made. Each Joint
Powers Agency member then has 90 days in which to decide whether or not to
terminate its participation in the Joint Powers Agreement.
RESOURCE IMPACT
The City’s franchise revenues totalled $345,000 in calendar year 1998; of this, the
City contributed approximately $153,000 to local programming provided by
MPAC.
The City has entered into an agreement with The Buske Group in the amount of
$102,250 for cable consulting services. In addition, the City has contracted with a
law firm in the amount of $30,000 for legal support during the transfer and
renewal processes. Also, significant staff support is being provided by the
Administrative Services Department and the City Attorney’s Office, and it is
anticipated that staff will request funding in the future to backfill for a Senior
Financial Analyst and a Senior Assistant City Attorney. Should a formal request
for proposal become necessary, staff will request Council approval for an
additional $15,300 for consultant support services.
The total costs for the franchise renewal proceedings will be shared among the
members of the JPA.
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POLICY IMPLICATIONS
During the renewal process, the City will utilize community focus groups to
evaluate the performance of the cable operator and to ascertain future community
related needs and interests. This is consistent with the goals in the Comprehensive
Plan regarding the use of advisory boards and ad hoc committees to assist City
staff" and the City Council on policy issues (Goal G-1, Policy G-2).
A key policy implication inherent in the transfer process involves the transfer of
the franchise from a locally controlled company to a large multi-national
corporation. However, a loss of local control does not necessarily imply a loss of
local programming. As mentioned above, the City would require that AT&T
assume all of the terms, conditions, and responsibilities of the current agreement,
including all provisions related to public, educational, and government access and
programming.
Also, although the loss of local control is an important concern for the community,
there may be potential benefits to the community in the sale to AT&T, including:
immediate access to capital for investment in infrastructure, facilities and other
resources; access to strategic alliances which could broaden service offerings; and
long-term stability in the provision of cable services.
During the transfer process, a policy decision also must be made regarding
whether or not the City should exercise the right of first refusal. In prior
discussions, the City Council has indicated that it does not wish to acquire Cable
Co-op nor to become a cable provider. Most recently, in February 1998, when
Cable Co-op asked the City Council to help create a new joint powers authority,
the Silicon Valley Communications Authority, the Council vetoed a motion
directing staff to conduct a preliminary legal assessment of the viability of the
venture. Individual Council members indicated that they preferred the private
sector to undertake the risks inherent in a rapidly changing and technologically
complex field.
TIMELINE
The expected timeline for the franchise renewal process is provided in the
following table.
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Phase
Phase One
Phase Two
Phase Three
Purpose
Development of renewal plan and timeline:
Educate City staff, elected officials and
community leaders about renewal and
cable issues.
¯Review current governing documents.
¯Review franchise agreements in
comparable cities.
Review Cable Co-op’s past performance and
future needs and interests:
¯Technical audit of cable system.
¯Compliance with existing franchise
agreement and franchise fee provisions.
Review of customer service standards
and consumer complaints.
Review of current PEG access resources
and services.
, Identify future community cable-related
needs and interests.
Identification of renewal goals, development
of renewal strategy, and renewal
negotiations.
Draft model franchise agreement and
ordinance.
Timing
July-September 1999
September 1999-
September 2000
September -
December 2000
PREPARED BY:Melissa Cavallo, Assistant Director
Shannon Gaffney, Senior Financial Analyst
REVIEWED BY: Grant Kolling, Senior Assistant City Attorney
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DEPARTMENT HEAD:
of Admini Services
CITY MANAGER APPROVAL:
ity Manager
Mr. Russell Averhart, Director of Administrative Services,
City of East Palo Alto
Mr. Walter Callahan, Deputy Director, Public Works, San Mateo County
Ms. Uma Chokkalingam, Finance Director, City of Menlo Park
Ms. Jan Dolan, City Manager, City of Menlo Park
Mr. Don Guluzzy, City Manager, Town of Atherton
Ms. Monika Hudson, City Manager, City of East Palo Alto
Mr. John Maltbie, County Executive, County of San Mateo
Ms. Jan Thomson, Stanford University
Ms. Salani Wendt, City Clerk, City of East Palo Alto
Mr. David Wheaton, Asst. City Manager, City of Menlo Park
Mr. Richard Wittenberg, County Executive, County of Santa Clara
The Buske Group
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