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HomeMy WebLinkAboutCM Comcast Low Income DiscountsarroF 5� Agenda Item No: 18
�++'' f+ Meeting Date: July 6, 2009
SAN RAFAEL CITY COUNCIL AGENDA REPORT
Department: CITY MANAGER
Prepared by: Ken Nordhoff, City Manager Approval:
SUBJECT: CONSIDERATION OF POLICY REGARDING LOW INCOME DISCOUNTS
FOR COMCAST SUBSCRIBERS
RECOMMENDATION: Provide policy direction to San Rafael MTA representative Vice -Mayor
Heller regarding implementation of discounted cable subscription rates for
eligible low income residents.
BACKGROUND:
MTA serves as the governing body which oversees cable franchise services, provided via
Comcast, for all customers throughout Marin, except in Novato. At the June 15, 2009 City
Council meeting, Vice -Mayor Heller, who serves as the City of San Rafael representative on the
Marin Telecommunications Agency (MTA), presented some information during the Council
member time on that agenda regarding discount rates for Comcast customers. The City
Council directed staff to place this item on a future agenda for discussion and policy direction.
MTA plans to take formal action on this matter in the coming months.
ANALYSIS:
For some time, MTA has deliberated on the ideas of offering lower cable service subscription
rates for Comcast customers. Attached to your staff report are:
✓ A memo from Vice Mayor Heller, summarizing the cost impacts to San Rafael via loss of
franchise fees if this program were approved by MTA
✓ A staff report from the Executive Director, and separate report from MTA Board member
Bragman, outlining the scope of the Comcast discount program, including costs, lost
revenues, program eligibility, administrative oversight, etc. These reports were part of the
MTA June 10, 2009 agenda
✓ An older MTA report from the prior executive director of MTA on this same subject.
FOR CITY CLERK ONLY
File No.:
Council Meeting:
Disposition:
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 2
San Rafael represents about 29% of the subscribers in the MTA franchise area. Total MTA
franchise fees are estimated to be $3.1 million for fiscal year 2009-10. Our share of these
General Fund revenues is about $900,000. Franchise fees are unrestricted revenues which pay
for essential services, such as police, fire protection, parks maintenance, etc.
As a MTA member, we are obligated to pay for our share of the Agency's operations, which will
be $121,204 for this fiscal year.
FISCAL IMPACT:
From the documents attached, the proposed MTA discount pilot program does not identify the
source of funding to pay for this new initiative, nor the final cost. Absent other sources, a
lowering of cable fees to any class of customers would reduce the overall pool of annual
franchise revenues available for distribution. Given the expected low levels of participation (as
measured against the total subscribers), franchise fee loss is estimated to be limited to several
thousand dollars per year (inclusive of any administrative costs required to run this program).
ACTION REQUIRED:
Discuss the Comcast low income subscriber program and provide direction to the San Rafael
MTA representative, who will be making a determination on the merits of this program at an
upcoming MTA meeting.
ATTACHMENTS
WACity Managers- WorkRe\Council Material\Staff Reports\09\MTA Comcast discounts.doc
Monday, June 15, 2009
To: San Rafael City Council
From: Barbara Heller
Re: Marin Telecommunications Agency
Two Items to report on the Marin Telecommunications Agency.
First, MTA's FY2009 Franchise Fee and interest Revenues are larger than budgeted for, by
$105,544 and the member agencies are receiving these additional revenues.
The FY2009 budget will also be enhanced by lower expenses in the Professional Services
Account by approximately $79,000. These budget under run amounts will be carried forward
and will decrease MTA member Agency payments for the FY 09/10 Operating Budget.
Second, The new Comcast Franchise Agreement approved in 2006 did not provide for a low
income discount. Comcast did agree to continue with their existing low income discount accounts,
however going forward, no additional customers would be given this discount.
Board Member, Larry Bragman (Fairfax) has been developing a program for a low income discount
for Comcast customers.
Such a discount has been discussed several times through the years, staffing and cost have always
been a concern of the Agency members.
Mr. Bragman has provided the Board with a memo describing a low income discount program, as
well as a proposal for a simplified method of processing applications and providing payments to
those who would qualify for the program.
Both Marin Center for Independent Living and the Marin Housing Authority have indicated that they
would be willing to help administer such a program. Proof of eligibility would be granted by the
agency, and once a year a voucher such as a Safeway gift card would be mailed to the low income
discount recipient.
The actual number of eligible participants is unknown. As is the MTA 's total time needed to assist in
administering the program, plus any legal costs. It is estimated the entire program might cost MTA
about $12,000 per year. San Rafael's share of an estimated cost of $12,000 annually would be
approximately $3,600 (29.8%).
A 2006 memo on this subject, noted that San Rafael had 150 low-income subscribers registered with
Comcast at that time. The 20% discount was $3.53 per month per customer.
San Rafael has 52,915 (29.8%) subscribers of a total of 181,962. (Novato is not a member of the
MTA, County of Marin is 27.31 %.)
IS SAN RAFAEL INTERESTED, IN CONCEPT, IN PURSUING THE LOW INCOME DISCOUNT
FOR OUR CITIZENS?
AGENDA ITEM J
MARIN TELECOMMUNICATIONS AGENCY
555 Northgate Drive, Suite 230, San Rafael CA 94903-3680
PHONE: (415) 448-0355
MEMORANDUM
DATE: June 10, 2009
TO: MTA Board of Directors /
FROM: Barbara Thornton, Executive Officer+'
SUBJECT: AGENDA ITEM J: LOW INCOME DISCOUNT
Recommended Action: Receive and consider the attached report from Board Member Bragman
regarding Low Income Discount and provide direction to staff.
Back rg ound:
The Low Income Discount is an issue that MTA has continued to consider since the approval of
the Comcast Franchise Agreement in June 2006. The new Comcast Franchise Agreement did
not provide for a low income discount for MTA Comcast customers going forward. A side letter
approved at the time made an allowance for existing low income discount customers to continue
with their existing low income discount, however, no further customers would be afforded the
low income discount going forward.
The low income discount issue has come to the MTA Finance and Policy Committee and the
MTA Board a few times for discussions regarding how to address providing a discount to
additional qualified customers beyond those that were grandfathered in June 2006. In May 2009
the Finance & Policy Committee discussed a possible low income discount program that Board
Member Bragman had been developing. The recommendation of the Committee was that Board
Member Bragman develop a memo for the MTA to consider at its June 2009 meeting.
Attached is Mr. Bragman's memo describing the low income discount program, as well as a
proposal for a simplified method of processing applications and providing payments to those
who would qualify for the program. In addition, a MTA staff Report presented to the Board in
July 2006 is attached. It details the low income discount program in place prior to the new
Comcast Franchise Agreement and elements to consider going forward for a MTA locally
administered low income discount program. At that time the cost and staff resources required to
administer a MTA offered low income discount program was a concern to the Board. Since that
time, staff and Mr. Bragman have researched alternative ideas to resolve those concerns. Mr.
Bragman's proposal for Board consideration is attached.
The current Comcast Basic 1 service (channels 2-34) is $15.43/month
Agendaltem_J_06-10-09-LowlnwmeDiswunt-bt.doo
AGENDA ITEM J
MARIN TELECOMMUNICATIONS AGENCY
555 Northgate Drive, Suite 230, San Rafael CA 94903-3680
PHONE: (415) 448-0355
MEMORANDUM
DATE: June 10, 2009
TO: MTA Board of Directors
FROM: Larry Bragman
SUBJECT: AGENDA ITEM J: LOW INCOME DISCOUNT
For many years up to the date of signing of our current cable franchise agreement with
Comcast in 2006, Marin County's cable television franchise agreement provided low income
subscribers with a significant discount on their basic cable television service. Under the terms of
our previous (1986) franchise agreement with Viacom, low income subscribers were broadly
defined to include low income elderly and disabled (SSI or SSDI) customers. These subscribers
were granted a 75% discount off their basic cable fees.
After the tern of the original franchise expired, it was renewed on a yearly basis
thereafter from about 1996 to 2006. During this time frame the discount was reduced by the
various companies that succeeded each other in operating the franchise. During the last days
leading up to the 2006 franchise agreement with Comcast, the Low Income Discount granted
was 20% off of the basic cable fee of $17.65. This amounted to $3.53 per month or $42.36
annually.
Unfortunately, as the negotiations wore to a conclusion, Comcast refused to budge on its
insistence in abandoning the low income discount as a condition of the current franchise
agreement. While MTA accomplished a great deal under the current franchise agreement by
way of funding our community media center, the INET and other beneficial terms, we were
unable to renew a contractual low income discount. As a compromise, Comcast did agree to
continue providing the discount to the 288 eligible subscribers who were then receiving the
benefit. New subscribers, or subscribers who became newly eligible under the guidelines, no
longer receive a low income discount from Comcast.
The historic importance of the Low Income Discount as a policy of the Marin County
cable television franchise is reflected in several policy statements made by the MTA Board of
Directors over the years. On February 6, 1999, the Board identified eight "major priorities for
the forthcoming TCI franchise renewal negotiations." Among those eight priorities was a
"Senior Discount (Life Line Rate)". Four and a half years later, in a "Priorities: Comcast
Franchise Renewal" memorandum adopted by the Board on November 12, 2003, low income'
discounts were again listed as a "franchise negotiation objective." More recently, as MTA's
Agendaltem_J_06-10-09-LowlncomeDiscountdoc
MTA Board of Directors
Agenda Item J: Low Income Discount
Page 2
negotiating team neared the long awaited completion of the 2006 franchise agreement with
Comcast, the Board of Directors vigorously sought renewal of a Low Income Discount.
Since 2006, our Board has revisited the low income discount on a number of occasions.
In a July 12, 2006 staff report, Low Income Discount program was discussed at some length.
The report found that the there were then 288 subscribers receiving the discount. The cost of the
program to the entire franchise was approximately $12,199.68 per year. (The cost may be less
now because of the shrinking size of services and cost of the basic tier). In analyzing what the
MTA could to continue the program, the staff found that agency management of the program
was problematic because of the cost of processing and mailing a monthly check to subscribers.
(I have attached a copy of this report for the Board's review and consideration). Comcast later
informed our staff that it would not assist in the administration of the Low Income Discount by
doing the intake or discounting the monthly bills of newly eligible subscribers. Thus, MTA has
been left to its own resources if it is to continue its historic commitment to the Low Income
Discount.
That there continues to be a significant community of subscribers that would benefit from
a Low Income Discount is evident from many different indicators. Many of the subscribers who
have historically received the low income discount are disabled or elderly and have very few
outside sources of entertainment and information. This is a growing demographic group in
Marin County. In addition, the current economic downturn is leading many subscribers to drop
their cable subscription in favor of internet viewing. More recently, Comcast dropped its bulk
rate agreement with the County of Marin for public housing facilities
Over the course of the last six months, I have met with various community members in
order to investigate the possibility of creating a new "user friendly" model for the Low Income
Discount. Both the Marin Center for Independent Living and the Marin Housing Authority have
both indicated that they would be willing to help administer a streamlined MTA low income
discount program. The MTA program would have similar eligibility guidelines: disabled
subscribers and low income subscribers. Proof of eligibility would be simplified to require that
subscribers present a current Comcast bill and documentation of their disability (yearly statement
from Social Security) of low income (residency in Marin Housing and best practices
documentation such as a PG&E lifeline bill for others) In order to avoid the necessity of mailing
out checks on a monthly or even yearly basis, both of these community providers agreed to
distribute yearly vouchers (such as Safeway gift cards) in lieu of a monthly discount payment.
The community providers would email the name and address of the new subscribers to MTA
which would maintain a master list of recipients in order to avoid inadvertent or intentional
duplication.
Both MCIL and Marin Housing have agreed to participate on a pilot basis to determine
whether the program was practical for them to operate. Marin Housing would incorporate the
program as part of their yearly renewal process. MCIL has agreed to participate at no fee in
order to serve its membership pending a determination of the volume of applications and the
time necessary to process them administratively. I would also hope that MTA itself consider
Agendaltem_ —06-10-09-LowlncomeDiscountdoc
MTA Board of Directors
Agenda Item J: Low Income Discount
Page 3
providing an outlet for subscribers at its new offices at 555 Northgate Drive during specified
hours. If there is Board approval of this proposal, I would continue to work with staff and our
community partners to create simplified rules of eligibility documentation and administration.
We would also begin outreach to local merchants to determine which ones would be willing to
help issue vouchers. Safeway, Whole Foods, Good Earth come to mind but others may want to
join in.
I am hoping that the Board will approve the proposed pilot program to renew and fulfill
MTA's historic commitment to the Low Income Discount.
Respectfully submitted,
Larry Bragman
Agendaltem_J_06-10-09-LowlncomeDiscountdoc
MARIN TELECOMMUNICATIONS AGENCY
27 Commercial Blvd., Suite C, Novato, CA 94949
Phone: (415) 883-9100 FAX: (415) 883-9155
MEMORANDUM
DATE: July 12, 2006
TO: MTA Board of Directors
FROM: Martin J. Nichols, Executive Officer
SUBJECT: AGENDA ITEM J: LOCALLY ADMINISTERED CABLE TV LOW-INCOME
DISCOUNT
Recommended Action: Receive report on a locally administered cable TV low-income discount
and authorize staff to determine if Comcast will administer the program and request the General
Counsel to review and report on potential legal issues associated with implementing an agency
administered program.
Background:
Under the terms of our Comcast franchise, the low-income discount will continue for only these
individuals currently eligible and enrolled. Your Board requested a staff report on a potential
locally run program for new low-income subscribers.
From Comcast, we have received the following information:
A. Total subscribers that qualify — 288 low-income discount customers
B. Comcast qualifications for low-income discount:
1) Must have an active cable service
2) Must be the head of a household and 18 years or older (must provide a copy of a
driver's license or state ID) and receive benefits from one of the following:
• SSI -supplemental Social Security Income
• SSDI-Social Security Disability Income
3) Customer must provide a copy of the Benefit Verification Letter from the Social
Security Administration. If customer qualified, Comcast sends the information to its
Credit and Collections Department located in Livermore.
Memo BOD Agenda Item_J 07-121.ocallyAdministrdCableTVLowlncomeDscnt.doc
MTA Board of Directors
Agenda Item J: Locally Administered Cable TV Low -Income Discount
July 12, 2006
Page 2
C. Amount of discount
The 20 percent discount only applies to the current basic rate of $17.65. The 20 percent
discount services for qualifying subscribers is $3.53 per month.
D. Low-income subscribers by jurisdiction
City of San Rafael
150
County of Marin
40
Town of Corte Madera
6
City of Larkspur
20
Town of Ross
2
City/Town of Belvedere/Tiburon
11
Town of Fairfax
15
Town of San Anselmo
28
City of Mill Valley
9
City of Sausalito
7
E. Annual cost of low-income discount for new subscribers by MTA jurisdiction
Since Comcast is willing to continue the discount for these currently enrolled, I assume
that a locally financed discount would only apply to new low-income subscribers. For
purposes of this analysis, I have assumed a 10 percent turnover each year. Comcast
could not provide actual turnover data.
Agency
Annual New
Low-income
Subscribers
Annual Cost @
3.53/mo/subscriber
City of San Rafael
15
$ 635
County of Marin
4
169
Town of Corte Madera
1
42
City of Larkspur
2
84
Town of Ross
1
42
City of Belvedere
1
42
Town of Tiburon
1
42
Town of Fairfax
2
84
Town of San Anselmo
3
126
City of Mill Valley
1
42
City of Sausalito
1
42
TOTAL ANNUAL COST
30
$1,350
Memo BOD Agenda Item_J 07-12 LocallyAdministrdCableTVLowlncomeDscnt.doc
MTA Board of Directors
Agenda Item J: Locally Administered Cable TV Low -Income Discount
July 12, 2006
Page 3
F. Other Services for low-income discount subscribers
Per Comcast, more than 230 (about 79 percent) of the 288 low-income subscribers who
receive the discount on the basic tier also pay for higher levels of service.
Jurisdiction or Ci
Basic
Only @
$17.65/mo
Standard
Cable
$48.25/mo
Above
Standard
(Digital,
Cable
Modem, etc.)*
Total
City of San Rafael
21
72
46
139
County of Marin
7
t0
23
40
Town of Corte Madera
0
3
3
6
City of Larkspur
5
8
9
22
Town of Ross
1
1
0
2
Ci /Town of Belvedere/Tiburon
1
5
4
10
Town of Fairfax
2
9
4
15
Town of San Anselmo
6
10
11
27
City of Mill Valley
3
4
3
10
City of Sausalito
3
2
4
9
TOTAL
49
124
107
280
*Current Digital Tiers
Digital Silver $29.95 estimate per month, extra in addition to Standard cable
Digital Gold $43.95 estimate per month, extra in addition to Standard cable
Administering a MTA/member low-income discount program
The easiest option would be for Comcast to continue the program and send us a bill for new low-
income subscribers. I would expect them to add an administration charge if they are willing to
administer the program for us.
A locally run program could be administered by a member agency or the MTA as follows:
1) The managing agency could reimburse new low-income subscribers for 20 percent (or
whatever amount the Board or agency determines) of the basic rate.
This would likely require the sending of monthly checks and continuing to verify that
the individual still is a subscriber. Low-income subscribers would need to send the
agency verification that they had paid the bill and request reimbursement; or
Memo BOD Agenda Item_J 07-12 LocallyAdministrdCableTVLowIncomeDsent.doc
MTA Board of Directors
Agenda Item J: Locally Administered Cable TV Low -Income Discount
July 12, 2006
Page 4
2) The agency could subscribe for the individuals and bill them for the reduced amount.
This would involve setting up a budget to pay subscribers and then a collection process
to invoice, collect, and deposit low-income payments.
In both cases, we would need to set eligibility criteria, establish a process to take applications,
and determine if each new individual qualifies. This will involve administrative costs. This may
also involve establishing an appeals process if someone wants to challenge a determination that
they do not meet the established criteria (potentially a Board item). Our General Counsel should
review if the MTA would be establishing an entitlement program and what legal obligations such
a program would impose on the MTA.
The cost to administer our locally run program would exceed the cost of the discount. Such a
program would create following new costs:
a. Eligibility and claims staff to:
• Determine and verify eligibility for new clients
• Verify eligibility each month
• Authorize payments
• Follow-up on missed documentation and/or discount checks
b. Possible appeals process
c. Postage
d. Accounting charges
e. Program outreach efforts
Informal discussion with Comcast indicates that, at a vice-president level, there is no interest in
administering this program for the MTA. Contact by the Chair of the MTA should be made to
upper levels of Comcast management.
Memo BOD Agenda Item _707-12 LocallyAdministrdCableTVLowlncomeDscnt.doc