July 17, 2017

Marlene H. Dortch, Secretary
Federal Communications Commission
Office of the Secretary
445 12th Street, SW
Washington, DC 20554

Dear Ms. Dortch,

Stop the Cap! is writing to express our opposition to any modification now under consideration of the 2015 Open Internet Order.

Since 2008, our all-volunteer consumer organization has been fighting against data caps, usage-based billing and for Net Neutrality and better broadband service for consumers and businesses in urban and rural areas across the country.

Providing internet access has become a bigger success story for the providers that earn billions selling the service than it has been for many consumers enduring substandard service at skyrocketing prices.

It is unfortunate that while some have praised Clinton era deregulatory principles governing broadband, they may have forgotten those policies were also supposed to promote true broadband competition, something sorely lacking for many consumers.

As a recent Deloitte study[1] revealed, “only 38 percent of homes have a choice of two providers offering speeds of at least 25Mbps. In rural communities, only 61 percent of people have access to 25Mbps wireline broadband, and when they do, they can pay as much as a 3x premium over suburban customers.”

In upstate New York, most residents have just one significant provider capable of meeting the FCC’s 25Mbps broadband standard – Charter Communications. In the absence of competition, many customers are complaining their cable bills are rising.[2]

Now providers are lobbying to weaken, repeal, or effectively undermine the 2015 Open Internet Order, and we oppose that.

We have heard criticisms that the 2015 Order’s reliance on Title II means it is automatically outdated because it depends on enforcement powers developed in the 1930s for telephone service. Notwithstanding the fact many principles of modern law are based on an even older document – the Bill of Rights, the courts have already informed the FCC that the alternative mechanisms of enforcement authority that some seem motivated to return to are inadequate.

In a 2-1 decision in 2014, the U.S. Court of Appeals for the D.C. circuit ruled:

“Given that the Commission has chosen to classify broadband providers in a manner that exempts them from treatment as common carriers, the Communications Act expressly prohibits the Commission from nonetheless regulating them as such. Because the Commission has failed to establish that the anti-discrimination and anti-blocking rules do not impose per se common carrier obligations, we vacate those portions of the Open Internet Order.”[3]

In fact, the only important element of the pre-2015 Open Internet rules that survived that court challenge was a disclosure requirement that insisted providers tell subscribers when their internet service is being throttled or selected websites are intentionally discriminated against.

Unfortunately, mandatory disclosure alone does not incent providers to cease those practices in large sections of the country where consumers have no suitable alternative providers to choose from.

Reclassifying broadband companies as telecommunications services did not and has not required the FCC to engage in rate regulation or other heavy-handed oversight. It did send a clear message to companies about what boundaries were appropriate, and we’ve avoided paid prioritization and other anti-consumer practices that were clearly under consideration at some of the nation’s top internet service providers.

In fact, the evidence the 2015 Open Internet Order is working can be found where providers are attempting to circumvent its objectives. One way still permitted to prioritize or favor selected traffic is zero rating it so use of preferred partner websites does not count against your data allowance.[4] Other providers intentionally throttle some video traffic, offering not to include that traffic in your data allowance or cap.[5] Still others are placing general data caps or allowances on their internet services, while exempting their own content from those caps.[6]

Our organization is especially sensitive to these issues because our members are already paying high internet bills with no evidence of any rate reductions for usage-capped internet service. In fact, many customers pay essentially the same price whether their provider caps their connection or not. It seems unlikely consumers will be the winners in any change of Open Internet policies. Claims that usage caps or paid prioritization policies benefit consumers with lower prices or better service are illusory. One thing is real: the impact of throttled or degraded video content which can be a major deterrent for consumers contemplating disconnecting cable television and relying on cheaper internet-delivered video instead.

Arguments that broadband investment has somehow been harmed as a result of the 2015 Order are suspect, if only because much of this research is done at the behest of the telecom industry who helped underwrite the expense of that research. Remarkably, similar claims have not been made by executives of the companies involved in their reports to investors. Those companies, mostly publicly-traded, have a legal obligation to report materially adverse events to their shareholders, yet there is no evidence the 2015 Order has created a significant or harmful drag on investment.

In a barely regulated broadband duopoly, where no new significant competition is likely to emerge in the next five years (and beyond), FCC oversight and enforcement is often the only thing protecting consumers from the abuses inherent in that non-competitive market. Preserving the existing Open Internet rules without modification is entirely appropriate and warranted, and has not created any significant burdens on providers that continue to make substantial profits selling broadband service to consumers.

Transferring authority to an overburdened Federal Trade Commission, not well versed on telecom issues and with a proven record of taking a substantial amount of time before issuing rulings on its cases, would be completely inappropriate and anti-consumer.

Therefore, Stop the Cap!, on behalf of our members, urges the FCC to retain the 2015 Open Internet Order as-is, leaving intact the Title II enforcement foundation.

Respectfully yours,

Phillip M. Dampier
Founder and Director

Footnotes:

[1] https://www2.deloitte.com/us/en/pages/consulting/articles/communications-infrastructure-upgrade-deep-fiber-imperative.html#1

[2] “Thousands of Time Warner Cable Video Customers Flee Spectrum’s Higher Prices.” (http://bit.ly/2tjHJ8f); “Lexington’s Anger at Spectrum Cable Keeps Rising. What Can We Do?” (http://www.kentucky.com/news/local/news-columns-blogs/tom-eblen/article160754069.html)

[3] http://www.cadc.uscourts.gov/internet/opinions.nsf/3AF8B4D938CDEEA685257C6000532062/$file/11-1355-1474943.pdf

[4] https://cdn3.vox-cdn.com/uploads/chorus_asset/file/7575775/Letter_to_R._Quinn_12.1.16.0.pdf

[5] https://www.t-mobile.com/offer/binge-on-streaming-video.html

[6] http://www.chicagotribune.com/bluesky/technology/ct-data-cap-policies-20151214-story.html

The Federal Communications Commission on Friday quietly approved the transfer of seven high-power television station licenses owned by Bluestone Television/Bonten Media to Sinclair Broadcast Group without informing the sole Democratic commissioner Mignon Clyburn of the agency’s action.

An FCC letter informing Sinclair it approved of the transfer of licenses also included an authorization allowing KCFW (NBC) Kalispell, Mont., to continue operating as a satellite station of KECI (NBC) Missoula.

“Given that KCFW is the only full-power television station in its community of license, is located in a community of license with limited economic viability, and is costly to operate as a stand-alone station, it is unlikely that an alternative operator would be willing and able to purchase or operate the station as a stand-alone facility,” the FCC wrote. “Moreover, KCFW has operated as a satellite of KECI under Commission authority for almost 50 years, most recently reauthorized in 2007 in the Missoula DMA, and we see no evidence in the record that continuing the satellite exemption will harm competition in that market,” the FCC added.

The transfer may put Sinclair over the FCC’s station ownership cap, unless the agency changes its rules to favor Sinclair’s ongoing expansion. Sinclair is already the nation’s biggest owner of local television stations.

Commissioner Clyburn was reportedly not happy to learn about the FCC’s decision only through media reports and tweeted her displeasure this morning, calling the announcement part of a “Friday night news dump.”

#FridayNewsDump continues. Unclear from @FCC’s approval letter (https://t.co/aM0oJRtcsb), does this put Sinclair over the 39% ownership cap?

— Mignon Clyburn (@MClyburnFCC) July 3, 2017

The stations involved:

• WCYB (NBC) Tri-Cities, Tenn./Vir.
• KRCR (ABC) Chico-Redding, Calif.
• KECI (NBC) Missoula, Mont.
• KCFW (NBC) Kalispell, Mont. (satellite station simulcasts KECI)
• KTXS (ABC) Abilene-Sweetwater, Tex.
• KTVM (NBC) Butte-Bozeman, Mont.
• KAEF (ABC) Eureka, Calif.

Most of the television stations are in smaller television markets but will still profit Sinclair because most operate profitable local news operations.

Sinclair’s growing domination of local television station ownership concerned HBO’s John Oliver enough that he spent almost 20 minutes of his Last Week Tonight with John Oliver show discussing how Sinclair’s owners have a history of skewing local newscasts to cater to its own political agenda. (Strong Language) (19 minutes)

States and communities across the country are warning the Federal Communications Commission its proposal to limit local authority over wireless infrastructure siting will create chaos and open the door to public safety and aesthetics nightmares.

The FCC’s proposal would allegedly accelerate wireless infrastructure deployment by removing or pre-empting what some on the Commission feel are improper zoning barriers, unjustified fees meant to deter providers from adding new towers, and various other bureaucratic impediments. It would modify current “shot clock” rules that set time limits on applications and deem them automatically granted if a local or state authority failed to reach a decision in as little as 60 days.

Pai

While the wireless industry has expressed strong support for the proposed changes introduced by FCC Chairman Ajit Pai in March during the FCC’s “Infrastructure Month,” many states and localities are fiercely opposed to what some are calling a federal government takeover of local zoning and permitting. States as diverse as Illinois, Utah, and Maine have submitted comments objecting to the proposal, noting it will turn the FCC into a national zoning agency that could allow the installation of new cell towers and monopole antennas just about anywhere if the clock for consideration has run out.

Several communities have also submitted comments to the FCC reminding the agency its existing rules have allowed some providers to abuse the system, with further easing of regulatory oversight on the local level only increasing the potential for more abuse.

Communities have complained some providers have intentionally overwhelmed local authorities by submitting “bulk applications” that attempt to win approval for dozens of new sites with incomplete or missing paperwork. Others report providers using the public rights-of-way have placed large pieces of infrastructure in direct line with residents’ front doors, have created public safety problems with equipment that blocks drivers’ views at intersections, and had to contend with requests to place 120-200 foot monopole antennas on the edge of public highways and abandoned retired infrastructure providers fail to maintain or remove.

Can you find the hidden monopole tower?

The Utah Department of Transportation, among others, calls the FCC’s proposal “detrimental to public safety” and warns the FCC could end up creating a new loophole allowing providers to submit defective applications and then stalling required corrections until the shot clock runs out.

“No decisions are made on incomplete applications because the requested information is necessary for a decision to be issued,” Utah’s DOT writes. “This information may include, but is not limited to, when and where the work will be performed, type of installation, impacts to the traffic of the state highway. All safety issues must be addressed. Any shot clock start considerations by the Federal Communications Commission must be based upon completed applications. Otherwise the telecommunications company may fail to submit a completed application and continue to not submit all the requested information until the shot clock time period has run out. Such an approach would have detrimental impacts to safety of the traveling public on state highways because the Federal Communications Commission seeks to remove any authority from the states and local governments to address safety and placement after the shot clock has run out.”

Utah also fears the FCC’s decision to set uniform fees for applications could end up subsidizing large telecom companies with taxpayer dollars.

“Any requirement mandating lower fees than the actual costs will require the states to subsidize the telecommunications industry,” Utah’s DOT warned.

Maine’s Department of Transportation worries the FCC is putting the interests of multi-billion dollar telecom corporations ahead of the citizens of the state and their own needs. By allowing telecommunications companies to win irrevocable rights to place wireless towers where they want by running out the clock, the interests of those companies overshadow the public interest.

“The only ‘right’ that any entity receives to locate within Maine’s highway corridors is a revocable permit,” the DOT wrote. “To minimize overall expense and downtime, it is essential that facilities are appropriately located the first time around and there should not be any rules stating that it is in any way appropriate for an entity to construct facilities in a location that has not been explicitly approved by the applicable licensing authority, property owner or facility owner.”

Because the FCC’s proposal is so wide-ranging and skewed in favor of telecom companies, several state and local agencies are asking the FCC to clearly affirm that a company’s business interests should never come before public safety, future transportation needs, or at the public’s expense.

“Any new or revised rules should clearly affirm a state or local highway agencies’ authority to properly manage the highway corridor in the interest of highway safety, operations, and right of way preservation for future highway purposes,” offers Maine’s DOT, adding that after the state’s experience with financially troubled telecom companies abandoning outdated or damaged infrastructure, the public should not have to pay to clean it up.

“Accommodation of wireless towers or other monopole structures within the highway corridor also present hidden public expense when relocation of those facilities cause construction delays or when such facilities are abandoned by a [company] that declares bankruptcy,” the agency noted.

The Illinois Department of Transportation echoed Utah and Maine, noting the telecom industry needed to work with local and state officials to ensure timely permitting.

Instead, the telecom industry has spent millions lobbying state and federal legislators to curtail or eliminate local oversight and control. While many telecom companies are honest and accommodating, especially when they are considering major infrastructure expansion, some are not and work to game the system.

IDOT notes it is willing to manage the burden of processing applications on a timely basis, but utilities should not be rewarded with a right to run out the clock with an incomplete application.

“The burden of timely issuance of permits is shared by both the state and the industry,” IDOT wrote. “It is important that the utility fulfill its duties and meet their obligations.”

Benjamin

In one instance, a large telecom company submitted a very large number of permit applications across Illinois for a network upgrade it had no plans to commence in the near future, overwhelming permit offices. If the FCC’s reforms were in place, many of those applications would have been automatically approved after the deadline for consideration ran out, even though the provider was in no hurry to start work.

“The concept behind this is […] if a government authority doesn’t respond in a timely manner, the permit is automatically granted,” the filing said. “The [proposal] is attempting to shift the burden of court appeal to the [local permitting authority] as opposed to the permit applicant.”

Columbia, S.C. mayor Steve Benjamin believes the FCC is trying to solve a non-existent problem.

“Simply put, local rights-of-way management does not discourage wireless deployment,” Mayor Benjamin said in March. “Instead, it serves numerous public policy goals and ensures that rights-of-ways are managed in a manner that allows for all users to safely and efficiently use public rights-of-way. The city is deeply concerned […] the Commission is simply seeking to preempt local authority and to dictate how local governments should manage public property, all in an effort to marginally increase the profits of an already profitable industry at the expense of important and legitimate public interest goals.”

FCC headquarters in Washington, D.C.

(Reuters) The U.S. Federal Communications Commission voted 2-1 on Thursday to advance a Republican plan to reverse the Obama administration’s 2015 “Net Neutrality” order.

FCC chairman Ajit Pai has proposed the commission repeal the rules that reclassified internet service providers as if they were utilities. He thinks the open internet rules by President Barack Obama, a Democrat, were unnecessary and harm jobs and investment.

“We propose to repeal utility-style regulation,” Pai said Thursday. “The evidence so far strongly suggests that this is the right way to go.”

The public will have until mid-August to offer comments before the FCC votes on a final plan.

Pai wants public input on whether the FCC has the authority or should keep its “bright line” rules barring internet companies from blocking, throttling or giving “fast lanes” to some websites. He has not committed to retaining any rules, but said he favors an “open internet.”

Pai said he would make a final proposal public before a final vote and said the FCC will conduct a cost-benefit analysis.

Democratic FCC Commissioner Mignon Clyburn, who voted against the plan, said the end game appears to be an internet without FCC regulatory oversight. She said the proposal “jeopardizes the ability of the open internet to function tomorrow, as it does today.”

The FCC, which has already received more than 1 million comments, is also seeking comment on whether U.S. states should be able to set their own broadband privacy or other regulations.

Facebook, Alphabet Inc, and others back Net Neutrality rules, saying they guarantee equal access to the internet.

Broadband providers AT&T Inc, Verizon Communications, and Comcast oppose the 2015 order, saying it would discourage investment and innovation.

Internet providers insist they will not engage in blocking or throttling even in the absence of rules, but critics are skeptical.

Senator Brian Schatz, a Democrat, said “it will take millions of people standing up, just like they did before, to say that the internet needs to stay free and open. That’s what it will take to win.”

Comcast, Charter Communications, and Altice USA signed an advertisement Wednesday saying they are “committed to an open internet that gives you the freedom to be in charge of your online experience…. We do not block, throttle or otherwise impair your online activity.”

USTelecom, an industry trade group, said the FCC “is moving the conversation beyond the merits of Net Neutrality to how best to safeguard this universally embraced value with a modern, constructive policy framework.”

(Reporting by David Shepardson; editing by Grant McCool)

In one of the largest media consolidation acquisitions in history, Sinclair Broadcast Group has agreed to buy Tribune Media and its 42 TV stations in a $3.9 billion deal.

The transaction, expected to win easy approval by the Republican-dominated Federal Communications Commission, will virtually guarantee cable and satellite TV subscribers will pay significantly higher prices to watch Sinclair’s local television stations covering more than 70% of the United States.

Sinclair helped lay the foundation for winning approval of the transaction in GOP-dominated D.C. by hiring former Trump spokesman Boris Epshteyn as Sinclair’s chief political analyst, and Sinclair executives mandate that many of its owned stations air pro-Trump conservative political content labeled as “news stories” as part of local newscasts.

Sinclair’s conservative leanings and accusations of hypocrisy are nothing new for the station group, which has been mired in controversy for more than two decades. The “family values” image that Sinclair purports to have in its political commentaries and corporate image ran headlong into the 1996 arrest of its former CEO David Smith, who used the company Mercedes to pick up hookers in Baltimore. He was convicted of a misdemeanor sex offense. Smith cut a deal with a Maryland state’s attorney that would allow him to avoid picking up trash on the highway or cleaning community-owned pools by having his reporters air stories about Baltimore’s drug court instead.

LuAnne Canipe, a reporter who worked on air at Sinclair’s flagship station, WBFF in Baltimore, from 1994 to 1998, told Salon in 2004 she took a phone call one day about the disposition of Smith’s arrest.

“A Baltimore judge called me up,” she recalls. “He wasn’t handling the case, but he called to tell me about the arrangement and asked me if I knew about it. The judge was outraged. He said, ‘How can employees do community service for their boss?’”

To this day, Smith remains the chairman of Sinclair Broadcast Group, although he relinquished the CEO position last fall.

Canipe said the sexual shenanigans at Sinclair didn’t stop with the CEO either.

“Let’s just say the arrest of the CEO was part of a sexual atmosphere that trickled down to different levels in the company,” Canipe remembered. “There was an improper work environment. I think that because of what he did there was a feeling that everything was fair game.”

Before leaving Sinclair in 1998, she said she once complained to management about another Sinclair employee, who had engaged in audible phone sex inside a station conference room, but that no action was taken against the employee. Canipe passed away in 2016 after battling cancer.

Sinclair stations were required to air political commentary during local newscasts that favored the Bush Administration.

By 2004, the majority of Sinclair’s then-62 stations were living with corporate interference in the local newsroom. Sinclair mandates that most of their owned stations air corporate-produced political segments that are routinely called “to the [political] right of Fox News” by detractors. That year, many local newsrooms at Sinclair stations bristled over the mandatory airing of a daily televised commentary called The Point, hosted by Mark Hyman, then Sinclair’s vice president for corporate relations. The Point could be compared as Sean Hannity’s talking points delivered with the bombastic panache of Bill O’Reilly. As the 2004 election neared, Hyman’s push for George W. Bush’s re-election went into overdrive. Hyman was a fierce advocate for the Bush Administration’s intervention in Iraq and referred to the French critics of President Bush’s war strategy as “cheese-eating surrender monkeys.”

While Hyman force-fed conservative political commentaries to Sinclair stations, he did not extend that same right to others, banning Sinclair’s ABC-affiliated stations from airing an edition of Nightline that showed host Ted Koppel reading the names of U.S. troops killed in Iraq, claiming the idea was inappropriate and “motivated by a political agenda.” Concerns about political agendas were short-lived, however, because Hyman later mandated that 40 of Sinclair’s 62 stations air “Stolen Honor,” a much-criticized and highly controversial political documentary attacking Democratic presidential candidate Sen. John Kerry’s war record. The stations aired a revised version of the documentary days before the 2004 presidential election.

When management at some of Sinclair’s local stations balked at the required airing, Hyman accused them of “acting like Holocaust deniers.”

Just prior to the 2012 election, WSYX was forced to air a Sinclair-produced “special” pre-empting ABC’s 6:30pm national news and Nightline that heavily criticized President Obama, then up for re-election, and accused him of lying about the attack on the American consulate in Benghazi, Libya. The special also pre-empted programming on other Sinclair stations, including WPEC in West Palm Beach.

The implied quid pro quo with the Bush Administration was particularly important for Sinclair as it continued acquiring TV stations, a process that required the approval of the then-Republican controlled FCC. A 2004 Salon article quoted journalist Paul Alexander, who produced a widely acclaimed documentary about Kerry as “insulting to the news-gathering process. That’s not how you gather news; that’s how you blackmail people.”

But news gathering was never the point, according to former Sinclair reporter Canipe. “David Smith doesn’t care about journalism,” she said.

Smith doubled-down on his cozy relationship with the Bush Administration by allowing conservative commentator Armstrong Williams to produce unfettered extended media segments for Sinclair stations. What Smith claims he did not know was that Williams accepted a $240,000 payoff from Bush officials to promote the Administration’s education agenda in the media. Williams brazenly interviewed then Education Secretary Rod Paige, the same man who authorized Williams’ payoff.

The result of the interview, according to the 2005 Rolling Stone piece:

Even before the payoffs became public, the news staff at Sinclair was horrified. The producer who edited the interview Williams did with Paige calls it “the worst piece of TV I’ve ever been associated with. You’ve seen softballs from Larry King? Well, this was softer. I told my boss it didn’t even deserve to be broadcast, but they kept pushing me to put more of it on tape. In retrospect, it was so clearly propaganda.”

When things became politically difficult for the president during the second term of the Bush Administration, Sinclair again came to the rescue, forcing its stations to air headquarter-produced news stories highlighting “good news” about the war in Iraq. Sinclair executives also demanded each of its 62 stations air a pledge of support for President Bush.

Rolling Stone:

But within the company, current and former employees have long known that there is a fine line between ideology and coercion. Jon Leiberman, once Sinclair’s Washington bureau chief, says Smith and other executives were intent on airing “propaganda meant to sway the election.” An ex-producer says he was ordered not to report “any bad news out of Iraq — no dead servicemen, no reports on how much we’re spending, nothing.” And a producer Sinclair sent to Iraq to report on the war calls the resulting coverage “pro-Bush.”

“You weren’t reporting news,” says the producer, who spoke on the condition of anonymity. “You were reporting a political agenda that came down to you from the top of the food chain.”

At the time, Smith told visitors to his Baltimore headquarters: “There are two companies doing truly balanced news today: Sinclair and Fox.”

During the most recent election cycle, Sinclair executives made sure audiences knew where they stood, urging voters to reject Hillary Clinton, as the New York Times reported, “because the Democratic Party was historically pro-slavery.”

More recently, Sinclair has defended the Trump Administration, with orders from Sinclair HQ to stations to dig up information about an online ad that seemed to recruit paid protesters for President Trump’s inauguration in January. Various right-wing groups used the ad as evidence of organized efforts to harass the incoming administration. The ad was later determined to be a hoax, wasting reporters’ time.

The national map of Sinclair and Tribune Media’s reach. (Image: New York Times)

The interference in local newsgathering by Sinclair executives has become so pervasive, its station in Seattle – KOMO, has been rebelling by burying mandated stories surrounding commercial breaks, when viewers are most likely to tune them out. But there is little else the station can do, and like with other acquisitions Sinclair has completed, there are fewer news staffers at KOMO to protest. Standard procedure at Sinclair after an acquisition to is dramatically cut back on employees and offer more stories and content produced at Sinclair’s headquarters or at other Sinclair-owned stations.

Sinclair’s latest target — Tribune Media, owns stations familiar to most cable and satellite subscribers around the country. Among the stations in Tribune’s portfolio — WPIX-New York, WPHL-Philadelphia, WGN-TV/WGN America-Chicago, KDVR/KWGN-Denver, and KTLA-Los Angeles.

“It’s an incredible amount of power in one company’s hands,” said Craig Aaron, president of Free Press.

Tribune Media owns some of the largest local TV stations in the country.

Former FCC commissioner Michael Copps doesn’t much like the deal either, noting it is “another blow to the diversity of journalism that we should have. It’s symptomatic of what is happening in this market, which is fewer and fewer organizations controlling more and more of the information on which our democracy rests.”

Copps

With all the recent turmoil at Fox News Channel, including the cancellation of Bill O’Reilly’s show, Sinclair could use its Tribune Media acquisition to launch a new conservative national news and opinion network that could rival Fox. WGN America, which no longer has anything to do with WGN-TV — a former “superstation”, could dump the current reruns it airs and be repurposed as a new home for exiled conservative commentators like O’Reilly.

Regardless of your political persuasion, you will likely be paying a lot more for Sinclair TV stations on the cable or satellite dial. Sinclair is among the most aggressive station owners boosting prices for carriage agreements. Cable operators will continue to pass most, if not all of these fees on to subscribers in the form of higher rates or through “Broadcast TV” surcharges that are rarely mentioned by cable companies in their advertised rates.

In Utah, cable operators are already very familiar with Sinclair’s retransmission rate increases. The revenue has grown so significant, some station owner groups are buying up small independent TV stations just to cash in on the growing revenue they get from cable systems and subscribers.

CentraCom, a cable operator in Utah, reports it now pays over $10 as month for local stations, per subscriber, double what it paid in 2008, and they are prepared to see rates much higher than that in the future. Sinclair will also be motivated to force bundle its cable network Tennis Channel with its local stations when it negotiates with cable companies, whether they want the tennis network or not.