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AFFILIATE OFFICE

MUMBAI, INDIA

June 13, 2012

VIA ECFS

Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, D.C. 20554

Re: Ex Parte Notice of Mediacom Connect America Fund, et. al, WC Docket Nos. 10-90, 07-135, 05-337, 03-109, GN Docket No. 09-51, CC Docket Nos. 01-92, 96-45, and WT Docket No. 10-208

Dear Secretary Dortch:

Dan Templin, President, Mediacom Telephony and Senior Vice President, Mediacom Communications (collectively, "Mediacom"), Roger Moss, Carrier Relations Officer and Voice Operations Director for Mediacom Telephony and Anne Sokolin-Maimom, Vice President of Regulatory Affairs for Mediacom Communications, and John Heitmann and Denise Smith, both of Kelley Drye & Warren LLP, met in separate meetings on June 11, 2012 with: (1) Priscilla Delgado Argeris, Legal Advisor to Commissioner Rosenworcel; (2) Sharon Gillett, Carol Mattey and Amy Bender of the Wireline Competition Bureau and Michael Steffen, Legal Advisor to Chairman Genachowski; and (3) Commissioner Pai and Matthew Berry, Chief of Staff, Commissioner Pai's Office; and in separate meetings on June 12, 2012 with: (1) Commissioner Clyburn, Angela Kronenberg, Legal Advisor to Commissioner Clyburn, and Keia Johnson, Intern, Commissioner Clyburn's Office; and (2) Christine Kurth, Policy Director and Wireline Counsel to Commissioner McDowell, to introduce Mediacom's telephony and broadband business and to discuss several policy issues pertinent to the Connect America Fund ("CAF") proceeding.

In particular, Mediacom emphasized the extent of its privately funded broadband network and the speed of the broadband service offerings it brings to rural America. Mediacom

DC01/SMITD/480345.2

KELLEY DRYE & WARREN LLP

Ms. Marlene H. Dortch June 13, 2012 Page Two

illustrated how its deployment of fiber to cell towers has enabled it to bring fiber-based services to more rural communities and businesses.

Mediacom also discussed issues pertinent to the ongoing CAF proceeding and stressed the Company's view that CAF support should not be provided where Mediacom provides broadband services. Mediacom emphasized the need to define the reference to "substantially unnerved" in Commission rule 54.313, 47 C.F.R. § 54.313, to ensure CAF support funds are appropriately targeted to where unsubsidized competitors are not already providing broadband service. Mediacom also explained that an inefficient cost model can result in over-subsidization which can devalue current privately funded facilities investment and provide disincentives to future privately funded facilities investment. Mediacom shared its experience with Clearwave, a wholesale customer of Mediacom's broadband services and recent recipient of federal and state government broadband stimulus funds for broadband investment in southern Illinois. After receiving over $42M in broadband stimulus funds ($31.5M from the federal Broadband Technology Opportunity Program and $11.3M in state stimulus funding), Clearwave installed middle- and last-mile fiber facilities in the same geographic area, often duplicating Mediacom's existing broadband network facilities in that area. As a result, Clearwave and its underlying customers will be moving off of Mediacom's privately funded broadband network and onto Clearwave's publicly funded network. Mediacom suggested that this experience in which public funds were used to overbuild and devalue existing private investment is the type of inefficient use of funding that must be avoided when the Commission distributes support from the CAF. Mediacom also addressed suggested improvements to the competitive bidding and eligible telecommunication carrier ("ETC") designation processes, noting that the Commission should take steps to reduce barriers to entry posed by the latter.

Mediacom distributed the attached presentation during the meeting to provide further detail about the points described above. With respect to page 10 of the deck, Mediacom explained that the red line indicates 10 gigabit backbone fiber, while the green line indicates 1 gigabit local fiber.

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KELLEY DRYE & WARREN LLP

Ms. Marlene H. Dortch June 13, 2012 Page Three

This letter is being filed electronically pursuant to section 1.1206 of the Commission's rules. Please do not hesitate to contact me, if you have any questions regarding this filing.

Respectfully submitted,

John J. Heitmann

Counsel to Mediacom Communications

Attachment

cc: Priscilla Delgado-Ageris, Sharon Gillett, Carol Mattey, Amy Bender, Michael Steffen, Commissioner Pai, Matthew Berry, Commissioner Clyburn, Angie Kronenberg, Commissioner Clyburn, Keia Johnson, Christine Kurth

DC01/SMITD/480345.2

Mediacom: Driving Broadband Network Investment and Deployment

in Rural America

WC Docket Nos. 10-90, 05-337

June 11-12, 2012

Mediacom Communications

Mediacom Telephony

Mediacom Business

Mediacom: More Than Cable

� Mediacom is the nation’s eighth largest cable company

� Focuses on serving smaller cities, communities and rural areas in the United States

� Significant customer base in the Midwest and Southeast

� Provides service using technologically-advanced cable systems to over 1,000,000 subscribers

� Through its Mediacom Telephony subsidiary, Mediacom provides broadband and digital telephony services in 20 states

� Provides high-speed Internet access to more than 850,000 subscribers

� Provides digital telephone service to nearly 350,000 subscribers

2

Mediacom: More Than Cable

� Using the Mediacom Business brand, Mediacom provides digital voice, high-speed Internet access and other broadband services to businesses throughout its service territory

� Serves small-to-medium sized businesses with broadband and advanced digital telephony voice service solutions

� Provides fiber-based connectivity and network solutions to enterprise and carrier customers

3

Bringing Broadband to Rural America� Mediacom offers broadband services throughout its footprint, including in

small communities and rural areas

� Mediacom’s speeds range from 3Mbps to 105Mbps

� Pricing typically is well-below competing ILEC offerings

4

Source: NetIndex.com

0

5

10

15

20

Download Speed (Mbps)

Century Link Mediacom Frontier Windstream

Actual Broadband Download Speeds -Iowa

Bringing Broadband to Rural America

� Mediacom’s customers have a growing need for speed

� Residential customers typically bypass Mediacom’s entry-level offerings in favor of higher-speed offerings

� Majority of customers select service speeds of 12-15Mbps

� SMB customers typically purchase bundled packages of multiline voice and higher-speed Internet access

� Mediacom projects residential and SMB customers will continue to demand and move to higher speed broadband offerings

5

Source: Cisco, White Paper, The Zettabyte Era (May 30, 2012)

0

5

10

15

20

25

30

35

40

2011 2012 2013 2014 2015 2016

Projected Growth in Broadband Speeds - North America

Broadband Speed(Mbps)

Storm Lake, Iowa

Bringing Broadband to Rural America

� Mediacom has spent over $1B in network improvements and expansions over the last 10 years

� Mediacom has built fiber connections to approximately 1000 cell towers

� Within 12 months, Mediacom deployed over 500 route miles of fiber in Iowa, including many in rural areas

11

Bringing Broadband to Rural America

� Cell tower build out enables Mediacom to bring fiber-based services to less-densely populated communities and rural areas

� Mediacom is extending its fiber-based network inward from residential communities into city centers and “Main Street” America

� Mediacom brings broadband to community anchor institutions, including school districts, hospitals, fire departments, police departments and other public safety agencies

� Education and healthcare are Mediacom’s largest verticals� Iowa Rural Healthcare Network

� Illinois Rural Healthcare Network

� Iowa State University

� Community Colleges

� Vocational Schools

12

13

Price Cap CAF Support Must Be Accurately Targeted

� The rule 54.313 reference to “Substantially Unserved”must be defined

� Price cap CAF support must be targeted to support only areas notserved by unsubsidized competitors

� CAF support should not be provided where facilities-based, unsubsidized competitors offer broadband, at the required performance levels, to at least a majority of service locations in a census block

� Industry must work to ensure that all providers are accurately reflected on the National Broadband Map

14

Cost Model Must Be Efficient

� An inefficient cost model can lead to over-subsidization

� Price cap carriers’ proposed cost model must be revised because it is not efficient

� Cost components and calculations must be transparent and based on lowest-cost broadband build by any provider

� Over-subsidization will disrupt private investment:

� Devalues current facilities investments

� Dissuades future facilities investments

� Mediacom supports the American Cable Association’s review of the price cap carriers’ cost model

15

Competitive Bidding Process

� Competitive bidding process must be designed to provide incentivesfor companies to participate

� Competitive bidding process must be tailored to ensure that support is provided to most efficient broadband provider

� Bidding should be based on aggregated eligible census blocks at the census tract level

� Service areas should be identified based on 4/1 standard but required performance standards should be higher

� Support recipients should be required to serve 95% of locations in service area within two years

� Support should be limited to five years; then the FCC should reevaluate need and method for further support

� Mediacom anticipates participating in the competitive bidding process

16

ETC Designation Process and Compliance Requirements

� Onerous ETC designation and compliance requirements create a barrier to entry

� The ETC designation process and compliance requirements must be simplified

� FCC should create and administer a uniform, national ETC designation process for broadband services

� Only carrier receiving CAF support should be required to apply for ETC status

17

Thank You