c. The TPT proposal would be complex in appli

cation and expensive to administer. The proposal contemplates
quarterly certification by the FCC (perhaps at the taxpayer's
expense) to the Register of Copyrights of the market share
("popularity") of each "copyright qualifying" station. This
would require quarterly determination of the subject stations,
measurement of the "popularity" of subject stations from
commercially syndicated rating service data (which are pub-
lished only once each year), and calculation of copyright
liability for over 3,200 cable systems. The cost of admin-
istering this procedure could amount to a sizable proportion
of total copyright fees collected.

2. In contrast to the provisions of H.R. 2223, the concepts of "copyright qualification" and "popularity" applied to broadcast signals by the TPT proposal serve to exempt outright substantial numbers of cable systems and their revenues from copyright liability. The following charts show the exemptions resulting from the proposal on TPT's systems (and revenues, in millions of dollars).

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3. Beyond outright exemption, the "qualification" and "popularity" aspects of the proposal necessarily tend to place a greater copyright burden on systems located in more remote areas compared with systems located in or near major TV markets. Stated another way, the copyright burden would fall more heavily on those systems for which the lack of sufficient "local" signals means greater reliance on "distant signals." 4. The TPT proposal impacts in grossly different ways on systems of comparable size. As a result: (a) some systems are exempt because they carry no "copyright qualifying signals"; other systems, although "copyright qualifying" are rendered exempt by reason of insignificant "popularity"; and (b) certain smaller systems, due to their relative remoteness

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from major TV markets, are liable for copyright fees substantially in excess of the nominal levels contemplated in H.R.

2223, and in excess of fees paid by larger systems. As

applied to TPT's own systems, the following table illustrates

Another effect of TPT's proposal is that it tends to increase payments by the decreased number of systems which remain liable for payment, with a proportionately greater burden borne by systems in the lower revenue classes.

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plied to its systems, results in an overall reduction in
copyright fees of $136,393, or 13 percent from $1,032,774 to
$896,381 relative to H.R. 2223. Only the highest revenue
class of systems--those with annual revenues in excess of
$640,000--show a decrease in fees. All other revenue classes
of systems show increases.

Viewed from a slightly different perspective, the following table presents the percentage distribution of copyright fee payments by revenue class under H.R. 2223 and the TPT proposal respectively. Among other things, it shows that the relative contribution of the largest revenue class is

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reduced from 77 percent to 60 percent of total copyright fee payments under the TPT proposal, while the relative contribution of the remainder increases from 23 percent to 40 percent.

COMPARISON OF COPYRIGHT FEES FOR TELEPROMPTER CABLE SYSTEMS
PER H.R. 2223 AND TELEPROMPTER PROPOSAL

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