Charter can ill afford the $100 million cost 2007-2009 of complyi...

and 300,000-350,000 new high-end boxes a year, it said. Low- end boxes the waiver would cover are 40-45% of the total but would run up most of the CableCARD compliance costs, Charter said. A waiver “would save it, and its customers, more than $50 million,” the company declared, citing “actual price information” from box suppliers Motorola, Scientific-Atlanta and Pace Micro. Those savings are “essential” for the company in the DTV transition, since it has “far fewer financial resources” than other big cable providers, it said. Charter has $20 billion debt, much from upgrades of old cable systems acquired in the 1990s, it said. The debt, 11 times yearly EBITDA, is more than triple Comcast’s and Time Warner’s, and 50% above the average of most large public MSOs, Charter said. The company said it has had negative cash flow each of the past 5 years. Charter runs many small, “widely dispersed” cable systems, so the digital transition will cost it far more than “more consolidated MSOs” per subscriber, it said. Charter called itself a “decentralized, highly scattered collection of local systems” in 31 states, with 3,379 franchises -- 4-1/2 times as many as Cox, which has a comparable number of subscribers. Unlike other large operators, Charter has no “national backbone” connecting its local systems, it said: “Charter must therefore spend significantly more per subscriber to launch digital simulcast in many of its markets because of higher distribution costs and because the fixed per-headend costs must be recouped from smaller, more localized bases of customers.” If Charter hadn’t spent so much money appealing the Commission’s rules for the CableCARD technology that “the cable industry came up with in the first place,” it might have the financial resources it now says it lacks, said Julie Kearney, CEA senior dir.-regulatory counsel.