DBS’ 749K sub gain in 2Q and Top 5 MSO’s 222K sub loss benefited cable a bit. NCTA used the figures in video competition comments filed with the FCC Wed. The Commission is soliciting comments as it assembles its 11th video competition report, due to Congress by year-end. Not that cable’s happy to lose subs, but it’s further evidence that "cable must compete hard to maintain current customers or win new ones," NCTA wrote. The association also whacked arguments that exclusive access to programming delivered terrestrially gives cable an unfair advantage. Coming from DirecTV, RCN, Verizon and others, the program access debate has become an annual tradition in the video competition proceeding. NCTA said Congress created the exemption to foster new programming nets, especially local and regional nets. — The bulk of competition comments to the FCC came from citizens unhappy with closed captioning; captions are garbled, missing and inaccurate, they argued.