ACA expressed "serious concerns" with FCC chmn Kevin Martin‘s proposal to modify program carriage rules at next Thurs open meeting. In a filing, ACA voiced strong objections to any changes that would subject non-vertically integrated operators to complaints filed by unaffiliated video programmers for not agreeing to similar prices, terms or conditions for carriage as those agreed to for any other programmer. ACA said such ops have no incentive to "unreasonably restrain independent programmers’ ability to compete fairly." At the same time, the group expressed its support for the FCC seeking further comment on unbundling of programming at the wholesale level. — Cablevision responded Tues to a Disney filing challenging its position on wholesale unbundling. Disney suggested that Cablevision’s stance in an antitrust, a la carte suit contradicts the MSO’s proposal to not allow programmers to request carriage on a particular package. CVC said its position in the suit is not at odds with the FCC’s plan to seek comment on wholesale unbundling, saying it and other ops have denied that the practice of purchasing and distributing programming in the industry constitutes a conspiracy to violate Section 1 of the Sherman Act. "At the same time, Cablevision believes that as a matter of public policy the time is right for the Commission to begin a public discussion of the regulator framework that permits programmers to require cable operators to place expensive programming, watched by only a percentage of their customer base, in the expanded basic tier," CVC’s filing said.