Memorandum to Thomas Hopkins, Acting Assistant Director, RE: UHF Filing

by Milton Kafoglis on April 12, 1977
by Milton Kafoglis

I have read the letter to Secretary Blumenthal by the Council for UHF Broadcasting. This letter makes some rather serious charges. To a significant extent these charges related to work I have done and for which only I can answer.

The analysis is described by CUB as “erroneous in major respects and grossly misleading” and “so defective as to make its conclusions worthless”.

CUB requests that it be withdrawn until it is “fully remedied.” Though the ana1ysis is not perfect, its imperfections and assumptions are clearly noted in the filing. I believe the filing is not only defensible, but is meritorious, responds to the questions raised by the Commission, and wi11 be of material assistance to the Commission in reaching an appropriate decision. I do not believe a responsible economist could agree with CUB’s evaluation. Furthermore, CUB has not provided a reasoned basis for their assertions.

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