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5 school districts serving the member cities; one is used for government access, with each of the cities’ programming distributed discretely within the their own municipal boundaries; and one is used for programming distributed by NASA via satellite. Because a number of cable subscribers were interested in the service, NSAC/CTV North Suburbs agreed to put the NASA programming on one of the community channels when a previous franchisee no longer wanted to carry it. Comcast’s formal proposal would cut the number of Standard Definition (SD) channels from eight to three and add one High Definition channel, with the possibility of adding one additional SD channel in the future. (Comcast proposal p. 74) The criteria for getting the HD channel is “not less than 5 hours per day, 5 days per week of locally produced, non‐character generated, first‐run programming (emphasis added),” a standard that does not appear to apply to any commercial channel on Comcast’s system. In fact, some cable programming services do not cablecast ANY first‐run programming. Further, Comcast’s emphasis on first‐run programming devalues the PEG channels role as a video archive of the community. There is no requirement in federal law the puts a “first‐run” restriction on PEG programming and would infringe on the NSAC’s freedom of speech protections. Whether it is a live broadcast, i.e., first‐ run, or a replay of a previous broadcast does not increase or decrease its value to the community. As such, the NSCC cannot recommend adoption of the Comcast proposal on either the number of SD and HD channels offered by Comcast nor the hurdles imposed in gaining new HD programming. In addition, failure to transition PEG programming to HD will marginalize this programming and ensure that it will NOT be watched. The reality is that cable subscribers with HD television sets tend to watch only HD channels/programming services, and the trend is that most, if not all, programming services will be provided in HD or its successor technology (likely 4K). CTV North Suburbs has already invested in HD and HD‐capable equipment, and a substantial amount of the programming produced at CTV North Suburbs, as well as that turned in for cablecast, is already in the HD format. At some point in the future, it will difficult to purchase SD production equipment. But it is the content of these channels and what they represent that is most important. The community channels provide a variety of programming for local audiences that are not available elsewhere on the cable system, and they give a voice to people and groups who are often not heard or seen. In 2013, community producers and volunteers contributed almost 17,000 hours to produce 558 programs for the PEG channels, and CTV staff produced another 206 programs. These include city parades and festivals, school sports and concerts (both from K‐12 and post‐secondary schools); election coverage; high school robotics competitions; talk shows about community people, organizations and activities, such as “Tale of Ten Cities;” community band and orchestra concerts (The Shoreview Northern Lights Variety Band, the Roseville Community Band, the Roseville Strings); and a program by and about people with