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CBG Communications, Inc. 2 determined by the Commission as described in both the Staff Report and the Community Needs Assessment prepared by the Buske Group.  Some of Comcast’s responses echo a unilateral sentiment of “we will decide” without proposing to the Commission what it specifically believes will meet the NSCC’s needs. As such, Comcast’s proposal is nonresponsive in these areas and is inadequate. In summary, Comcast’s Renewal Proposal, in many respects, is not so much a proposal of what it will do from a technical perspective to meet the needs determined by the Commission, but rather a dictate of what it will not do. Further, where Comcast indicates it will meet some or a portion of the needs, it often will not describe how it proposes to do so. As such, Comcast’s Renewal Proposal regarding many technical, I- Net and PEG Access signal transport matters is deficient and not reasonable. Provision and Use of the Institutional Networks Comcast has made it clear that it is not proposing to continue the existing fiber optic and HFC I-Net as built and maintained today. Comcast has proposed to continue the HFC I - Net for PEG Access video origination purposes only. Comcast also proposes to keep the existing fiber optic I-Net in place for PEG Access video origination purposes. However, Comcast has proposed that any utilization of the I -Net, outside of video origination, can only occur as a managed service whereby Comcast would charge a monthly recurring charge for use of the network and therefore Comcast would profit from non-video origination use of the I-Net. During the current franchise, Comcast has enabled the NSCC and the Member Cities to use the I-Net for data transportation, in addition to using the I -Net for PEG Access video origination. Indeed, Comcast has installed equipment owned by Member Cities on the I-Net in order for this data transportation to occur. This arrangement dates back to when cable modem technology was in its infancy in the late 1990s and early 2000s and has continued through the more recent installation of Ethernet based equipment on the fiber optic I-Net. CBG strongly believes that Comcast should continue to provide the I-Net for uses beyond PEG Access video origination, as well as for such video origination, as detailed in the Buske Report and in CBG’s Technical Report. The I-Net has been in place for more than 14 years and has fulfilled data communication needs for the NSCC and its Member Cities for more than 14 years and needs to continue to do so.