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CBG Communications, Inc. <br /> <br /> 5 <br /> <br /> <br />Because the I-Net has been in place for at least 14 years and because Comcast and its <br />predecessors recovered the cost to build the I-Net from its subscribers over the years, <br />this cost should not be included in a costing model of the I -Net. <br />Therefore, the only cost, if anything, to the NSCC And Member Cities for utilization of <br />the I-Net should be the cost of maintaining the I-Net over and above costs that would be <br />incurred by Comcast to maintain their subscriber system. <br /> <br />System Inspection / Documentation and Repairs <br /> <br />CBG’s technical Report documented a number of issues of non -compliance with the <br />National Electrical Code (NEC) and the National Electrical Safety Code (NESC) on <br />Comcast’s cable TV system up to and including on buildings and homes in the NSCC <br />area. CBG then recommended that the NSCC require Comcast to regularly inspect and <br />document issues found on its cable TV system. In addition, the Report recommended <br />that requirements for such inspections and documentation be included in any renewed <br />franchise. This was embodied in the Staff Report that Comcast “provide a detailed <br />inspection and repair plan that addresses these and all issues and code violations in the <br />NSCC service area”. Comcast provided a significant amount of discussion on its repair <br />procedures in place today but it never specifically described an inspection and <br />documentation plan. <br /> <br />System Upgrade Review <br /> <br />CBG’s Technical Report stated that there may be a need to upgrade the system in the <br />future to meet the cable related needs of the communities served by the NSCC. The <br />report recommended that there be a mid-term review of the system in part to evaluate <br />the ability of the system to meet the cable related needs of the community. In <br />Comcast’s Proposal, Comcast only states: <br /> <br />“Comcast does not propose any rebuilds or upgrades to the current system at <br />this time, and does not propose new upgrades to the current institutional <br />network.3” <br />This makes it impossible to evaluate Comcast’s system’s ability to meet the needs of <br />the community going into the future and the likelihood that Comcast will upgrade the <br />system as needed. This becomes important as Com cast may continue to use more of <br />its system’s capacity for non-cable TV services diminishing the ability of the cable TV <br /> <br />3 Comcast Renewal Proposal, page 57