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6 <br /> <br />III. RESPONSE TO COMCAST’S CRITIQUE OF COMMUNITY NEEDS ASCERTAINMENT <br /> <br /> Comcast’s critique of the Community Needs Ascertainment report criticizes the <br />methods undertaken by TBG to gather public input. TBG conducted a telephone survey, <br />five focus groups, a survey of the focus group participants, an on-line survey of area <br />residents, and small group interviews with I-Net and PEG access stakeholders. These <br />activities provided opportunities for all residents of the NSCC franchise area, people who <br />work but do not reside in the area, and individuals with first-hand knowledge of and <br />experience with the I-Net and PEG access resources to offer their input regarding a <br />number of cable-related matters. This expansive approach to public input is essential in <br />that the Cable Act points out that the franchise renewal process should “afford the public in <br />the franchise area notice and participation.” <br /> <br /> Comcast also criticizes the conclusions regarding existing PEG Access and <br />Institutional Network resources that were based upon the consultant’s: (1) on-site <br />inspections of the PEG access facilities; (2) examination of detailed inventory and <br />operations documents; (3) discussions with and input from PEG access and I-Net staff <br />and/or stakeholders; and (4) decades of experience in this field. <br /> <br /> Comcast’s consultant, Talmey-Drake Research and Strategy, Inc., prepared a critique <br />of TBG’s research and conducted a telephone survey that it argues is superior to the <br />telephone survey conducted by Group W Communications on behalf of NSCC. It is <br />important to note that Talmey-Drake’s telephone survey of cable subscribers was the only <br />reported activity undertaken by Comcast to ascertain the cable-related needs and interests <br />of the public in the NSCC franchise area. <br /> <br /> Unlike Comcast’s limited effort to obtain public input, the TBG community needs <br />ascertainment activities sought and obtained input from elected officials and other <br />representatives of the Member Cities’ local governments; teachers and other individuals <br />associated with educational institutions in the franchise area; representatives of nonprofit, <br />civic and community organizations; leaders of health and human service organizations and <br />agencies; members of area arts, cultural, and heritage organizations; local business <br />leaders; PEG access and I-Net staff and/or stakeholders; current Comcast subscribers; <br />and residents who are currently not (or have never been) Comcast cable subscribers. <br /> <br /> Talmey-Drake’s critique relies heavily on advocacy-oriented value judgments, <br />unsubstantiated assumptions, double standards, and frequent hyperbole. In addition, <br />some elements of the Group W telephone survey that were severely criticized by Talmey- <br />Drake appear in very similar form in the telephone survey conducted by Talmey-Drake. <br /> <br />1. Talmey Drake claims that the Group W survey is “fatally flawed” because “the <br />sample did not include cell-phone-only respondents”. Group W complied with <br />the federal law that prohibits use of automatic dialing systems to contact a cell <br />phone number without prior consent. Survey research professionals have also <br />raised many other concerns about the use of cell numbers in their work. Given