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Executive Summary FRC’s Review of Comcast’s Formal Renewal Proposal © Front Range Consulting, Inc.Page 4 burdensome, and unnecessary to evaluate Comcast’s overall financial capabilities. Moreover, due to rapid and ongoing changes in technology and the cable industry, Comcast would be otherwise unable to make reliable pro forma financial projections for the life of a 10-year franchise. Nevertheless, to try to accommodate this request, Comcast has supplied a 3–year history as Exhibit 13 and subscriber information as Exhibit 16. Further, with regards to the financial projections of each year of the proposed term of the franchise, they simply referred to this response above. As such there is no data provided by Comcast that will allow any measurement of impact of meeting the future cable related needs and interests. Also Form III.D asked Comcast for information about its financial goals including historical rate of return on investment. Comcast’s response7 was: Overall financial goals for the member cities’ systems are to provide a reasonable return on existing and newly invested capital, commensurate with the anticipated risks of the business and the required returns of the capital markets. Since business and market risks change over time with the economy and as competition and technology rapidly increase, Comcast has not established a stated rate of return for the system. Actual financial returns will always be dependent upon satisfying customers with an array of service offerings delivered in an economically efficient manner. Financial returns do and will vary across cable systems as a result of competition, market characteristics, regulation, and system efficiencies. Without the required historical and pro forma financial data include data on subscriber rates and Comcast’s financial goals like return on investment, Comcast has not presented any evidence that would suggest that the RFRP requirement would be overly burdensome on subscribers and would not meet Comcast’s financial goals. Quite to contrary, Comcast avoids addressing the fact that PEG obligations are subscriber pass-throughs and will have no impact on the financial results of Comcast. Based on FRC’s analysis of subscriber rates in the NSCC franchise areas, PEG fees historically assessed to subscribers have risen at a much smaller rate of increase than has the cable rates under Comcast’s control. FRC has noted that the Proposal has improperly attempted to use the FRC Financial Analysis of Comcast Corporation8 as some sort of endorsement of Comcast financial capability to operate the cable system. The financial report was not meant to assess the financial capability of Comcast but was, as shown in the report, an attempt to ascertain the level of profitability that Comcast generates in the franchise area. With the level of profitability estimated, Comcast 7 Proposal at 45. 8 See Attachment D to the RFRP.