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06-09-14-R
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06-09-14-R
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Executive Summary <br />FRC’s Review of Comcast’s Formal Renewal Proposal <br />© Front Range Consulting, Inc.Page 8 <br />Recently Comcast has agreed to resolve the same 6 MHz issue discussed above with the <br />Ramsey Washington cable commission by agreeing to provide an HD PEG channel now and has <br />agreed to continue the same capital and operating support payments for approximately two <br />years while the commission negotiates an informal renewal with Comcast and potentially <br />longer as negotiations continue. The current PEG capital and operating support payments in <br />the Ramsey Washington area are similar if not greater than the current NSCC capital and <br />operating support payments. It would seem logical that the suggestion that the current PEG <br />capital and operating support payments are impacting subscriber retention and acquisition has <br />been dismissed by Comcast as part of that settlement agreement with the Ramsey Washington <br />cable commission. <br />Conclusion <br />FRC has concluded that the Proposal falls woefully short on the required financial information <br />contained in the RFRP that is necessary to assess the impact on Comcast earned rate of return <br />and any impact on subscriber rates. FRC believes that many of the modifications contained in <br />the Proposal from the RFRP would likely allow Comcast to increase its profitability in the <br />franchise area and the reduction of services provided by the NSCC/NSAC. The Proposal has not <br />considered the already paid for I-Net and the impact of the recapture of analog PEG spectrum <br />which will both allow Comcast to earn additional profits. The Proposal has suggested a use of <br />the reserves that will place the NSAC in a venerable financial position and should have <br />considered the operating payments to be, at a minimum, a voluntary payment.
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