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$\\�;:. <br /> fz. <br /> COMCAST <br /> VIA ELECTRONIC MAIL <br /> November 30, 2015 <br /> �erG" <br /> ed gv5 <br /> Mayor David Grant <br /> City of Arden Hills <br /> 1245 West Highway 96 <br /> Arden Hills, MN 55112 <br /> Dear Mayor Grant: <br /> I am writing to provide Comcast's comments regarding the CenturyLink Cable TV Franchise <br /> Ordinance that was presented for a First Reading at the October 26, 2015, City Council Meeting <br /> ("Summary' and "Proposed Franchise"). Thank you in advance for considering this input. As we <br /> have stated previously and in the public record in front of the North Suburban Cable <br /> Communications Commission (see attached), Comcast welcomes robust competition and we do <br /> not oppose the granting of an equitable cable franchise to Qwest Broadband Services or its <br /> d/b/a, CenturyLink. <br /> Comcast is however concerned with the competitive inequities created by some of the <br /> obligations in the proposed CenturyLink franchise that are materially different from the <br /> obligations in Comcast's current franchise with the City. As you are aware from the Summary, <br /> Minnesota Statute 238.08, subd. 1(b) requires that the City cannot grant an additional franchise <br /> with "terms and conditions more favorable or less burdensome than those in the existing <br /> franchise pertaining to (1) the area served..." Furthermore, the FCC expressly allows buildout <br /> requirements in franchise agreements so long as they are "reasonable."' <br /> Section 2(7) of CenturyLink's proposed franchise requires that CenturyLink build to only 15%of <br /> the City. The supporting documents, however, contains no discussion of what may be a <br /> reasonable requirement for [X] or why CenturyLink's proposal, that fails to address 85% of its <br /> citizens, meets this standard. "Less burdensome" certainly requires more than what <br /> CenturyLink has offered. And while Section 2(7) of the proposed franchise requires that "a <br /> significant number of households below the medium income of the city" it offers no instruction <br /> 1 Implementation of Section 621(a)(1) of the Cable Communications Policy Act of 1984 as amended by the Cable <br /> Television Consumer Protection and Competition Act of 1992,Order on Reconsideration, at para.?(rel.Jan 21, <br /> 2015). <br /> 10 River Park Plaza St. Paul, MN 55107 www.comcastcorporation.com <br />