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Page 13 PUBLIC DOCUMENT-TRADE SECRET DATA HAS BEEN EXCISED Proposal for Formal Franchise Renewal December 20, 2013 make adjustments to rates to reflect programming and other business costs as allowed by law. Comcast will not be continuing "Universal PEG Service" for customers but will provide the few customers using that service with a 6- month transition to Comcast's basic level of cable service (if they choose). J. Comcast's renewal proposal meets all criteria under the Cable Act and should be approved. The service offerings described above, along with further details provided throughout this application, clearly demonstrate that it is more-than qualified to have renewed its competitive cable franchises in the North Suburbs. Indeed, the formal renewal process was created by Congress to protect cable operators from unreasonable and excessive demands by local franchise authorities— demands very much like those set forth in the NSCC Staff Report and RFRP. Congress protected cable operators by providing procedural and substantive requirements. Under federal law, there are only 4 strictly limited grounds on which denial of renewal can be based, and none of those grounds exist. Comcast's proposal clearly fulfills these fundamental requirements. First, Comcast has complied in all material respects with the existing franchise. Second, as described in section IV, Comcast's system is high performing, comparable to any system in the country in quality. Survey results confirm very high marks in reliability, picture and sound, channel variety, and customer service. Third, as shown in sections II and III, Comcast is the largest and most experienced cable provider in the country, and its financial and technical capabilities are not in question. Fourth, as explained throughout this application, Comcast offers a system that reasonably meets the needs of the member cities' communities. Renewal should not be in dispute. Comcast, of course, submits this proposal with the understanding that further discussion by the parties will be necessary to refine certain elements of the proposal and incorporate the results of the parties' discussions into the provisions of the franchise agreements. Comcast submits this proposal under an assumption that each member city's Franchise Agreement will be the prevailing document that governs all terms and conditions by which Comcast and the NSCC will be obligated. Comcast looks forward to further discussions with the City with respect to its Proposal.