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PUBLIC DOCUMENT-TRADE SECRET DATA HAS BEEN EXCISED Comcast of Minnesota LEGAL ISSUES AND OBJECTIONS REGARDING THE STAFF REPORT AND RFRP Page 14 To protect its right to continue providing cable services, and in an effort to work within the process that the NSCC staff has designed, Comcast submits this proposal despite the many significant legal issues raised by the RFRP. By submitting this proposal, Comcast does not waive any of its rights, including its right to continue to object to the RFRP on any ground in other or related proceedings. Comcast has responded to the RFRP in a variety of ways, in light of the legal issues discussed below. For example, in some cases where Comcast believes a demand is particularly unreasonable or overly burdensome, Comcast has noted its objection or provided information that reasonably responds to the demand. In other cases, to resolve differences with the NSCC staff, Comcast has gone beyond what the NSCC lawfully may require. In still other situations, Comcast has proposed alternatives that are subject to further discussions between the parties. In these and other cases, Comcast does not waive its rights to object to a particular request or requirement. Comcast states that this Proposal responds to the NSCC's Staff Report and RFRP's demands as a whole, and that Comcast reserves the right to change any elements of this Proposal if any part of the RFRP—whether by voluntary amendment by the NSCC, court order, or other means — is changed or deemed unlawful. A. The Cable Act establishes an expectation of renewal, and provides limited grounds for denial. The Cable Act has a number of goals, including the creation of "an orderly process for franchise renewal which protects operators against unfair denials of renewal."1� Another purpose is to "promote competition in cable communica- tions and minimize unnecessary regulation that would impose an undue economic burden on cable systems."15 The procedures in the Cable Act are designed to effectuate these goals, requiring a formalized process for making and evaluating a renewal proposal, and an administrative hearing and judicial review following any attempted denia1.16 It is well recognized that "[t]he Cable 14. 47 U.S.C. � 521(5). 15. Id. � 521(6). 16. Id. � 547.