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Page 15 PUBLIC DOCUMENT—TRADE SECRET DATA HAS BEEN EXCISED Proposal for Formal Franchise Renewal December 20, 2013 Act establishes a significant federal law property expectation in the renewal of a franchise."17 Substantive limitations also protect Comcast's interest in continuing to provide its cable service in the North Suburbs. The Cable Act confines grounds for denial to considerations of (A) whether the operator has substantially complied with the material terms of the existing franchise and applicable law; (B) the quality of the operator's service, in light of community needs; (C) the operator's financial, legal, and technical ability; and (D) whether the operator's proposal reasonably meets the future cable-related community needs and interests, taking into account the cost of ineeting such needs and interests.18 In addition, the franchising authority must "balance the community's need for a certain cable service against the cost of providing that service."19 Under the Cable Act, Comcast's "responsibility is to provide those facilities and services which can be shown to be in the interests of the community to receive in view of the costs thereof."20 "In assessing the costs [under § 546(c)(1)(D)], the cable operator's ability to earn a fair rate of return on its investment and the impact of such costs on subscriber rates are important considerations."zl Additionally, the FCC has interpreted the Cable Act to prevent franchising authorities from imposing excessive demands for PEG channel capacity, I-Nets, PEG operational support, payments for consultants, and the like.22 In doing so, the FCC noted a new competitive and technological reality 17. E. Telecom Corp. v. Borough East Conemaugh, 872 F.2d 30, 35 (3d Cir. 1989); see also Continental Cablevision of Mass., Inc. v. Irwin, No. 91-11256, 1991 U.S. Dist. LEXIS 21805, *8 (D. Mass. June 4, 1991) ("The Cable Communications Policy Act establishes a property right on behalf of licensed cable operators in the expectation that its franchise will be renewed."). 18. 47 U.S.C. � 546(c)(1), (d). 19. Union CATV, Inc. v. Cit�� of Sturgis, K�.,107 F. 3d 434, 440 (6th Cir. 199�. 20. Id. (quoting and emphasizing H.R.REP. No. 98-934, at 74, reprinted in 1984 U.S.C.C.A.N. at 4711). 21. Id. (quoting H.R.REP. No. 98-934, at 74, reprinted in 1984 U.S.C.C.A.N. at 4711). 22. Implementation of Section 621(a)(1) of the Cable Communications Polic� Act of 1984 as amended b� the Cable Television Consumer Protection and Competition Act of 1992, Report and Order and Further Notice of Proposed Rulemaking, 22 FCC Rcd 5101 (2006) ("621 Order"). The FCC subsequently applied this "reasonableness" standard to incumbent cable operators. In the Matter of Implementation of Section