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Page 19 PUBLIC DOCUMENT-TRADE SECRET DATA HAS BEEN EXCISED Proposal for Formal Franchise Renewal December 20, 2013 C. The Staff Report and RFRP make demands—mostly related to the I-Net and PEG channels and operations — that are unlawful under the Cable Act. In addition to violating First-Amendment standards, many of the substantive demands in the staff report, the consultant reports, and the RFRP are unlawful under the Cable Act. Again, section 621(a) prohibits the NSCC from unreasonably refusing to award a franchise. Section 621(a)(4) of the Cable Act allows an LFA to require "adequate assurance that the cable operator will provide adequate public, educational, and governmental access channel capacity, facilities, or financial support." (Emphasis added.) In its 621 Order, the FCC, interpreting these 2 statutory provisions together, ruled that LFAs may not make unreasonable demands for PEG and I-Net support. The FCC also affirmed that an LFA must "evaluate their current and future PEG needs at the time of an incumbent provider's renewal, and are allowed to request such PEG support from their providers, within the limits of the Act and the Commission's statutory interpretation."33 PEG Channels. Congress sought to protect and further the diversity of video programming when it enacted Section 611 of the Cable Act to permit LFAs to demand PEG channels as a condition of franchise renewa1.34 Congress did not enact Section 611 to give LFAs carte blanche to demand any number of channels desired, nor did it specify the level an operator must provide. Read in light of First Amendment concerns, Section 611 permits an LFA to require the minimum number of PEG channels necessary to provide an "adequate" level of access.35 And indeed the FCC ascribed the word "adequate" its plain 33. 621 Order ¶110; Second 621 Order ¶¶12-15. 34. See 47 U.S.C. � 531; House Report at 30, reprinted in 1984 U.S.C.C.A.N. at 4667 ("Public access channels ... provide groups and individuals who generally have not had access to the electronic media with the opportunity to become sources of information in the electronic marketplace of ideas. PEG channels also contribute to an informed citizenry by bringing local schools into the home, and by showing the public local government at work."). 35. 47 U.S.C. � 541(a)(4) (allowing LFAs to require cable operators to provide "adequate assurance that the cable operator will provide adequate public, education, and governmental access channel capacity, facilities, or financial support").