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PUBLIC DOCUMENT-TRADE SECRET DATA HAS BEEN EXCISED Comcast of Minnesota Page 20 meaning — that is, "satisfactory or sufficient and not significant."36 The FCCs 621 Order prohibited LFAs from the practice of conditioning a cable franchise on unreasonable or unsupported PEGchannel demands.�� The Staff Report, the RFRP, and the NSCC's consultant reports do not even address the subject of what would represent an "adequate" level of access but, instead, make or support a demand based on the purported aggregate desire of all PEG users and NSCC staff. The most telling evidence of actual need for PEG channels and support is found by examining the 15-year history of the current franchise's PEG usage. That evidence shows an inability to program 8 PEG channels resulting in a dilution of PEG content, loss of customer interest, and an excessive reliance on repeat and stale programming. As such, there is a demonstrated lack of need and interest in a continuation of this large allocation of PEG channels or the expansion of it proposed in the RFRP. In fact, the demonstrated low viewership in NSCC member city for PEG offerings may in fact be the result of too many PEG channels. There is a demonstrated history, as shown by channel-lineup reports obtained by Comcast, of the NSCCs inability to utilize 8 PEG channels with local, original, or fresh programming. The vast majority of current airtime on PEG networks is reserved for excessive re-runs, stale content, and non-local programming.38 Old government meetings, youths sporting games from several months earlier, and other programs are played dozens and dozens of times across more than one channel. One entire channel is dedicated to non-local NASA programming. As explained in the attached expert report of Professor Amy Sanders, this is demonstrative that fewer channels would enhance PEG programming; and 8 channels are certainly not justified.39 Stale content drives down viewers and interest, and reduces the success of PEG channels, under basic broadcasting standards. Current media consumption trends and technology also show how 36. 621 Order¶¶ 111-114. 37. Id. ¶¶ 5,110. 38. Ex. 12. Comcast's review of the programming data showed that the average city-council meeting is played 26 times. Other government meetings and sporting events are on average played 25 times and 20 times, respectively. These repeated re-broadcasts occur on multiple channels, including channels viewed by the entire NSCC area. Id. That means that at any given moment a member city resident's channel may air dozens of airings of ineetings and games having nothing to do with his or her city. 39. Ex. 6.