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Page 1 PUBLIC DOCUMENT-TRADE SECRET DATA HAS BEEN EXCISED Proposal for Formal Franchise Renewal December 20, 2013 INTRODUCTION Comcast of Minnesota ("Comcast") makes the following proposal for renewal of a cable franchise under 47 U.S.C. § 546. The Federal Cable Act requires that Comcast's application be accepted. Denial is only permitted if it is based on an established and adverse finding on 4 limited criteria: (a) whether "the cable operator has substantially complied with the material terms of the existing franchise and with applicable law"; (b) the "quality of the operator's service," (c) whether the "operator has the financial, legal, and technical ability to provide the services, facilities, and equipment as set forth in the operator's proposal"; and (d) whether "the operator's proposal is reasonable to meet the future cable-related community needs and interests, taking into account the cost of ineeting such needs and interests." Given high satisfaction rates, a high- performing system, Comcast's clear qualifications, and the many benefits provided in this proposal, Comcast's renewal should be granted. Comcast's past performance in the North Suburban Cable Communications Commission (NSCC) communities is evident in the NSCCs Staff Report's conclusion that "generally, cable subscribers in the NSCC service area indicate that they are satisfied with the Comcast cable TV service." Comcast received high ratings in picture quality, channel offerings, customer service, and responsiveness. Comcast, according to the NSCCs own evaluation, provides quality services to its subscribers. A survey study requested by Comcast confirms high general satisfaction with the current cable system. Indeed, this is due to Comcast's substantial investments in the cable system in the last decade, its role in the community as an employer and a supporter of local causes, its diverse channel offerings and high-quality picture and sound, its dedicated and experienced managers, and its competitive pricing. Similarly, the NSCC's Staff Report, along with the information supplied herein, leave no question about Comcast's qualifications to operate the cable system. However, the NSCC Staff's Report and RFRP are dominated by unsupportable demands for excessive public, educational, and government access (PEG) channel capacity, a free institutional network (I-Net) for the NSCC and member-city governments, and unlawful contributions to pay for the NSCC and NSAC's extraordinary capital and operational expenses. While the NSCC's Staff's RFRP violates the Federal Cable Act as well as the First Amendment in many of these respects, Comcast has proposed terms on these items that are both lawful and supported by the community's cable-related needs and interests, taking into account the costs.