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<br />[97259/1] 3 <br /> <br />to local franchising authorities.4 During the negotiations between the parties in this <br />case, however, NSCC sought a higher level of complimentary services for its member- <br />cities. Specifically, it sought complimentary cable service provided to more than three <br />locations within each city.5 <br />The parties ultimately settled upon a two-part solution to their disagreement. <br />Section 2.10 of the Franchise Agreement would reflect the familiar offering made by <br />Comcast to a host community in the Twin Cities – specifically, Comcast agreed “to <br />provide Digital Starter or equivalent package of Cable Service and reception equipment <br />to up to three (3) outlets at all municipal government buildings, schools and public <br />libraries located in the City where Grantee provides Cable Service.”6 Yet, in a “Side <br />Letter” to be completed by Comcast and each NSCC member city, Comcast would <br />further agree to provide complimentary cable service to four additional “outlets at the <br />Commission Office and at each City Hall of each Member City.”7 As the Side Letter <br />explains: “These items have been negotiated in good faith and agreed to as part of the <br />informal franchise renewal process pursuant to 47 U.S.C. [§] 546(h)(2012), and <br />specifically relate to unique community needs that exist in the City.”8 <br />Beginning in December of 2016, counsel for each of the parties exchanged drafts <br />of the Side Letter and the lawyers for each side proposed revisions and additions for the <br />other party to consider.9 <br />The NSCC negotiator maintains that as part of the discussions and deliberations <br />over various drafts, he made clear to Comcast’s negotiator that a key purpose of the <br />Side Letter for the NSCC and its member-cities was to “eliminate any additional <br />charges” related to High Definition television services and equipment.10 The <br />complimentary services delivered to the NSCC and its member cities under the then- <br />current agreement, which was initially approved in 2002, included only Standard <br />Definition programming.11 <br />Under Comcast’s rate structure in late 2016, as it is today, the delivery of High <br />Definition cable television services is separately-priced and is more costly than <br />Standard Definition cable television service.12 Comcast obtains an additional $10 per <br />subscription month for providing High Definition television service to its customers.13 <br />While both High Definition television and Standard Definition television are digital <br />services, as the monikers suggest, High Definition television services provides viewers <br /> <br />4 Holmes Decl., at 2. <br />5 Id; Bradley Aff., at 2. <br />6 Id; Bradley Aff., Attach. A, at 10. <br />7 Bradley Aff., Attach. D. <br />8 Id. <br />9 See Holmes Decl., at 2-4; Bradley Aff., at 1-3. <br />10 Bradley Aff., at 2. <br />11 See Comcast’s Memorandum of Law in Support of its Motion for a Sufficient Notice of Hearing, at 4 <br />(September 19, 2014); Digital Recording (August 14, 2017). <br />12 See Holmes Decl., Attach. 4. <br />13 Id.