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Response: This appears to be some sort of "value" judgment by Comcast. The <br />NSCC/NSAC believes that these channels are used at least as much, if not substantially more <br />than most, PEG operations and have less repetitive programming and infotnercial programming <br />than other channels on the Comcast system. Comcast is attempting to impose a standard for <br />original, non -repetitive programming which it does not appear to apply to the commercial <br />programming services. <br />Comcast's proposal does eliminate a significant number of PGG channels from 8 SD <br />channels to 3 SD channels. Whether providing fewer channels meets the needs and interests of <br />the NSCC (and its member cities) will ultimately be determined by the NSCC (and its member <br />cities). <br />Argument: Comcast's investment in the local community is relevant to renewal. <br />Response: While Comcast spoke at length about its involvement in the local community, <br />it has no relevance to whether its franchises should be renewed in the NSCC area. <br />Argument: The case of Cablevision Systems v. Town of East Hampton addresses <br />substantial franchise noncompliance for franchise renewals. <br />Response: The East Hampton case has nothing to do with a franchise renewal, It <br />addressed how a town could revoke a cable franchise. Of course, federal law prescribes an <br />entirely different process and standard that we must follow for renewing a cable franchise. <br />Argument: Comcast at least implied that the NSCC must address 4 questions prior to <br />accepting or preliminarily denying the Comcast proposal. <br />Response: The 4 questions outlined by Comcast in its presentation are questions that <br />must be addressed following a preliminary assessment of the Comcast proposal. A review of the <br />2 <br />