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To: North Suburban Cable Commission <br />From: Michael R. Bradley <br />Re: Response to Certain Arguments Asserted by Comcast <br />Date: April 3 0, 2014 <br />Comcast made several arguments at the Public Hearing on April 17, 2014, and in <br />subsequent e-mails concerning Comcast's renewal proposal and the related public hearing. Yol <br />have asked that I review and respond to those arguments. <br />Argument: "[flhis formal process is the one that [the NSCC] triggered..." <br />Response: Comcast actually "triggered" the formal process when it sent a letter to the <br />NSCC asking for its franchise to be renewed through the formal renewal process set forth in the <br />federal Cable Act. Of course, both the NSCC and Comcast know that the NSCC has made <br />multiple attempts to renew the franchise informally, while proceeding with the formal process. <br />The NSCC remains open to continue those informal discussions to the extent progress is actually <br />being made during those discussions. <br />Argument: Requiring Comcast to fund operational expenses is an unlawful demand. <br />Response: Comcast has been funding the operations of the NSAC since at least 1991 — <br />over twenty years. The Cable Act allows the cable operator to voluntarily make operational <br />payments that can be passed through to subscribers at no cost to Comcast. <br />Argument: The PEG channels are underused and "[C]omcast offered to help [the <br />NSCC] make PEG programming more effective including by simply reducing the sheer number <br />of channels." <br />Bradley Hagen & Gullikson, LLC <br />1976 Wooddale Drive I Suite 3A I Woodbury, MN 55125 1(651) 379-0900 1 bradleylawran.com <br />