HomeMy WebLinkAbout7.a. Competitive Cable Franchise Application
EXECUTIVE SUMMARY
City Council Regular Meeting: May 16, 2016
AGENDA ITEM: Competitive Cable Franchise Application AGENDA SECTION:
Public Hearing
PREPARED BY: Emmy Foster, Assistant City Administrator
Alan Cox, Communications Coordinator AGENDA NO. 7.a.
ATTACHMENTS: Memo from City Attorney; Application from
Frontier Communications APPROVED BY: ddj
RECOMMENDED ACTION:
(1) Motion to close public hearing, accept written comments through June 15;
--AND—
(2) Motion to accept Frontier application and direct attorney and staff to negotiate franchise
terms with Frontier, prepare a report concerning Frontier’s qualifications and any legal
issues arising out of Frontier’s application, and present final recommendations for Council
action as soon as is practical
The City has received an application for a cable television franchise from Frontier Communications.
Under City policy, the City Council must conduct a public hearing to introduce the applicant and then
determine whether to direct staff to begin negotiations on the granting of a franchise.
BACKGROUND
In February, City staff was notified by Frontier, the company that provides traditional telephone service in
much of the community, that the company would like to obtain a franchise to provide cable television
service in Rosemount. The Frontier system would be in competition with the two existing franchise
holders, Charter Communications and Gigabit Minnesota (formerly known as FTTH). At staff’s request,
Bob Vose, the attorney who advises the City on cable regulation issues, reviewed existing policy on
consideration of competitive cable franchises. The attorney proposed amendments to City policy to
comply with changes in state and federal law, to reflect changes in the industry, and to keep Rosemount’s
policies aligned with its partners in the Apple Valley-Farmington-Rosemount Cable Commission.
During the April 5 regular meeting, the Council approved the amended policy. Staff then arranged for
publication of legal notices of the City’s willingness to accept applications for competitive franchises. The
notices required applications from any interested parties to be filed by May 12, and the notices set a public
hearing as required by state law for tonight’s meeting. Frontier was the only entity to file an application by
the deadline.
Frontier has filed applications with the cities of Farmington and Apple Valley, and both cities have already
conducted public hearings like the one in Rosemount tonight. Negotiations will be conducted through the
Cable Commission, but any franchise proposals must be acted on separately by the Councils. (Frontier has
also indicated it has or will apply for franchises in Lakeville and in the part of Burnsville in which the
company already provides telephone service.)
After tonight’s hearing opens, the applicant is invited to make a presentation summarizing its proposal.
2
Council members may ask the applicant questions. Other companies and members of the public may make
comments before the hearing is closed. It is recommended that the Council agree to accept written
comments on the application for the next 30 days. The Council may then consider whether to authorize
staff to negotiate with Frontier. Negotiations would take place through the Apple Valley-Farmington-
Rosemount Cable Commission.
The City Attorney has provided a brief memo with an overview of the process. It also explains the
considerations for Council members in their role as neutral and independent decision-makers for this
quasi-judicial process.
RECOMMENDATION
Staff recommends that the City Council move to close the public hearing following any comments but
agree to accept written comments for an additional 30 days. The Council may then vote on a motion to
authorize negotiations with Frontier, to instruct staff and the Attorney to prepare a report on the
company’s qualifications to operate a cable franchise and any other legal issues raised in the application;
and instruct staff and the Attorney to present a final recommendation for action by the Council.
470 U.S. Bank Plaza
200 South Sixth Street
Kennedy
Minneapolis MN 55402
&
(612) 337-9275 telephone
(612) 337-9310 fax
Graven
http://www.kennedy-graven.com
rvose@kennedy-graven.com
C H A R T E R E D
MEMORANDUM
Date: April 26, 2016
To: Apple Valley, Rosemount, Farmington Cable Commission
From: Bob Vose
Re: Frontier Franchise Application
Frontier recently approached the about obtaining franchises to
provide cable service. Minnesota law proscribes a detailed process for considering issuance of
cable franchises authorizing such service. The member cities have competitive franchising
policies that closely track applicable law.
nd
As required, the cities published notices of intent to consider franchises. On April 22, Frontier
filed timely applications and fees with Apple Valley and Farmington. A timely application is
anticipated in Rosemount. applications are responsive to the application questions.
No other companies filed applications.
The cities will review and consider financial, technical, and legal qualifications to
hold franchises and provide cable service. 47 U.S.C. § 541(a)(4)(C); Minn. Stat. § 238.081,
subd. 4. State law ensures that information addressing these
qualifications.
Public Hearings
applications. The upcoming hearings will give Frontier an opportunity to summarize its cable
franchise application and detail its cable plans. Charter Communications and the public will
have an opportunity to present comments, evidence or argument regarding plans.
s
cable system should be driven by market success, and not a contractual requirement for
However, Minn. Stat. § 238.08,
provides that additional franchise for cable service for an area included in an
those in the existing franchise pertaining to: (1) the area served; (2) public, educational, or
governmental access requirements; or (3) franchise fees.
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Charterhe end of 2015. Notwithstanding, Charter may
claim to still have sremain entitled to the protections of its prior
franchises. Additionally, s application includes several pages discussing recent FCC
actions which, Frontier claims, preempt level playing field law. At the hearing, the
companies may present evidence or argument regarding these issues.
Process Going Forward
After the public hearings are closed, we will more thoroughly review the applications, consider
the input received at the hearings, and, if so directed, begin negotiation of franchises with
Frontier. Upon completion, a financial, legal and
technical qualifications would be presented to the city councils along with the terms of any
franchise(s) that are successfully negotiated.
is quasi-judicial, meaning the city councils will
ultimately need to act as neutral and independent decision-maker
application and any opposition that may be presented by Charter or members of the public. In
re Application of Dakota Telecommunications Group, 590 N.W.2d 644, 647-8 (Minn. App.
1999). As a result, staff and legal counsel should engage in any direct negotiations or
communications with Frontier (and potentially Charter). City council members should not
communicate directly with the companies about this matter before a final decision is rendered.
Finally, it is important to remind the member cities to continue carefully following the
applicable A franchise issued via a
defective franchising process may be invalidated. Triax v. City of Nashwauk, (unpublished)
(Minn. App., December 15, 1998)(city must strictly comply with state procedural franchising
requirements).
Recommendation
At the conclusion of the upcoming hearings, I recommend that the city councils direct staff and
legal counsel to negotiate franchise terms with Frontier, prepare a report concerning
qualifications and any legal issues arising out of s application, and present final
recommendations for council action as soon as is practical.
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Jack Phillips
Director-Gov't and External Affairs
Frontier Communications
v)952-435-1373
fl 952-435-2111
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DELIVERED VIA COURIER AND E-MAIL
rvose@kennedy-graven.com
May 12, 2016
Robert J. Vose, Esq.
Kennedy& Graven
470 US Bank Plaza
200 South Sixth Street
Minneapolis, MN 55402
Re: Application of Frontier Communications of Minnesota, Inc. for Cable
Communications Services Franchise in City of Rosemount,Minnesota
Dear Mr. Vose:
In response to the City of Rosemount's published Notice of Intent to Franchise and
Request for Proposals, please find one original copy of Frontier Communications of
Minnesota, Inc.'s notarized application for a cable communications franchise in the City of
Rosemount, Minnesota. Frontier reserves the right to make and redact any information it
determines to be Trade Secret information. Also enclosed is a certified check in the
amount of$5,000 payable to the City of Rosemount in full payrnent of its application fee.
This application fee constitutes the City's "entire reasonable and necessary costs of
processing a cable communications franchise" as contemplated in Minn. Stat.
238.081 Subd.(8).
Very truly yours,
Jac i 1 s
1 : ,
00221537.DOCX/1}
CITY OF ROSEMOUNT
APPLICATION OF FRONTIER COMMUNICATIONS OF MINNESOTA, INC.
FOR A COMPETITIVE CABLE FRANCHISE
Frontier Communications of Minnesota, Inc. ("Frontier") respectfully files this
application for a competitive cable communications franchise with the City of Rosemount
pursuant to the City of Rosemount's published Notice of Intent to Franchise and Request for
Proposals this 12th day of May, 2016.
Background:
Overview of Frontier
Frontier's motto is "We can help!" Frontier goes the extra mile for our customers and is
extremely proud to serve our communities. Local engagement is more than a strategy to
Frontier. It is in our DNA. Broadband and communications are central parts of daily life
and are requirements for our communities to thrive and grow. Frontier takes seriously
our responsibility to reliably deliver these services to the millions of customers we serve.
Frontier's parent company is Frontier Communications Corporation, Frontier
Communications Corporation is a S&I' S00 cc rnpatly and is included in t11e Fc rtune
1040 list of Azn rica's largest corporations. Frontier serves a mix of urban, suburban,
and rural areas in 29 states across the United States. Frontier offers a variety of services
to customers over its fiber-optic and copper networks, including video, high-speed
internet, advanced voice and Frontier Secure digital protection solutions. Frontier
Business Edge offers communications solutions to small, medium, and enterprise
businesses.
Frontier's Values
Frontier is committed to its core value of being the leader in providing communications
services to residential and business customers in its markets by putting our customers
first, treating our customers,business partners, and employees with respect, keeping our
commitments, being accountable at all times,being ethical in all of ours dealings,being
innovative and taking the initiative, being a team player, being active in our communities,
doing right the first time and continuously improving, using resources wisely and always
having a positive attitude.
Overview of Frontier in Minnesota
Frontier is one of Minnesota's largest incumbent local exchange carriers and our
Minnesota infrastructure is critical residential customers and to the success of businesses
large and small, educational institutions, healtl care facilities and public safety agencies
in the communities we se-ve. Frontier's net Jork is essential to the support af other
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telecommunications (such as wireless carriers) and information service providers. All
Frontier products and services offer 24/7`365 support fr m a 100% U.S.-based
warkforce.
Frontier employees live and work in the Minnesota communities they serve. They are our
customers' friends and neighbors and the subject matter experts on the best
communications technology for home and business. They are customer-focused and
empowered to make the right decisions for the customer. Employees support programs
and initiatives important to their communities and live Frontier's values every day.
Burnsville is headquarters for Frontier's National Region which serves as the centralized
seven-state location for regional leadership, engineering, marketing and operational staff.
Additionally, the Burnsville office serves as the centralized location for other
administrative functions serving all of Frontier's 29 states.
Frontier is an award-winning Veteran employer and proud to support those who served
our nation. More than 1 out of every 10 Frontier employees is a veteran, reservist, and
their spouse. Frontier is a member of The Military Spouse Employrnent Partnership, The
100,000 Jobs Mission, The Employer Partnership of the Armed Forces, Honor and
Remember, and Joining Forces.
Frontier is deeply involved in the communities we serve. Recent examples include:
Major sponsor of the Burnsville International Fest.
A contributing business for the Farmington Veteran's Memorial.
The lead (and original) sponsor of the Apple Valley all-female robotics
STEM team.
Sponsor of Dakota County Fair events
Participant in South Metro home and art shows
Provide professional guidance to students, mentoring students on career
opportunities.
Active members in local chamber of commerce organizations including:
Burnsville, Apple Valley, Burnsville and Rosemount.
Active with the Dakota County Technical College in establishing the new
Telecom Technician certificate program.
Contributing sponsor supporting Burnsville's Ames Center, since 2008.
00221537.DOCX 1} _ 3 I "3 __
Creator and supporter of the America's Best Cities program, which gives
an opportunity for communities to win money to support their local
initiatives to improve their communities.
Frontier's Commitment to Our Customers
Each of Frontier's markets across the 29 states we serve has a General Manager who is
personally accountable for delivering extraordinary service. Decisions are made at the
local level taking into account local needs and interests. In the South Metro Minnesota
area, the General Manager is Steve Jones. Frontier's regional Vice President handling
Minnesota is George Meskowski. Frontier's regional, state and local leadership are
actively involved in day-to-day operations and personally see to it that customers in their
markets are receiving our best. From the CEO down, we are all accountable to our
customers every day. When storms or natural disasters strike our regions, we are among
the first to respond, and have the national resources to call upon. When members of our
community fall on tough times, we pride ourselves on being there to support them. Our
technicians work around the clock in some tough conditions to keep your services
running smoothly. Know that when a person becomes a Frontier customer, they are
signing up for over 28,600 employees at their back. Every day, our employees put the
customer first.
Frontier's Commitment to Veterans
Frontier is also an award-winning veteran employer and proud to support those who
served our nation. More than 1 out of every 10 Frontier employees is a veteran, reservist,
and/or the spouse of a veteran. Frontier is a member of The Military Spouse
Employment Partnership, The 100,000 Jobs Mission, The Employer Partnership of the
Armed Forces, Honor and Remember, and Joining Forces.
Frontier Communications of Minnesota, Inc., the applicant, is a Minnesota Corporation in
good standing and authorized to do business in the State of Minnesota.
The following responds directly to the requested information set forth in the Request for
Proposals pursuant to Minn. Stat. § 283.081Subd.(4):
A. Plans for channel capacity, including both the total number of channels
capable of being energized in the system and the number of channels to be
energized immediately.
Frontier's underlying technology allows for an almost unlimited channel capacity.
While a final channel lineup has not been finalized a this time, please see "Exhibit A-
channel lineup and programming packages" from another jurisdiction Frontier offers
service. Frontier will provide the City with a copy of the actual channel lineup prior to
launching service. Frontier also provides a robust library of Video on Demand content.
00221537.DOCX/1}4 I s
B. A statement of the television and radio broadcast signals for which
permission to carry will be requested from the Federal Communications
Commission.
Frontier will make all appropriate filings and preparations prior to the turn up of its
video service including (1) filing a community registration with the FCC via FCC Form
322; (2)providing notice to local broadcasters and requesting either must-carry or
retransmission consent election.
In its existing markets, Frontier complies with many additional federal requirements in
providing its service, including all of the FCC requirements applicable to multichannel
video programming distributors (such as equal employment opportunity and set-top box
requirements), the FCC requirements applicable to EAS participants that are wireline
video service providers, other FCC requirements applicable to provision of Vantage TV
Frontier Broadband Service in Minnesota) (such as receive-only earth station license
requirements and annual regulatory fees for IPTV providers), and the Copyright Office
requirements for cable systems filing semi-annual copyright statements of accounts and
paying statutory license fees. Frontier does not file an FCC Form 327 relating to CARS
microwave facilities because Frontier does not use such facilities in connection with the
provision of Vantage TV. Similarly, Frontier does not file FCC Form 320 and FCC
Form 321 as they relate to the use of aeronautical frequencies that are not applicable to
the IPTV technology.
In these areas where Frontier offers service, area, Frontier will negotiate retransmission
or must carry agreements with the following stations:
KTSP (ABC)
WCCO (CBS)
KMSP (FOX)
KARE (NBC)
WFTC (My Network)
WUCW (CW)
KSTC (This/Antenna)
KTCA (PBS)
WUMN (Univision)
KPXM (ION)
The planned carriage of the stations identified above could include both primary and
multicast signals of each station.
C. A description of the proposed system design and planned operation,
including at least the following items:
The following provides a general description of the technology and infrastructure:
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Frontier Communications' Vantage TV video offering is powered by Ericsson's
Mediaroom software platform. Mediaroom is the world's #1 IPTV platform—one that is
proven and widely adopted by Network Service Providers worldwide—with over 16.4
million subscriber households and 32 million connected devices running the software to
date. Vantage TV is an innovative, scalable, and highly reliable video service designed
to run over our IP enabled networks (xDSL, FTTP/FTTN, etc.). Our customers'
satisfaction has been extremely high to date—relative to our competitor's video offerings
in the same markets in which we are deployed.
Vantage TV's core product features include:
Secure delivery of SD (Standard Definition), HD (High Definition)
and 4K/UHD (Ultra High Definition) content—via integrated Digital
Rights Management—to set-top Boxes on each TV.
Superior HD, SD & UHD picture quality.
WiFi-enabled set-top boxes are also a deployment option allowing
our customers to place their TVs wherever they want in their homes.
Live TV broadcast with instant channel change allowing super-fast
navigation through our Interactive Programming Guide.
Video On-Demand library that will contain more than 100,000
movies and shows.
Total Home DVR records up to 6 shows at once and lets our
customers pause, rewind and play back live TV and store over 170
hours of HD programming. We provide our customers with up to 1
Terabyte worth of on-premise storage capacity.
Next generation EPG (Electronic Program Guide) and enhanced
search functionality deliver real time results with a rich, new visual
poster-art driven experience that allows our customers to easily
discover and consume content on their terms.
Integrated interactive applications include Social TV (access to
Twitter and Facebook), Weather, Interactive Workout, Home
Shopping Network and interactive games.
It is important to note that Vantage TV is more than just a"middleware" or a User
Interface; it is an end-to-end platform that covers all video functional dependencies starting from
Content Acquisition all the way through to Service Consumption. These are described below:
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Content Acauisition:Frontier processes Live and On-Demand content through encoders
and content packaging tools at our Video Headend in Fort Wayne, Indiana and Video
Serving Offices (VSOs) in markets that we serve. Acquisition Servers (A-Servers) in
our service delivery architecture encrypt streams, encapsulate in RTP and/or Smooth
Streaming format,and put multicast streams out on our netwark for devices to seamlessly
connect to and consume content.
Content Protection: Frontier secures all of the content it received through leveraged
Digital Rights Management (DRM) and Public Key Infrastructure (PKI) systems, which
in turn, establishes trust across its entire server environment and its set-top Box clients.
Service Management. Vantage TV leverages a complex TV Services management tool
to configure and manage subscriber information, Live TV Services, Channel Line-Up /
Channel Maps, and Video On Demand Services all from a web-based interface that our
Video Operations team controls.
Subscriber Management: Frontier integrates Vantage TV with our internal Billing and
Provisioning systems (OSS/BSS) in a seamless fashion to ensure the most efficient
customer experience. We continuously monitor the system end to end and manage
subscriber groups, entitlements, and user authentication to all content and packages,while
at aIl times protecting customer information
A subscriber group is essentially a category to which one or more client set-top boxes are
associated with. For example, a single client device might be in the following subscriber
groups: "HD-capable," "Premium Content Package," and/or "Suburban Illinois metro
area."
Subscriber groups also have Server clusters associated with them (for VOD and Linear
TV Services). For example "South Metro"might be used to associate a subscriber goup
to a set of live channels, public-access channels, and correlated to a specific set of video
distribution servers that provide content.
The TV Services Management tool then offers the ability to associate clusters of Servers
with a subscriber group and to associate subscriber groups with client devices
propagating associated content rights and entitlements).
Service Delivery: Frontier delivers high-quality Live and Video-on-Demand content
over our Managed IP Network to the customer premise. Distribution Servers (D-Servers)
in our service delivery architecture buffer streams, generate instant channel change bursts,
and do forward error packet correction.
Service Consumption: Frontier presents content to our customers' TVs in a secure and
reliable manner through Vantage TV's client software. That software, which decrypts the
stream(via SOC / System on a Chip), resides directly on our customers' set-top boxes.
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In summary, Vantage TV is an end to end software solution that enables Frontier to deliver
next-generation TV experiences including standard and high-definition/ultra-high-
definition live TV channels, video-on-demand (VOD), digital video recording(DVR) and
connected entertainment experiences to our customers.
The following responds directly to the requested information set forth in the Request for
Proposals regarding a description of the proposed system design and planned operation:
1. The general area for location of antenna and headend, if known;
Frontier has a "super head end" in Fort Wayne, Indiana which has a satellite
farm" used to download national content. This super head end has
redundancy to receive terrestrial secondary feeds from Verizon, i.e., should an
emergency interrupt service from one of its national content sources. The
national content is encoded and then deployed over diverse 10 GIG circuits to
the local head where the local content, including public, educational and
government access channels, is inserted for delivery to end users. Customers in
the City of Rosemount will be served out of the head end located in Apple
Valley. Frontier will pick up the local broadcast signals via fiber circuits
and/or will also capture those signals by antennae located at the local head end
and/or as a back-up,precautionary measure.
2. The schedule for activating cable and two-way capacity;
While an exact launch date has yet to be determined, Frontier is working
diligently to complete all necessary work and required testing and operational
readiness reviews to offer service to customers upon successful execution of a
Franchise Agreement. Frontier will meet with City to share the actual launch
date when it becomes finalized.
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3. The type of automated services to be provided;
As noted in Section B above, Frontier has provided a sample channel
lineup. See Exhibit A. This illustrates the vast selection of content
available to subscribers.
Vantage TV offers:
Incredible 100% digital picture and sound.
Total-home DVR with ability to record up to six shows at once and view
on any TV with a set-top box.
Instant channel change and super-fast navigation through our interactive
program guide and Video on Demand.
The ability to watch up to six different channels at once with Multi-View.
The ability to Pause, Fast Forward, Rewind live or recorded shows on up
to eight TVs in your house.
Next generation enhanced search which delivers real-time results by
program name, actor/actress and other keywords across Live TV, Video
On Demand and DVR recordings.
Introducing Channel Peeks which maintains full-screen viewing while
peeking" into other programming.
o Recent& DVR Peek allows you to preview and tune to any of the
last five channels or DVR recordings.
4. The number of channels and services to be made available for
access cable broadcasting; and
Frontier offers to carry the same number of PEG stations as the incumbent for
Rosemount public access, education and government.
5. A schedule of charges for facilities and staff assistance for access
cable broadcasting;
i.Frontier will make all franchised cities' access channels
available to its subscribers. For purposes of acquiring the
signal, Frontier will pick up the particular City's access
channel signals at the point(s) of origination via fiber facility
and transport such content back to the local VSO for insertion
in the channel lineup. At the point(s) of origination, Frontier
will need rack space and power for its equipment to receive
the signal(s)handed off by the City to Franchisee. Franchisee
will pay for all facilities and equipment located on its side of
the demarcation point where the City will hand off its content
to Franchisee and as is industry practice the City will be
responsible for all equipment on its side of the demarcation
point.
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D. Terms and conditions under which particular service is to be provided to
governmental and educational entities.
Frontier will provide at no charge expanded basic service to all government buildings,
schools, and public libraries located within its service footprint so long as those locations
are capable of receiving service from Frontier and no other cable provider is providing
service at such locations.
E. A schedule of proposed rates in relation to the services to be provided and
a proposed policy regarding unusual or difficult connection of services.
Final rates have yet to be determined, please see "Exhibit B- sample rates" which are
offered here for illustrative purposes.
F. A time schedule for construction of the entire system with the time
sequence for wiring the various parts of the area requested to be served.
Frontier is still finalizing its initial footprint for the deployment of cable services within
its service area in the City of Rosemount. Frontier's planned deployment is highly
confidential. Pursuant to an executed franchise agreement(s), Frontier will meet
regularly with the City and the Commission to discuss where service is available and
any plans for additional deployment. Frontier is the second operator that intends to offer
cable services throughout the City of Rosemount. There is another company with a
cable franchise in the City, but it serves only a limited portion of the City. As a second
city-wide entrant, investment in and expansion of Frontier's cable system should be
driven by market success, and not a contractual requirement for ubiquitous coverage.
The following sets forth some critical background with respect to employment of both
telecommunications and cable infrastructure. Initially, local telephone companies were
granted monopolies over local exchange service in exchange for taking on a provider of
last resort obligation- a duty to provide service - to customers in its service territory.
Similarly, with respect to video services. The incumbent video provider(and its
predecessors) operated as a monopoly over facilities-based video. In exchange for
making the capital investment to deploy facilities, the incumbent cable company got
100 percent of the customers who wanted cable television.
Subsequently, with respect to telephone services, the federal and local governments
effectively eliminated the local telephone monopolies and fostered robust competition. It
should be noted that in doing so, the telecom second entrant had absolutely no obligation
to build any facilities or to serve any particular location(s) at all. As the FCC noted,
imposing build-out requirements on new entrants in the telecommunications industry
would constitute a barrier to entry(13 FCC Red 3460, 1997). Cable companies were free
to enter the telecom market on terms that made business and economic sense to them.
This very environment was the catalyst for robust wireless and wireline competition and
the proliferation of higher broadband speeds.
00221537.DOCX/1} 1 I y ,
Congress became concerned about the lack of competition in the video world and in
1992 amended federal law to prohibit a local franchising authority from
unreasonably[y] refusing to award an additional competitive franchise." 47 U.S.C. ,¢
541(a)(1) provides a direct avenue for federal court relief in the event of such an
unreasonable refusal. 47 U.S.C. ,¢555(a) and (b). Until the advent, however, of state
statutes granting statewide cable franchises without a mandatory build requirement
e.g., Florida) or progressive cities willing to grant competitive franchises, cable
monopolies continued to the detriment of consumers and competition. Level playing
field requirements are just one example of barriers to competitive entry erected by
cities at the behest of the cable monopolies.
Courts have ruled, however, that "level playing field" provisions do not require
identical terms for new entrants. See, for example,Insight Communications v. City of
Louisville, 2003 WL 21473455 (Ky. Ct. App. 2003), where the court found: There will
never be an apple-to-apple comparison for Insight and other franchisee simply because
Insight is the incumbent which in its own right and through its predecessors has been
the exclusive provider of cable services in the City of Louisville for almost thirty years.
No new cable franchisee can ever be in the same position as a thirty-year veteran. See
also, In Cable TVFund 14 A, Ltd. v. City ofNaperville (1997 WL 209692 (N.D. Ill);
and New England Cable Television Ass'n, Inc. v. Connecticut DPUC 717 A2d 1276
1998).
In sharp contrast to the monopoly provider, a second entrant faces a significant capital
outlay with absolutely no assurance of acquiring customers; rather, it must compete
with the monopoly incumbent and win each and every customer over. As Professor
Thomas Hazlett of George Mason University has explained, "[i]ncumbents advocate
build-out requirements precisely because such rules tend to limit, rather than expand,
competition." The federal Department of Justice has also noted that "...consumers
generally are best served if market forces determine when and where competitors enter.
Regulatory restrictions and conditions on entry tend to shield incumbents from
competition and are associated with a range of economic inefficiencies including higher
production costs, reduced innovation, and distorted service choices." (Department of
Justice Ex Parte, May 10, 2006, FCC MC Dkt OS-311)
The fact is that the incumbent cable provider has (1) an established market position; (2)
all of the cable customers; and (3) an existing, in-place infrastructure. These disparate
market positions make imposing a build-out requirement on a competitive entrant bad
public policy. Under the guise of"level playing field" claims, incumbent cable operators
seek to require new entrants to duplicate the networks the incumbents built as
monopolies, knowing that such a requirement will greatly reduce, if not eliminate, the
risk of competitive entry.
In 2007, the FCC issued its findings with respect to facilities based video competition
and held as follows: (1) with respect to level playing field requirements, the FCC
oozzsss.ocx/i} 11 <; s
stated that such mandates "unreasonably impede competitive entry into the
multichannel video marketplace by requiring local franchising authorities to grant
franchises to competitors on substantially the same terms imposed on the incumbent
cable operators (Para. 138); and (2) with respect to inandatory build out, the FCC held
that "an LFA's refusal to grant a competitive franchise because of an applicant's
unwillingness to agree to unreasonable build out mandates constitutes an unreasonable
refusal to award a competitive franchise within the meaning of Section 621(a)(1) [47
U.S.C. 541(a)(1)]."
Those two FCC holdings alone should put this entire inatter to rest- level playing field
requirements and unreasonable mandatory build requirements are barriers to competitive
entry in the cable market and violate the federal Cable Act and the FCC's order.
Minnesota, however, codified its requirements in a state law and the FCC expressly
declined to "preempt" state laws addressing the cable franchising process.
It is clear, however, that the FCC did not intend to protect the Minnesota statute which
mandates the imposition of barriers to entry on each and every local franchising
authority. As various providers were trying to enter the competitive cable market and
encountering barriers such as level playing field requirements and mandatory build out
provisions,many states passed statutes to facilitate competitive entry and to prevent
local franchising authorities from erecting barriers to entry. Such laws were passed in
26 states including Florida, Missouri and North Carolina, where incumbent video
providers have taken advantage of the streamlined process to enter a market without a
mandatory build obligation. These laws have facilitated competitive entry as
evidenced, for example, by the presence of four facilities based competitors in the
Orlando, Florida market, including CenturyLink and Comcast. As such, these state
laws are aligned and not in conflict with the FCC's and Congress'policies for
promoting competition in the video distribution market.
Minnesota's cable law, however, is quite the opposite. Minnesota's cable act dates back
to the 1970s and directs each local franchising authority to impose not only a level
playing field across a broad range of issues (many of which Frontier does not oppose),
but also a five year mandatory build out requirement. Both of these provisions have
been deemed to be barriers to entry by the FCC. The incontrovertible fact is that the law
has been extremely successful in barring significant cable communications competition
in the City of Rosemount: The City of Rosemount has not experienced any significant
facilities-based competition because of the barriers to entry Minnesota codified in
Chapter 238.
In support of this position, that the FCC's 2007 Order preempts Minn. Stat. Chapter
238, Franchisee notes the following:
Conflict preemption: State law may be preempted without express
Congressional authorization to the extent it actually conflicts with federal
law where state law "stands as an obstacle to the accomplishment and
oozziss.00cx/i} 12 >
execution of the full purposes and objectives of Congress." English v.
GeneYal Elec. Co., 496 U.S. 72, 79 (1990).
Whether state law constitutes a sufficient obstacle is a matter of judgment
to be informed by examining the federal statute as a whole and
identifying its purpose and intended effects. Crosby v. Nat'/Foreign
Trade Council, 530 U.S. 363 #372 (2000).
Minn. Stat.§ 238.08 mandates terms that each municipality must
implement in granting a new or renewed cable franchise.
Minn. Stat. 238.084 sets forth the required contents of a franchise
ordinance and sets forth very precise requirements in an initial franchise
about the build: commence build within 240 days; must construct at least
50 plant miles per year; construction throughout the franchise area must
be substantially completed within 5 years of ganting the franchise; and
these requirements can be waived by the franchising authority only upon
occurrence of unforeseen events or acts of God.
Section 621(a)(1) initially gave local authorities the authority to grant
franchises,but this broad grant resulted in exclusive
franchises/monopolies. Congress "believed that exclusive franchises are
contrary to federal policy... which is intended to promote the
development of competition." H.R. Conf. Rep. No. 102-862, at 77
1992).
Legislative history clearly supports that Congress was focused on
fostering competition when it passed the 1992 Act. Qwest B oadband
Servs. Inc. v. City ofBoulder, 151 F. Supp.1236, 1244 (D. Colo. 2001).
In its 2007 order, the FCC found that "an LFA's refusal to grant a
competitive franchise because of an applicant's unwillingness to agree to
unreasonable build out mandates constitutes an unreasonable refusal to
award a competitive franchise within the meaning of Section 621(a)(1)."
The FCC order, however, targeted local and not state laws.
Arguably, the Minnesota build requirements set forth in Section
238.084(m) are in conflict with Section 621(a)(1) and are, therefore,
preempted.
In the Boulder case, the court applied Section 621's prohibition on
unreasonable refusals to grant franchises to find conflict preemption
where local rules required voter approval for any new franchises.
oozzis3.00cx i} __ 13 T `
The mandatory build out in the Minnesota statute could be considered a
de facto "unreasonable refusal" to grant a franchise and thus conflict with
the pro-competition purpose set forth in Section 621(a)(1).
In upholding the FCC's ruling, the Sixth Circuit stated that "while the
FCC] characterized build out requirements as 'eminently sensible'under
the prior regime in which cable providers were ganted community-wide
monopolies, under the current, competitive regime, these requirements
make entry so expensive that the prospective ... provider withdraws its
application and simply declines to serve any portion of the community."
Alliance for Cmty Media v. FCC, 529 F.3d 763, 771 (6th Cir. 2008).
The FCC ruling targeted local rules and actions and the FCC refrained
from preempting state regulation because it lacked "a sufficient record to
evaluate whether and how such state laws may lead to unreasonable
refusals to award additional competitive franchises." FCC Cable
Franchising Order(FCC 06-180, at n.2 &126). That is not to say,
however, that upon full consideration, the FCC would not find the
Minnesota mandatory build requirements to constitute an unreasonable
refusal under Section 621.
o The franchising laws which were being enacted about the
time of the FCC order facilitated competitive entrants into
the facilities based video market.
o In sharp contrast, the Minnesota statutes mandates
individual cities and commissions to include onerous build
out schedules which, standing alone, would run afoul of
the FCC's order.
It should also be noted that over 40 cities in Minnesota have chosen to award
competitive franchises to second entrants without satisfying all the mandates of
Chapter 23 8. See Mediacom Minnesota, LLC v. City of Prior Lake, Minn. Ct. of
Appeals, A09-1379 (Unpublished decision, Filed June 22, 2010). In October 2014, the
City of Owatonna awarded a competitive franchise to a second provider, and the
franchise did not contain the five year build requirement set forth in Chapter 238.
Rather, it contained a market success model expressly endorsed by the FCC. The
competitor will provide service to 25 percent of the City of Owatonna and will have
no further obligation to enable the provision of cable communications services until
48 percent of households in the footprint subscribe to its service.
Finally, nothing in the FCC's Order on Reconsideration released in January of this year
alters the above analysis.
oozziss.ocx/i} 14
G. A statement indicating the applicant's qualifications and experience
in the cable communications fiield, if any.
Frontier ec ln nurt icatic ns is an S:P 500 cain}any axZd i.s included in the Fortune l OQ0
list af America's largest corporations.
General Manager, Southeast Minnesota (including South Metro): Steve Jones is the
recently appointed general manager overseeing Frontier's Southeast Minnesota
operations. He has overall responsibility for the operations organization serving this area,
including customer service and community relations. He was formerly general manager
for Frontier Communication in the Wausau, Wisconsin area.
Area General Manager, Minnesota, Iowa and Nebraska: George Meskowski is
Frontier's Area General Manager with overall operations responsibility for the states of
Minnesota, Iowa and Nebraska. He lives and has his office in the South Metro area. He
has overall responsibility for the entire operations organization in the three states and is
responsible for all customer service and community relations for these areas. George was
formerly a general manager with Frontier in Michigan and Indiana prior to being
promoted to his current position in 2014.
President and Chief Executive Officer: Daniel J. McCarthy became a member of the
Frontier Board of Directors in May 2014. He has been President and Chief Operating
Officer since Apri12012 and was Executive Vice President and Chief Operating Officer
from January 2006 to Apri12012. Before this, he was Senior Vice President, Field
Operations from December 2004 to December 2005, Senior Vice President, Broadband
Operations from January 2004 to December 2004, and President and Chief Operating
Officer of Electric Lightwave from January 2002 to December 2004.
Mr. McCarthy has been with Frontier Communications Corporation since 1990, when he
joined the company's Kauai, Hawaii, electric division. In 1995, he moved to Flagstaff,
Arizona, and assumed responsibility for the company's energy operations. In 2001 he was
promoted to President and Chief Operating Officer of Citizens Public Services sector,
responsible for the company's energy and water operations. He earned a bachelor's degree
in marine engineering from the State University of New York Maritime College at Fort
Schuyler, and holds an M.B.A. from the University of Phoenix.
In October 2013, he was appointed a Trustee of The Committee for Economic
Development, a nonprofit, nonpartisan,business-led, public policy organization that
combined with The Conference Board, a nonprofit business membership and research
group organization. In December 2013, Mr. McCarthy was elected to the Board of
Trustees of Sacred Heart University in Fairfield, Connecticut. He is also a member of the
Western Connecticut Health Network Corporate Advisory Council.
Executive Vice President and Chief Financial Officer: John M. Jureller is Executive
Vice President and Chief Financial Officer. He joined Frontier Communications in
oo22iss.ocx/i} _ _ __ 15 € : ,
January 2013 as Executive Vice President and Chief Financial Officer—Elect and became
Chief Financial Officer on February 27, 2013.
From 2008 through 2012, Mr. Jureller was Senior Vice President, Finance and
Operations for the Resources Group of General Atlantic LLC, a global growth private
equity firm managing $17 billion around the globe.
Before this, he was Chief Financial Officer of WestPoint International, Inc., with overall
financial responsibility for a $900 million company. He was responsible for all financial
matters, including public financial reporting, taxation, internal audit and corporate
finance. From 2003 through 2006, Mr. Jureller was a member of the Corporate
Turnaround &Restructuring practice of AlixPartners, LLC. His responsibilities gave him
wide exposure to telecommunications, including cable, wireless and internet services.
Previously,he was Chief Financial Officer of Trans-Resources, Inc.; Senior Vice
President, Corporate Development at Gartner, Inc.; and Senior Vice President, Finance
and Corporate Development at Caribiner International, Inc. Early in his career, Mr.
Jureller held increasingly senior financial roles at PepsiCo World Trading Company, Inc.,
Emcor Group, Inc., and General Electric Capital Corporation. Mr. Jureller began his
career in finance at Bankers Trust Company. Mr. Jureller earned a B.S. with Distinction
and an M.B.A. in Finance from Cornell University. He sits on the Board of Directors of
White Plains Hospital in White Plains, New York and is a member of the hospital's
Finance Committee.
Executive Vice President, Frontier Secure and Administration: Cecilia K. McKenney
is Executive Vice President, Frontier Secure and Administration, responsible for Frontier
Secure, Human Resources, Marketing, and Product Development. Before this, she was
responsible for Human Resources, Sales Operations, Corporate Communications and
Public Relations. She was Executive Vice President, Human Resources and Call Center
Sales & Service from February 2008 to May 2012. Ms. McKenney joined the company as
Senior Vice President, Human Resources in February 2006. She is a member of the
company's Senior Leadership Team and reports to the CEO.
Frontier Secure, a service of Frontier Communications, offers products and services to
protect every aspect of digital life, including computer security, cloud backup & sharing,
the connected home, identity protection, equipment protection and 24/7 U.S.-based
premium technical support. Its products and services are sold nationwide directly to
consumers and sinall businesses, and wholesale tl rough strategic partnerships. Prior to
F'rontier, Ms. McKenney was Group Vice President of Headquarters Human Resources
for the Pepsi Bottling Group, Inc. (PBG) in Somers, New York, responsible for all
Human Resources functions supporting PBG's worldwide operations. Her organization
supported PBG's headquarters and call center in addition to providing long-term strategic
direction and day-to-day business support for Staffing, Compensation and Benefits,
Diversity, Training, Talent Development and Human Resources Systems.
Ms. McKenney joined the Pepsi-Cola Company in 1989 in its headquarters-based
employee benefits group. She became Human Resources Manager in Pepsi-Cola's
oozzisa.ocx/i}_ 16 .
Northeast Business Unit in 1992. In less than two years, Ms. McKenney transferred to
Northern California to manage HR issues for the company's San Francisco market. In
1995, she was appointed Director of Human Resources for PBG's California Business
Unit. When PBG became an independent company near the end of 1998, Ms. McKenney
was appointed Vice President, Staffing and Diversity at Company's headquarters. In
2000, she was promoted to Vice President, Headquarters Human Resources and was
named Group Vice President, Headquarters Human Resources, in 2004.
Prior to Pepsi, Ms. McKenney worked for Mutual of New York and L.F. Rothschild in
Human Resource and Management roles. She earned a bachelor's degree in business
administration from Franklin&Marshall College and is a Certified Employee Benefits
Specialist.
Ms. McKenney is a member of The Leadership Council of Franklin & Marshall College
and a member of the Board of Directors of The Child Care Council of Westchester
County, Inc. In May 2014, she was honored with the HR Leader Award in the Large
Company category at the 2014 Fairfield County HR People of the Year Awards. The
awards are given each year by The Southern Connecticut Chapter of the Society for
Human Resource Management to recognize individuals whose performance and
contributions have significantly benefited their organizations, the Human Resources
profession and the community.
Executive Vice President, External Affairs: Kathleen Quinn Abernathy is Executive
Vice President, External Affairs, responsible for the company's governmental and
regulatory affairs. From March 2010 to June 2012, she was Chief Legal Officer and
Executive Vice President, Regulatory and Governmental Affairs. Prior to joining
Frontier, she was a Partner at Wilkinson Barker Knauer LLP, advising clients on a wide
range of legal, policy and regulatory issues related to telecommunications and the media.
Before this, she was a Partner at the law firm of Akin Gump Strauss Hauer & Feld, LLP.
Ms. Abernathy served as a Commissioner with the Federal Communications Commission
FCC) from 2001-2005. While a Commissioner, she chaired the Federal-State Joint
Board on Universal Service and participated as a U.S. representative in numerous
international bilateral and multilateral negotiations, including the 2002 International
Telecommunication Union(ITU) Plenipotentiary Conference and the 2003 ITU World
Radiocommunications Conference. She was appointed by the ITU to chair the 2004 ITU
Global Symposium for Regulators.
Prior to joining the FCC, Ms. Abernathy was Vice President for Public Policy at
BroadBand Office Communications; Vice President for Regulatory Affairs at US West;
and Vice President for Federal Regulatory Affairs at AirTouch Communications. Earlier
in her career, she was Legal Advisor to two FCC commissioners and a Special Assistant
to the agency's General Counsel.
ooz21s3.ocx/i} 17 ' ;
Ms. Abernathy has received numerous honors and awards in recognition of her
contributions to the profession. In 2011 she was named one of the "Top Ten Women in
Telecom" by Fierce Telecom and honored by Legal Momentum with an "Aiming High
Award." She was featured in Chambers USA's "Leaders in their Field" in the Telecom,
Broadcast & Satellite: Regulatory category(2009); included in the Washington, DC
edition of Super Lawyers (2009, 2010); and named one of Washington's Top Lawyers by
Washingtonian magazine (2007, 2009).
Ms. Abernathy served on Frontier Communications'board of directors from Apri12006
through February 2010. She is currently on the boards of the John Gardner Fellowship
Association, which is affiliated with U.C. Berkley, and Stanford University and Children
Now. She also serves on the board of ISO New England Inc., the operator of New
England's bulk power and wholesale electricity markets.
Ms. Abernathy received her B.A. magna cum laude from Marquette University and her
J.D. from Catholic University of America's Columbus School of Law, where she was a
Distinguished Practitioner in Residence. She is a member of the District of Columbia Bar
and the Federal Communications Bar Association, of which she is a Past-President, and
has served as an adjunct professor at Georgetown University Law Center and The
Columbus School of Law.
Senior Vice President, General Counsel Secretary: Mark D. Nielsen joined Frontier in
March 2014 as Senior Vice President, General Counsel, and Secretary. Prior to this, he
was Associate General Counsel and Chief Compliance Officer for Danbury, Conn.-based
Praxair Inc. From 2007 to 2009, he was a Vice President and Assistant General Counsel
of defense contractor Raytheon Co. Before that, Mr. Nielsen served as Chief Legal
Counsel, and then Chief of Staff, to Massachusetts Governor Mitt Romney(2004-2007).
Mr. Nielsen began his legal career in 1990 as an associate with the Hartford law firm of
Murtha, Cullina LLP. He also served three two-year terms in the Connecticut Legislature,
one term in the House(1993-1995) followed by two terms in the Senate (1995-1999).
Mr. Nielsen graduated from Harvard College magna cum laude and Phi Beta Kappa. He
earned his law degree, cum laude, from Harvard Law School.
H. An identification of the municipalities (including contact information for
the municipal officials in each community) in which the applicant either
owns or operates a cable communications system, directly or indirectly, or
has outstanding franchises for which no system has been built.
Please see Exhibit C for a list of jurisdictions Frontier or an affiliate of Frontier
holds a cable franchise agreement pursuant either to local agreement or statewide
franchise authority.
oozziss.ocx/i} 18 ,
I. Plans for financing the proposed system,which must indicate every
significant anticipated source of capital and significant limitations or
conditions with respect to the availability of the indicated sources of
capital. This information should include:
1. Current financial statement
Frontier's ultimate parent company is Frontier Communications Corporation. Frontier
Communications Corporation's most recent Form 10-K (along with all other SEC
filings) may be found here: l tt%/i-es c r.fi•ntie.ct ni;ec.cfn.
2. Proposed sources and uses of funds for the construction project
Frontier's parent company is Frontier Communications Corporation. Frontier
Communications Corporation is an S&P 500 company and is included in the Foriune
1000 list of America's largest corporations with reported fourth quarter 2015 revenue
of$1,413 million and operating income of$182 million. Frontier does not require
any unique or additional funding sources (i.e.special notes or bonds) in order to
deploy its Vantage TV service in this, or any other market.
3. Financial budgets for the next three (3)years
Please see response to Section I (4)below.
4. Documentation regarding the commitment of funds, and
As a publicly traded company, Frontier releases a very limited amount of forward-
looking information for the company as a whole,but it does not provide forward-
looking information at the individual market level because it could lead to incorrect or
inappropriate assumptions or conclusions by its current and potential investors regarding
the business as a whole. Given the extremely sensitive nature of the information
contained in the requested pro forma, Frontier cannot file this information as part of its
application.
5. Any other information that applicant determines would be useful in
evaluating its fmancial qualifications.
Please see response to Section I (1) above.
J. A statement of ownership detailing the corporate organization of the
applicant,if any,including the names and addresses of officers and
directors and the number of shares held by each officer or director, and
intercompany relationship, including the parent, subsidiary or affiliated
company.
oozzisa.ocx/i} 19 I €? Tp
g
Frontier Communications of Minnesota, Inc. operates as a subsidiary of Frontier
Communications Corporation.
Frontier Communications Corporations Board of Directors believes that the purpose of
corporate governance is to ensure that Frontier maximize stockholder value in a manner
consistent with legal requirements and the highest standards of integrity. The Board has
adopted and adheres to corporate governance practices which the Board and senior
management believe promote this purpose, are sound and represent best practices. We
continually review these governance practices, Delaware law (the state in which we are
incorporated), he rules and listing standards of the NASDAQ Exchange and SEC
regulations, as well as best practices suggested by recognized governance authorities.
Frontier's Board of Directors' Code of Business Conduct and Ethics reflects Frontier's
commitment to maintain a culture of integrity, honesty and accountability when dealing
with our business partners, our customers, our stockholders and each other. It is intended
to help us focus on areas of ethical risk, recognize and deal with ethical issues, and to
provide us with the resources and procedures. The code applies to all of Frontier's
directors, officers and employees, including those at Frontier's subsidiaries and affiliates.
Directors:
Pamela D. Reeve, Chairman
Leroy T. Barnes Jr., Director
Peter C.B. Bynoe, Director
Diana S. Ferguson, Director
Edward Fraioli, Director
Daniel J. McCarthy, Director
Virginia P. Ruesterholz, Director
Howard L. Schrott, Director
Larraine D. Segil, Director
Mark Shapiro, Director
Myron A. Wick, III, Director
Officers:
00221537.DOCX/1} 2 , £; ?
Chief Executive Officer and President Daniel McCarthy
Executive Vice President, External Affairs Kathleen Quinn Abernathy
Executive Vice President and Chief Financial Officer John M. Jureller
Executive Vice President, and Chief Custom Office Cecilia K McKenney
Executive Vice President, Field Operations John Lass
Executive Vice President and Chief Technology Officer Steve Gable
Senior Vice President, General Counsel, Secretary Mark D. Nielsen
Executive Vice President and Chief People Officer Kathleen Weslock
Contact information for the members of Frontier's Board of Directors and Management,
as well as their profiles, may be found at I tt:;';'in r stc3i•.frc)n ier.c n;'ciirectc rs.f and
Frontier's Management's profiles found at h_t s°.,_'i'i1-estor.i'rc niier.c rnin a7 s€e ent.i i.
For information concerning the number of shares held by each officer or director of
Frontier, please see Frontier Communications Corporation's most recent Form 10-K
along with all other SEC filings) found at: htt 7:/:%ir ve tc r.frc ntier.cc rn%sec..;fm.
For information concerning intercompany relationships, including the parent, subsidiary
or affiliated companies please see the detailed corporate structure depicted on the
attached Exhibit D.
K. A notation and explanation of omissions or other variations with
respect to the requirements of the proposal.
None at this time.
The following responds directly to the requested information set forth in the
Rosemount Request for Proposals pursuant to Minn. Stat §238.081, subd. 2 and 4
1.Plans for channel capacity, including both the total number of channels capable of
being delivered and actually to be delivered upon system activation;
Please see Frontier's response to Section A above.
oo2zisa.ocx 1}_ 21 F
2.A statement of the television and radio broadcast signals for which permission to
carry has been obtained or will be requested from the Federal Communications
Commission;
Please see response to Section B above.
3.In the case of a telephone provider, a copy of the MPUC certificate of authority;
Please see copy of Frontier's MPUC certificate of authority attached as Exhibit D.
4.A description of the proposed system design and planned operations, including at
least the following items:
a. The location of the headend facilities from which programming will be
received:
Please see Frontier's response to Section C (1) above.
b. An explanation of the ownership of the facilities comprising the video system;
Please see Frontier's response to Section I (2) above.
c. A map identifying the proposed initial service area(s) in the City;
Please see response to Section F above.
d. A proposed schedule for expansion of service beyond the initial service area
or description of the proposed policy for such expansion;
Please see response to Section F above. A confidential Cable Availability Map is
being provided to the City's counsel.
e. The schedule far activating two-way capacity; i.e. capacity to send video
signals "up stream";
Please see response to Section C (2) above.
f. The number of channels and services to be made available for community
access broadcasting, and a proposal for providing community access
programming;
Please see response to Section C (4) above.
g. A general description of any non-video services such as telephone service,
high speed internet or data transmission services to be provided in the City.
00221537.DOCX/1} 22 I_P ,
Frontier currently does and will continue to provide voice telecommunications
service, high-speed Internet and both intrastate and interstate data
transmission(special access) services in Rosemount.
5. A proposal for funding community access programming facilities and/or staff;
Please see response to Section C (5) (i), (ii) and(iii) above.
6.The terms and conditions under which services will be provided to institutions
and identification of any plans for providing free or reduced priee video or data
transmission services or capacity or other"in-kind" services to governmental,
educational, and other institutional entities;
Please see response to Section D above.
7. A schedule of proposed service rates and proposed policy regarding changes for
unusual or difficult service connections;
Please see response to Section E above.
8. A schedule for constructing and activating the system including the sequence in
which video service will be activated in various parts of the City;
Please see response to Section F above.
9. A statement indicating the applicant's qualifications and experience in the video
services field, if any;
Please see response to Section G above.
10. Identification of and contact information for the municipalities in which the
applicant either owns or operates a video system, directly or indirectly, or holds
video franchises;
Please see Exhibit C.
11. Plans for financing the proposed system, including significant anticipated source
of capital and significant limitations or conditions with respect to the availability
of the indicated sources of capital;
Please see response to Section I above.
12. A statement detailing the corporate organization of the applicant including the
names of officers and directors, and information identifying all affiliated
companies or businesses;
00221537.DOCX/1} 23 I _' \
Please see response to Section J above.
13. A statement of form and substance acceptable to the City indemnifying the City
fully against any claims or liabilities alleged as the result of City's exercise of
these Policies and Procedures including any such claims or liabilities alleged or
asserted by the incumbent Cable Company;
Frontier is prepared to discuss the requirements and scope of the indemnification
issue in more detail with the City as part of the franchise agreement term
negotiations.
14. A notation and explanation of omissions or other variations with respect to the
application; and
None.
15. An application fee in the amount identified in the Notice of Intent to Consider
Issuance of Franchise to offset the City's cost associated with the processing
applications. Any portion of the application fee which remains after payrnent of
all the City's costs will be refunded.
Submitted by Frontier with our Application.
Subscrib and s orn to before
C 1 .
this l.(
Notary public
My Commission Expires:
o4T e.;.1VIICHELLE ANN SCHLIE
NOTARY PUBLIC
MINNESOTA
My Commisslon Expirea Jan.81,2017
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Cable Franchises Held by Frontier Communications Affiliates
State Area Covered
indiana State-issued franchise
Oregon Beaverton
Oregon Cornelius
Oregon Durham
Oregon Forest Grove
Oregon Hillsboro
Oregon King City
Oregon Lake Oswego
Oregon Rivergrove
Oregon Tigard
Oregon Tualatin
Oregon Washington County
Oregon Fairview
Oregon Gresham
Oregon Troutdale
Oregon Wood Village
Oregon City of Damascus
Oregon City of Dundee
Oregon City of Happy Valley
Oregon City of McMinnville
Oregon City of Newberg
Oregon City of Sherwood
Oregon City of Wilsonville
Oregon Clackamas County
Oregon Clackamas County
Oregon Multnomah County
Washington Bellevue
Washington Bothell
Washington Brier
Washington Camas
Washington City of Bothell
Washington City of Edmonds
Washington City of Everett
Washington City of Kenmore
Washington City of Lynnwood
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