The VPUC claimed that it could impose the blanket 550-mile line extension mandate on Comcast because it is the "largest" cable operator in Vermont and can afford it. These discriminatory conditions contravene federal and state law, amount to undue speaker-based burdens on Comcast's protected speech under the First Amendment of the United States Constitution... and deprive Comcast and its subscribers of the benefits of Vermont law enjoyed by other cable operators and their subscribers without a just and rational basis, in violation of the Common Benefits Clause of the Vermont Constitution.

Rival providers Charter and Burlington Telecom don't have to comply with these special requirements, Comcast said. Instead, the other companies "need only comply with the non-discriminatory line extension policies" established in a VPUC rule.

Comcast's complaint also objected to several other requirements in the permit, including "unreasonable demands" for upgrades to local public, educational, and governmental (PEG) access channels and the building of "institutional networks ("I-Nets") to local governmental and educational entities upon request and on non-market based terms."

The requirements will raise prices for Comcast customers, the company argues. "Together, these contested conditions would impose tens of millions of dollars in additional regulatory costs and burdens on Comcast and its Vermont cable subscribers," Comcast wrote.

Comcast often refuses to extend its network to customers outside its existing service area unless the customers pay for Comcast's construction costs, which can be tens of thousands of dollars.