Today, more than seven months after filing our Applications and Public Interest Statement on the Comcast/GE joint venture relating to NBCU Universal, the formal comment period on the FCC’s review of the transaction has concluded. We filed our Public Interest Statement on January 28 when there was still snow on the ground, and now as we approach the unofficial end of summer, we look forward to the Commission examining the comprehensive record before it, and completion of an expeditious review and approval before the end of the year.
We think we’ve built an unprecedented record in support of the strong public interest benefits of this transaction. And those arguments have been supported by an unprecedented torrent of substantive positive statements in the record.
As in many prior transactions, various parties have attempted to use this review to try to advance agendas they may have on industry-wide issues, and to ventilate pre-existing grievances, that have nothing to do with this transaction. Some competitors are opportunistically trying to get the FCC to put conditions on the transaction that will give them business advantages or hamper us from competing effectively.
Not surprisingly, a few perennial critics of entertainment and communications companies have made apocalyptic predictions, just like they’ve made for years and years. The credibility of their arguments is thoroughly undercut by today’s dynamic competitive media marketplace. While some of those critics claim this transaction is unprecedented in its size, the facts show they’re simply wrong:
Also, it’s important to remember that more than three-quarters of the video customers in the U.S. don’t use Comcast, more than 80% of broadband users aren’t Comcast customers, and only 1 out of 7 channels on a typical Comcast cable system will be affiliated in any way with Comcast-NBCU after the closing of the joint venture.
Over 1,000 substantive comments supportive of this pro-consumer, pro-competitive transaction have already been filed. They’ve come from New Hampshire to Florida, Illinois to Texas, Oregon to Southern California. Over 100 federal elected officials have weighed in with support. Almost 50 mayors let the FCC know why they support Comcast and NBCU working together, from big cities like Miami, Florida to smaller ones like Tualatin, OR. Over 150 other elected officials from state and local offices all took the time to let the FCC know they this transaction is in the public interest.
We continue to be gratified by the support we’ve received from diverse organizations like the National Urban League, the Hispanic Federation, the National Puerto Rican Coalition, and the Asian Pacific Islander Caucus of the California State Legislature, to name only a few.
Support has come not just from the business community and programmers like TVOne, HipHop on Demand, and CoLours TV; and advertisers like Starcom Mediavest and Mindshare; but also from organized labor, with seven different unions submitting comments of support including IBEW Local 40, OPCMIA Local 755, Studio Utility Employees Local 724 and Southern California District Council of Laborers.
Comcast and NBCU have submitted four expert reports on the economic benefits of the deal, online video, and advertising, and detailed rebuttals of the economic analysis that certain opponents of the transaction had submitted. Other thought leaders such as University of Chicago Professor Richard A. Epstein have also submitted thorough analyses that show "there are no principled public interest grounds on which to oppose the merger’s consummation." Professor Epstein points out that many of the same groups opposed to this transaction have had "similar dire, misguided criticisms" of other mergers. The economic filings show overwhelmingly that the transaction delivers substantial consumer benefits, and that any alleged harms are highly speculative and are contradicted by the facts of the marketplace.
The benefits of this joint venture are real. It will bring about a reinvigoration of broadcasting through an infusion of new capital and energy into NBC. We’ve committed to additional local broadcast content. We’ve committed to launch new independent channels, including channels with majority ownership by African Americans and Hispanics. We’ve committed to accelerate the creation of the "anytime, anywhere" future with a wide array of high-quality content. We want to bring these benefits to American consumers as soon as possible.
to FCC Chairman Genachowski and requested the Commission conclude its review of this transaction by December 1. We believe that based on the extensive record that has been developed over the past 30 weeks, this is an achievable goal, and look forward to working with the Commission on a timely review.