There have been a lot of questions and some misinformation out there suggesting that our transaction with Time Warner Cable will threaten "independent voices." Here’s the real story and highlight comments from some of the nearly 30 independent programmers who have written to the FCC to express their support for the transaction.

First of all, a combined Comcast – TWC will control less than 30% of the nation’s video customers.  That’s a level that the courts have twice determined does not affect the ability of programmers to achieve successful carriage in the marketplace.  The courts have spoken so strongly on that issue, that 30% is too low a threshold, that the FCC chose not to try and set a new threshold – the courts said even 60% of customers could be too low.  It also is important to remember that in addition to the special conditions in our NBCUniversal deal, we are also subject to the same program carriage and program access rules as always.

Filings at the FCC clearly show that we have a stellar record supporting smaller, independent programmers.  Today, Comcast carries over 160 independent networks, including many small, diverse, and international ones, and six of every seven networks carried by Comcast are unaffiliated with the company.  Since 2011, Comcast has added 20 independent networks (including four independent networks with African American or Hispanic American ownership – ASPiRE, BabyFirst Americas, REVOLT, and El Rey) and has substantially expanded carriage of over 141 independent networks by an astonishing 217 million subscribers.

The facts are clear. The number of programmers who support our transaction outweigh the number who have opposed it.  In fact most of the programmers (almost all truly independent) who filed comments at the FCC support the transaction.  These programmers include Access La Porte County, BabyFirst Americas, Bedford Community Television, Berks Community Television, Cape Cod Community Media Center, Castalia Communications, C-NET, Condista, Crossings TV, El Rey, Grace Bible Center, Hallmark, INSP, JTV, Inc., New England Sports Network (NESN), Outside TV, Ovation, PBS Hawaii, REELZ, REVOLT, Rutland Region Community Television, Senior Issues, SomosTV, Starz, Television Korea 24, Inc., UnionTV34, Village of Niles, WLPC-TV Detroit, and WOCK-CD. 

Ovation states that "Comcast has the best record of any pay-TV provider in launching independent networks like Ovation, as well as many minority-owned channels, such as TV One." 

INSP adds that the transaction "will be a great development for independent networks."

Our transaction with TWC would mean that more customers will be able to see The Hallmark Channel. Their president writes that Comcast’s distribution of his networks "reflects a genuine commitment to [our programming]… One need only look at Comcast's… schedule to recognize that it similarly distributes other independent channels."

A Comcast-TWC partnership would mean that customers can watch their favorite teams on the New England Sports Network. Their President and CEO writes that, "Comcast has a strong record of supporting independent sports networks-even those that compete with Comcast's own CSN. Indeed, Comcast has never discriminated against NESN... On the contrary, Comcast is a good competitor and negotiates fairly with NESN as to both rates and carriage."

And as the CEO of Sean "Diddy" Combs’ REVOLT Network writes, "Comcast not only supported our programming development and launch efforts, but also gave REVOLT a significant ‘head start’ by providing economic support and broad distribution on Comcast's cable systems. This helped make REVOLT a viable network candidate for other distributors."

We also extend this same care and concern to regional and local-access programmers, who provide a critical viewpoint and outlet for community-specific programming.

In Illinois, the host of a local "Senior Issues" show on Channel 17 writes that Comcast’s studio facilities and broadcasting have "empowered our show by broadcasting our diverse voices to more than just Channel 17. They’ve helped give us the skills to develop our own website, editing, and graphics."

In Hawaii, the board chair of the local PBS station writes that, particularly in remote locations like his, "Hawaii needs investments from a company like Comcast to change with it. And Hawaii needs a company that will make the commitment to the special parts of Hawaii that Comcast has made to us." 

And in Massachusetts, the executive director of the Cape Cod Community Media Center writes that while corporate investments in communities can often be PR-driven, "That is absolutely not the case with Comcast. Comcast is a true and genuine community leader… We have worked on a number of projects… such as serving the homeless [through] the NOAH Shelter Telethons and numerous March of Dimes, Rotary Auctions and major community events."

We’ve been a demonstrated leader in supporting diverse programming, including national and local Spanish-language programming.  We are proud to be the nation’s largest provider of Latino packages and have a television distribution platform that delivers more than 60 Latino networks, in both Spanish and English, to our Hispanic customers.  Since the NBCUniversal transaction, Comcast has launched two independent national Hispanic-owned channels (El Rey and BabyFirst Americas) and recently, we reached a long-term agreement to distribute the Univision Deportes Network. 

As BabyFirst Americas explains, "Comcast’s support of BabyFirst Americas demonstrates the collective commitment of both Comcast and the network to bilingual education and entertainment, as well as to viewers seeking content in both English and Spanish."  

Condista Networks adds, "Comcast employees at all levels – whether at the local systems, regions, or corporate offices – have worked with our company to expand the number of independent, Spanish-language networks available on its systems."

We are lucky today to truly be in a "Golden Age" of television, there are so many programmers and content creators out there today – independent and not independent – that no provider can carry all of them.  Independent programmers today have more options for distribution than ever before.  Besides satellite and telephone company video providers (many of which carry various networks that we do not, and vice versa), independent programmers can now turn to a variety of online video distributors.  Programmers also can – and many do – distribute their programming online directly to the public.  While Comcast is a friend and partner to independent and diverse programmers from across the ecosystem, there are many choices beyond Comcast, that ensure that consumers can have access to a broad range of independent voices.

America’s independent and local programmers bring a unique and valuable voice to a diverse range of communities. We are committed to creating a positive environment for independent programmers and ensuring that independent voices are able to reach new audiences across the country.  Through the transaction with Time Warner Cable, we will continue to support these essential businesses and bring their benefits to as many Americans as possible.