Do you have strong feelings about the proposed merger of Comcast and NBC Universal? The FCC is holding a public hearing Tuesday from 1 to 8 PM at Northwestern University's Thorne Auditorium, 375 E. Chicago Avenue in Chicago.
One of the critics of the merger who'll be here testifying is Josh Silver, executive of the national media-reform organization Free Press, which has already joined other like-minded groups in petitioning the FCC to deny the merger. At my request, Silver sent me an early draft of his prepared remarks, which I offer to you here in abbreviated form. They begin with a tangent:
"There is a context at this moment in history that this agency must not ignore. Policymaking at the behest of the largest companies — across industries — is imperiling our economy, our oceans, our health, our security, indeed the very viability of our democracy and our nation. This is not hyperbole. Just look at our nation’s economy or the Gulf of Mexico for the most recent examples. In media and technology, policies made for decades at the behest of industry lobbyists have resulted in a media system dominated by companies like Comcast that overcharge customers who have no alternative providers to switch to when bills get too high or service becomes too lousy. Failure to ensure competition and reasonable prices have resulted in a nation with internet speeds that are far slower and far costlier than in other nations. In the past decade, the US has slipped from 4th to 22nd in broadband speed and affordability."
Silver then identifies Comcast as the country's "largest cable operator, largest high speed internet service provider, and one of the leading providers of regional cable sports and news networks," NBC Universal as "one of only four major national broadcast networks and one of only two national Spanish language broadcast networks." He says previous media mergers in recent decades brought "increased profit pressures that expedited the shuttering of news bureaus, journalist layoffs, and the increase in cheap-to-produce, mindless programming like Comcast’s show Hurl, about people vomiting, or reality contestants eating worms," and warns that mergers create more programming on this wretched level, not less of it.
If the FCC approves the Comcast/NBC deal, says Silver, it will be allowing "a single company to own both a huge array of popular content, and to exert excessive control over how that content — and the content produced by competitors — is distributed over the airwaves, cable, and Internet. Control over any one of these elements would be sufficient for the FCC to block the merger. Taken together, they overwhelmingly require that regulators stop the deal. By combining vast programming assets with distribution dominance, the merger would dramatically increase the incentive and ability of Comcast and NBC/Universal to raise prices, block competitive entry, force bundles on other cable systems, and discriminate in carriage of competing programming. For consumers this would spell higher prices, fewer programming and provider choices, diminished media diversity, and less innovation in budding markets, such as online video."
Silver argues that the merger "would vastly increase Comcast’s ability to inhibit emerging online video competitors," and warns that if it "decides to 'enhance' access to NBC content or to degrade access to competing content or providers, the FCC does not currently have net neutrality rules in place to protect consumers from this anticompetitive conduct...
"Locally," he continues, "the implications of the deal are equally alarming. Chicago is one of several markets where a merged Comcast/NBCU would own major cable operations and broadcast television stations in the same market. In this town, Comcast is by far the dominant cable operator and broadband internet service provider. In purchasing NBCU it would acquire — not one — but two, broadcast stations that serve Chicago — the local NBC affiliate, WSNS, and the local Telemundo affiliate, WMAQ, as well as all of the NBC-owned cable networks. That means here in Chicago, Comcast will control cable access, internet access, and nearly a quarter of all the commercial channels offered in the most popular 'expanded basic' cable package."
Silver tells the FCC that as it makes up its mind about the Comcast/NBC merger, American media are undergoing "seismic shifts in technology and market economics." Policy initiatives that should be made "include Net Neutrality, providing unlicensed spectrum, modernizing the universal service fund for broadband deployment, updating nonprofit tax code for news organizations, changing press credentialing and bankruptcy law, and reinvigorating America’s noncommercial media system.
"However, allowing the unparalleled vertical integration of massive companies like Comcast and NBC-Universal is not a positive step. Indeed, it is a step in the opposite direction that will actively deepen the problems rather than ameliorate them."
Agree? Disagree? Want to add your own voice? Go to Tuesday's hearing, and put your thoughts down here.