Federal Communications Commission
445 12th St SW
Washington, DC 20554
On behalf of the 65 undersigned organizations, representing low-income consumers, community-based leaders, content producers, and public interest organizations from across the country, we urge you to stop the proposed merger between Comcast and Time Warner Cable. A merger between the nation's two largest cable companies would inevitably lead to unprecedented gatekeeper control over our nation's telecommunications and media landscape. It would mean higher prices and fewer choices for broadband users and cable customers. It would put too much control over the future of the Internet and our communications infrastructure in one company's hands and would negatively impact diversity in ownership and content.
Pay-TV rates have risen for two straight decades, and Comcast's rates have gone up as fast as anyone's despite its scale. Comcast's Executive Vice President David Cohen made no promises that this merger would rein in those skyrocketing prices, saying there was no guarantee "that customer bills are going to go down or even increase less rapidly."
This deal would increase Comcast's service area to almost two-thirds of the U.S. It would allow Comcast to use its increased market power, and increased control over millions more customers, to dictate terms to broadband content providers and increase its leverage over cable programmers. To put it mildly, combining these two firms would lessen competition and harm innovation, but not improve the consumer experience.
Despite all this, Comcast is currently trying to impress Washington by claiming to provide low-cost broadband access to low income communities and by nominally embracing Net Neutrality. Yet due to barriers that limit eligibility, customer difficulty with signing up, and lack of outreach even to eligible participants, the company's Internet Essentials program has not delivered on its promises.
Comcast's commitment to Net Neutrality is also problematic to say the least. First, all broadband users deserve strong Open Internet protections, and that's only possible with Title II reclassification that applies to every broadband provider. Merger conditions that apply only to Comcast are no substitute for rules protecting everyone, no matter how strong those conditions may be. Moreover, the conditions that apply to Comcast today are not permanent. Comcast agreed to Net Neutrality conditions that run until 2018 to gain approval for its previous merger with NBCUniversal.
After 2018, those conditions expire and Comcast customers would be left without protection absent reclassification and real Net Neutrality rules. Our rights to connect and communicate should not have an expiration date. Even while these conditions have been in place, Comcast has found ways to manipulate them – using its market power to charge new tolls for Internet content and create special exemptions for its own video services. These kinds of anticompetitive practices would only grow as a result of this merger.
Comcast has a history of misrepresenting its adherence to other merger commitments, too. It has been fined for failing to fulfill the standalone broadband service commitments it also made for the NBCUniversal acquisition, and it had to be ordered by the FCC to live up to its commitments about equitable treatment for independent channels. Given this history, no amount of promises or conditions would be good enough to assuage concerns about this merger. The deal needs to be rejected outright.
The transaction is just as concerning for its negative impacts on media localism and diversity. At the state level, firms like Comcast have lobbied for "State Franchising" bills that have stripped municipalities of the power to negotiate franchise agreements with cable companies. This merger would also further the need for measures promoting diversity in ownership. The FCC's most recent statistics found that already low ownership levels for people of color have only gotten worse. Allowing Comcast to merge with Time Warner Cable would only continue the trend away from the diverse local media our communities need.
In closing, we urge the Federal Communications Commission to review the facts—this merger is not in the public interest. Hundreds of thousands of people around the country have already called on you to stop this merger and an increasing number of people around the country want the opportunity to meet with the FCC face to face to provide the data and public input crucial for informed discussions and decisions about this merger. For these reasons, we ask you to reject this deal.
Art Is Change
Broadband Alliance of Mendocino County
Cambridge Community Television
CCTV Center for Media & Democracy
Center for Digital Democracy
Center for Media Justice
Center for Rural Strategies
Common Cause Colorado
Common Cause Hawaii
Common Cause Illinois
Common Cause New York
Community Media Visioning
Democracy for America
Easton Community Access Television
Evanston Community TV
FREE! (Families Rally for Emancipation and Empowerment)
Future of Music Coalition
Global Action Project
Independent Media Publications
Institute for Local Self Reliance
Iraq Veterans Against the War
Martinez Street Women's Project
Media Action Grassroots Network (MAG-Net)
Media Literacy Project
Media Mobilizing Project
Minnesota Center for Neighborhood Organizing
National Alliance for Media Arts & Culture
National Organization for Women
Nothing Without Us
Open Technology Institute, New America Foundation
Philadelphia Student Union
Prometheus Radio Project
Rural Broadband Policy Group
St. Paul Neighborhood Network
Sports Fan Coalition
The Greenlining Institute
The Harry Potter Alliance
The Other 98%
The People's Press Project
TURN – The Utility Reform Network
Writers Guild of America East
Women in Media & News
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