Comcast-NBCU Merger

Greenlining Files Petition to Deny Comcast-NBCU Merger

Comcast Corporation, General Electric Company, and NBC Universal (collectively the "Applicants") are seeking to merge Comcast’s cable and content holdings with NBC Universal’s vast content library and production facilities into a newly formed joint venture. In order to do so, they must receive approval from the FCC for the transfer of various licenses. However, before the FCC may approve the transaction, the Applicants must have met their burden of showing that the transaction serves the public interest. Applicants have not met this burden because they have failed to show that the transaction will promote diversity, localism, and competition.

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Greenlining Letter to Comcast & NBC CEOs

Greenlining Institute Oral Testimony

Oral Testimony of
Sam Kang
Managing Attorney
Greenlining Institute 

Before the
  US House of Representatives
Committee on the Judiciary 

Regarding
The Proposed Combination of Comcast and NBC-Universal

June 7, 2010

Introduction
Mr. Chairman, and Members of the Committee, My name is Samuel Kang.  It's an honor and a pleasure to be here today.

The Greenlining Institute is a non-profit advocacy organization that seeks to protect consumer interests while partnering with some of the largest companies in America to better serve this country's multi-ethnic and underserved communities.

Although there are a myriad of significant problems with this merger, I will limit my testimony to three key issues:

1)      Diversity in ownership;

2)      Impact on democracy; and

3)      What a merger would mean for the economy

I. Diversity - Ownership Gap & Its Consequences
Over the last 20 years, media consolidation has diminished independent voices and sources of information, particularly diverse voices.  Unfortunately, the proposed merger does not seem to provide much to improve this situation.

Today, only five companies own 90 percent of the top 50 cable networks, produce three-quarters of all prime time programming, and control 70 percent of the prime time television market share.  These same companies also own over 85 percent of the top 20 Internet news sites.

A recent study found that while minorities comprise 34% of the U.S. population, they own only 3% of television stations.  Approximately 12% of the nation's African American homes are in the New York City and Los Angeles markets.  However, there are no African American-owned stations in these markets.  African Americans do not even own stations in cities with large black populations like Detroit, Atlanta and New Orleans.  As a result, African American owned stations reach just 5% of the African American TV households in the US.

The problem with the lack of minority ownership is that it has a direct correlation with the lack of minority programming.

So what is Comcast's role in this?  Comcast may state that there is not a problem and point to diversity success stories like BET, TV One and Oxygen.

The reality is that despite Comcast's and NBCU's substantial holdings none of these channels is minority-owned. Many so-called "minority stations" are in fact owned by large media conglomerates. BET is owned by Viacom; Comcast holds a substantial ownership in TV One; and a large interest in Oxygen belongs to Time-Warner.

Comcast's leadership might reveal some of the reasons for this deficiency.  The company's 13-member board of directors includes only one woman and one person of color.  A report by the Hispanic Association on Corporate Responsibility gave Comcast a failing grade on the diversity of its workforce.

NBC similarly has a poor track record.  For example, NBC's CEO Jeff Zucker admitted that even though NBC runs Telemundo, one of the largest Latino TV networks in the country, they have no Latinos on the board or executive team. 

Comcast and NBC both say they are serious about diversity, but the truth is, both struggle when it comes to the number of minorities within their workforce and management who actually have the ability to hire or influence content.

II. Undermining Democracy
But why exactly is diverse programming such a vital issue?  The answer is that diverse programming has a critical impact on the health of our democracy.

In 2009, The American Economic Review published a groundbreaking study that showed Spanish-language local television news can substantially boost Hispanic voter turnout. 

Hispanic voter turnout increased by 5 to 10 percentage points in markets where Spanish-language local television news was available. Local news in Spanish caused about one in five Spanish-language news viewers who had never voted before to start voting.

The results are real and they are significant.  If you build it, they will come, and they will vote.

Unfortunately, Comcast and NBCU have a poor track record of promoting minority perspectives and preserving local content.

This is most starkly demonstrated by NBC's systematic dismantling of Spanish-language stations after NBC took over Telemundo.  In December 2006, NBCU eliminated locally produced Telemundo newscasts in seven markets.  They were instead replaced with regional content transmitting from consolidated hubs.

The markets that were gutted of its local programming included Houston, Dallas, San Antonio, San Jose and Phoenix.  The gutting consisted of terminating dozens of reporters, camerapersons, production team members, and producers.  These markets, alone, comprised five of the top ten Hispanic markets in the country.

In response to audience outrage, NBCU brought back four local Telemundo newscasts in February 2010 - Dallas, Houston, San Jose and Phoenix.  However, these newscasts rely on reports and images received from NBC news sources, not Telemundo's.  Only a smattering of content is locally produced and the resources are still threadbare.

Comcast has demonstrated a similar penchant to cut local content.  In 2008, Comcast consolidated operations in Denver, Colorado, and gutted local coverage of nearby Colorado Springs.  That same year, Comcast consolidated its east-coast operations, cutting 300 positions by combining six regions into four. 

In 2009, Comcast took a hatchet to New England Cable News, and most recently did it again to Sarasota and Fort Myers-Naples in Florida.

What is most disturbing about these practices is that both NBCU and Comcast seem proud about their track record.  The proposed marriage of NBCU and Comcast is a union of two corporations that operate by a remarkably similar modus operandi - gut, cut, and strut.

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