In an FCC filing on Thursday, Comcast and General Electric said that joining NBC Sports with Comcast's Versus, Golf Channel and regional sports networks (RSNs) will yield "new opportunities ... for the combined entity to negotiate for broader rights packages."
"Combining the sports-oriented networks of NBCU and Comcast is not only good for the new NBCU, but it is good for sports fans as well, because they will have more high-quality sports programming available on more platforms at more times," Comcast and GE wrote.
The parties also indicated that NBC Sports programming would be distributed on the Comcast slew of RSNs, as well as Versus and Golf Channel. Furthermore, the two companies wrote, the RSNs could "augment" sports news offerings at the local broadcast stations linked with NBC.
Plus, opportunities for video-on-demand and online distribution could make the new NBCU a more active bidder for sports content. "The ability to distribute content across a number of different platforms also can create incentives to increase investment in sports programming ..." Comcast and GE wrote.
NBCU owns the rights to the NFL's "Sunday Night Football" and golf's U.S. Open, as well as other properties, including the Stanley Cup, which it shares with Versus.
Comcast and GE are looking for the FCC's blessing to proceed with the deal to create a joint venture -- still called NBC Universal -- where Comcast would hold a majority stake. Other government bodies will have to approve the deal. The process should take about a year.
Throughout the lengthy FCC document, Comcast and GE sought to lay out a case that the new company would be "pro-competitive." For example, the parties said the new NBCU would account for 12% of all ad dollars and affiliate fees among national cable networks -- still less than Disney/ABC, Time Warner and Viacom.
Beyond sports, the filing provided some insight into how the venture would be run. NBCU's Jeff Zucker will be CEO initially, but should he leave within three and a half years after launch, Comcast will be able to choose a replacement. GE, however, can veto up to two choices. If a stalemate ensues, the NBCU board will make the decision.
Seeking to curry favor with regulators, Comcast and GE promised to expand Spanish-language programming. Within 12 months, they will debut a new multicast channel affiliated with Telemundo with library programming. NBCU Telemundo stations will offer it and affiliates of the No. 2 Spanish-language station will also have an opportunity.
Separately, Comcast and GE said the new company will triple the length of time a program rating stays on-screen after a commercial break, claiming it will "empower families and children." Currently, NBCU networks keep the rating there for five seconds -- that will be expanded to 15.
"NBCU will also make the program ratings information more visible to viewers by making it more distinct and presenting it in larger format each time it appears on the screen," said the filing.
On issues of whether the deal will be anti-competitive, the parties said that almost six out of seven networks the Comcast cable systems will carry will not be owned by the joint venture. The suggestion is that it won't block networks that are competitive with the NBCU channels from its mass distribution base.
"There is simply no prospect of Comcast 'going it alone' and relying exclusively or even primarily on NBCU content," Comcast and GE wrote.
Refusing to carry networks that compete with NBCU outlets would "degrade" Comcast's operator business and be counterproductive, the parties said. Also, Comcast faces competition from satellite and telco TV operators that could offer networks it chooses not to carry.
Comcast and GE reiterated a commitment Comcast CEO Brian Roberts has made to maintain the decades-old broadcast model, in which NBCU would own various stations and the NBC and Telemundo networks would have affiliates.
Comcast also will guarantee the current independence of NBC News operations and keep an ombudsman as a watchdog. "Although there is no legal requirement that it do so, Comcast offers to commit to adhere in all respects to the policy and to maintain the journalistic integrity and independence of NBCU's news operations," the document said.