Dear Mr. Roberts and Mr. Zucker:
Since the announcement late last year, the Greenlining Institute has
carefully scrutinized the proposed merger between Comcast and NBC
Universal. Our analysis over the past several months of Comcast’s
corporate practices leaves us with serious concerns over the negative
implications that a vertically integrated media corporation will have on the
nation’s communities hardest hit by the economic downturn.

In addition to the criticism expressed by legislators, regulators, consumer
advocates, and industry analysts, we believe that the proposed merger in
its current form will adversely impact the economic situation of lowincome
communities while also handicapping their ability to contribute
and consume media. As such, we have discussed these issues at length in
meetings with legislators, as well as government officials at the
Department of Justice and several commissioners at the FCC.

We would like to offer you a chance to address these serious concerns and
outline the opportunities that the proposed merger will offer to
traditionally underserved communities.

About Greenlining
As a multi-ethnic, public policy, research and advocacy institute based in
California, the Greenlining Institute’s efforts include protecting consumer
interests while partnering with some of the nation’s largest companies in
planning socially and economically viable futures. Greenlining’s coalition
includes three of the largest African-American churches in the state, the
California Hispanic Chamber of Commerce, the California Black
Chamber of Commerce, one of the nation’s largest pan-ethnic Asian
organizations, and dozens of community-based organizations stretching
from San Diego to Sacramento. Over the last 17 years, Greenlining and
its coalition have successfully partnered with the nation’s largest banks,
utilities, and telecom companies to advance mutual goals of profitability
and diversity. It is our hope that the same can be achieved with Comcast.

A Jobless Recovery and a Jobless Merger?
As Americans continue to struggle with widespread unemployment and
government officials scramble to create critical job stimulus, the American
public has reacted with a visceral feeling of dread to the proposed
Comcast-NBCU merger and the potential for more layoffs. In this
context, the reassurance that the merger will lead to ‘no massive layoffs’
appears painfully insensitive to the plight of working Americans.

Across America, low-income communities of color face
disproportionately higher unemployment rates. Consequently, lawmakers
have expressed their strong criticism for corporate actions that threaten
jobs in such fragile economic times. With concerns of a ‘jobless recovery’
on everyone’s mind, the feeble guarantee’s presented by Comcast and
NBCU beg the question of the need for ajobless merger.

Rates Rise, But Poor Service Remains
Comcast’s poor consumer protection record adds to the public’s
apprehension towards handing over the reins of a major production
company to the nation’s largest cable operator. In 2009, a Forrester
Research survey of customer satisfaction ranked Comcast at number 105
out of 113 companies. Comcast’s customers regularly face rising rates,
attributed to increases in the value of services. Such crippling rate
increases create a barrier of entry for low-income consumers to crucial
media, exacerbating the effects of digital inequality.

Meanwhile, higher rates have been accompanied by a declining quality of
service, with frustrating customer protection and diminishing choice over
content. While we stand open to substantive commitments for change,
Greenlining remains anxious of a future in which Comcast gains greater
control over the media industry while continuing business as usual in
regards to consumer protection.

Disregard for. Contracting with Diverse Businesses
In an economic downturn that has disproportionately impacted lowincome
communities of color, Comcast has not demonstrated adequate
commitment to equitable economic recovery by contracting with Diverse
Business Enterprises. Supplier diversity commitments ensure that large
corporations and small businesses can realize and maximize profits
together. Without such commitments, the economic recovery will leave
behind the nation’s traditionally underserved communities, severely
jeopardizing the diversity that is crucial in the media industry.

In California, the Public Utilities Commission’s General Order 156
requires all utilities and telecoms to report data on their supplier diversity.
While AT&T, Verizon, and Sprint all reported in 2009, Comcast
conspicuously abstained from submitting supplier diversity numbers and
only provided limited numbers in 2010. We strongly encourage Comcast
to report more detailed GO 156 data as a preliminary measure. Without a
strong dedication to equitable corporate practices, it remains to be seen
how communities of color, and thus California, will benefit from the
proposed merger.

Comcast-NBCU’s Diversity Problem
Although Comcast and NBCU have promised that the proposed merger
will enable greater product quality and innovation, both companies’ poor
history regarding diversity make such assurances sound hollow. Over the
past month, legislators repeatedly asked questions about the absence of
diversity in programming, contracts, and jobs. With only one woman and
one person of color on Comcast’s Board of Directors, Greenlining is
concerned with the lack ofminority leadership involved in the proposed
merger. As a corporation that will wield enormous influence in the media
market, a lack of diverse voices will prevent Comcast-NBCU from
incorporating minority media into its workforce, programming, and
contracting policies.

In its current form, the Greenlining Institute cannot support the proposed
Comcast-NBCU merger. We would like to extend the opportunity to meet
and discuss our concerns about the merger, and we welcome you to offer
suggestions for a greater dedication towards traditionally underserved
communities in the future.

We will follow up to set up a convenient meeting time to discuss these
issues. In the mean time, please do not hesitate to contact Samar Shah in
advance at (510) 926-4020 or samars@greenlining.org.