The proposed Comcast-Time Warner Cable merger, if not properly regulated, is a threat to the future of rural America and independent channels.

I say that because of the clear disconnect towards rural, independent programming exhibited over the past year by Comcast’s program executives and, most recently, in their May 8 testimony before the House Judiciary subcommittee.  Comcast executive David Cohen expressed little interest in Comcast carrying programs of appeal to rural audiences, describing Comcast as “primarily an urban-clustered cable company.”

That’s a curious statement given the fact that at least one-fourth, or over 8 million homes of Comcast’s post-merger systems, will operate in America’s rural counties and/or in cities with strong western ties, affecting homes in 40 of 50 states.

I am the founder of RFD-TV, one of America’s leading independent television networks.  Currently distributed into over 40 million homes on direct broadcasting satellite and cable, the network fills a void for rural and agribusiness news, western sports, and rural lifestyle programming ignored by urban-based cable networks.  Our Washington, D.C., news bureau, located at the USDA, covers issues important to the 27 million households of those who choose to live in small-town America, while serving as a link for urban viewers to understand issues important to rural America.  RFD-TV’s Chicago news bureau focuses on America’s largest industry – agriculture – providing commodity market coverage “live” from the Chicago Mercantile Exchange for five hours each weekday.  RFD-TV’s Market Day Report and the RURAL EVENING NEWS provide valuable information that should not be blocked from any American home.

RFD-TV was the only channel dropped by Comcast on all its cable systems in Colorado and New Mexico on August 13, 2013 despite impressive Nielsen ratings, and over the strong objections from thousands of Comcast customers in these two western states.  To date, Comcast has denied all efforts by local government officials and the State of Colorado to return RFD-TV. 

Cohen’s explanation for the removal of RFD-TV was that it was a “bandwidth” issue.  Since dropping RFD-TV, Comcast has added Al Jazeera America and BBC World News not only to their cable lineups on these same systems, but nationwide as well.

The 2011 merger between Comcast and NBC Universal came with a well-intentioned mandate for Comcast to launch 10 new, independent channels.  Not addressed in 2011 were any provisions or protection for existing independent networks.  RFD-TV is presently distributed into less than 4 percent of Comcast’s 21,000,000-plus households and has lost 43 percent of its limited distribution on Comcast since the approval of the NBCUniversal merger.  No Comcast system carries RFD-HD.

Like other news/business channels, RFD-TV programs its prime time and weekends hours with general entertainment shows directed at a national audience.  In our case, this time is devoted to serving senior citizens with traditional, family-oriented programs, another category ignored by most of the other 400-plus cable channels. 

After 15 years of hard work and overcoming obstacles shared by all independent channels, I am proud to say that our Nielsen ratings consistently show RFD-TV as the #1 channel for Adults 50-plus, as well as #1 for C&D County Viewership, and #1 Time Spent Viewing – all as a percentage of the 50-plus demographic. In the most recent Independent Cable News survey of over 200 cable operators, RFD-TV was ranked #1 as “A Bargain/Most Reasonably Priced” versus all other cable channels. 

RFD-TV is a FCC/Congressional success story, as our launch was solely due to provisions mandated for public interest channels in Section 335 of the 1992 Cable Communications Act. 

I want to make it clear that I am not inherently opposed to the Comcast/Time Warner merger.  As I testified recently during the same hearing in which Comcast’s Cohen described his “urban-clustered cable company,” we fear that Comcast makes what should be a two-way conversation between rural and urban areas into a one-way street: urban-oriented programming goes out to rural America but not the other way around, and rural-to-rural communications suffer.

If the merger goes through without specific conditions protecting rural and other underserved programming, the disconnect with urban America will worsen and rural areas will continue to be deprived of news and entertainment that meets their needs and values.  RFD-TV, and other independent channels, will be blocked from nearly one-third of the country’s TV universe.

Comcast is ignoring the pleas of local governments and Comcast customers for diversity in programming.  As part of this latest Comcast merger, there is no choice but to address and expand the protection for existing independent channels that serve the public interest.

A wall built between rural and urban America is in no one’s best interest.

Gottsch is the founder of RFD-TV, the nation's first 24-hour television network dedicated to serving the needs and interests of rural America.