A study compiled by a former FCC chief economist and issued Monday by the American Cable Association (ACA) estimates that U.S. cable consumers could face significant rate increases if the Comcast-NBC Universal (NBCU) merger is approved by the FCC without conditions. The ACA released the study as the FCC approaches the November 24 expiration of its informal 180-day “shot clock” for consideration of the $28 billion Comcast-NBCU deal, which was first announced last December. Observers say a draft order addressing the $28 billion transaction could begin circulating among the agency’s commissioners within a few weeks. Although ACA is not among the parties that have urged the FCC to reject the Comcast-NBCU deal, the trade group has called for conditions that would (1) require the merged entity to offer program rights to NBCU broadcast stations or regional sports networks on a stand-alone basis and (2) provide pay-TV system operators that are involved in retransmission disputes with the merged entity with rights to binding arbitration. An analysis of the Comcast-NBCU merger conducted by former FCC Chief Economist William Rogerson outlines potential costs to subscribers arising from both the vertical and horizontal aspects of the deal. Noting that the issues raised by ACA “have been examined by the Commission in three previous transactions and in each case [the FCC] rejected imposition of a condition on national cable networks,” a Comcast spokesman proclaimed: “there is no reason for the FCC to treat Comcast and NBCU worse than it treated Fox, DirecTV and Liberty in those recent deals.”