In documents that request FCC approval of the transfer of control of broadcast and other licenses held by NBC Universal (NBCU) to Comcast, the merger partners touted the public interest benefits of the proposed $30 billion transaction, as they offered a smorgasbord of voluntary commitments that are intended to alleviate the concerns of critics of the merger. These concerns include the effects of the transaction on program access, the journalistic independence of NBCU networks and stations, and the migration of educational and governmental programming to digital tiers. The FCC is expected to take up to a year to review the merger, which would create the largest producer and distributor of video programming in the nation. Describing the deal as a “contentfocused joint venture,” Comcast and NBCU promised that the combined entity (which is slated to operate under the NBCU name) would advance the FCC’s goals of diversity, localism and competition and would pose “no cognizable risk of harm in any market.” Responding to charges that Comcast-NBCU would have the incentive to discriminate against competitive multichannel video program distributors (MVPDs) that seek access to the merged company’s huge stable of program assets, Comcast and NBCU told the FCC that they would extend voluntarily the application of “key components” of the FCC’s program access rules when negotiating with MVPDs on rights to retransmit stations owned and operated by NBCU and Telemundo. Such a step, said Comcast and NBCU, “will benefit consumers by lessening uncertainties concerning continued carriage of popular broadcast programming” that was spotlighted in recent retransmission disputes pitting Time Warner Cable against News Corp. and Mediacom against Sinclair Broadcasting. While promising to maintain the journalistic independence of news programming offered on NBCU stations, Comcast and NBCU also pledged, among other things, to (1) refrain from migrating public access, educational and governmental (PEG) channels to digital cable tiers until Comcast digitizes its entire cable system, (2) add two independently-owned channels to its digital lineup each year for the next three years, and (3) continue to offer Comcast cable customers access to more than 15,000 video on demand (VOD) offerings at no additional charge and to expand that VOD lineup to 20,000 within three years of merger approval. The companies also urged the FCC to condition merger approval upon their adherence to these pledges as they reminded the FCC of its conclusion in the 2004 order approving the merger of News Corp. and DirecTV that the union of a broadcaster and an MVPD does not “present horizontal combination issues.”