As part of an early pitch to federal regulators who will be scrutinizing its proposed acquisition of a controlling interest in NBCU, Comcast says it is fully committed to TV broadcasting and that it will work with NBC affiliates in finding ways to sustain the free, over-the-air service.

"Notwithstanding the turbulence in the current media marketplace and the ongoing threats to the business model of a national broadcast network, [Comcast] remains committed to continuing to provide free over-the-air television through its O&O stations and through local broadcast affiliates across the nation," says Comcast Executive Vice President David Cohen in a "regulatory letter" released this morning along with details of the deal that will make Comcast the 51-percent owner of NBCU.

"As we negotiate to renew agreements with our broadcast affiliates, we will continue our cooperative dialogue with our affiliates toward a business model to sustain free over-the-air service that can be workable in the evolving economic and technological environment," the letter says.

To consummate its takeover of NBCU, Comcast must win the approval of the antitrust regulators and the FCC. Cohen's letter is Comcast's opening argument.

The letter also says Comcast is committed to localism. "We intend to preserve and enrich the output of local news, local public affairs and other public interest programming on NBC O&O stations," it says.

"Through the use of Comcast's On Demand and On Demand Online platforms, times slots of cable channels, and use of certain windows on the O&Os schedules, we believe we can expand the availability of all types of local and public interest programming."

The letter says that Comcast will also use its On Demand platform to provide NBCU broadcast content "at no cost to the consumer."

Comcast is "very proud" of Telemundo, NBCU's Spanish-language broadcast network, the letter says. "We intend to expand the availability of over-the-air programming to the Hispanic community utilizing a portion of the digital broadcast spectrum of the Telemundo O&Os (as well as offering it to Telemundo affiliates) ...."

The letter vows that Comcast will continue General Electric's hands-off policy toward NBC News. "To insure such independence, the [NBCU] will continue in effect the position and authority of the NBC News ombudsman to address any issues that may arise."

Comcast will expand its commitment to programming for children and parents, the letter says. "We will use Comcast's On Demand and On Demand Online platforms and a portion of the NBC O&Os' digital broadcast spectrum to speak to kids."

The letter promises to provide "clear and understandable on-screen" program ratings and to work with Common Sense Media, which it describes as a "highly respected organization offering enhanced information to help guide family viewing decisions."

Seeking to calm the unions, the letter promises to honor all of NBCU's collective bargaining agreements. "We respect NBCU's existing labor-management relationships and expect them to continue following the closing of this transaction."