We’re starting to see some interesting filings at the FCC as it prepares to revamp media ownership rules — and that includes a letter sent today by a strange-bedfellows coalition of Dish Network; Time Warner Cable; activist group Free Press; the Newspaper Guild; and the American Cable Association which represents small and mid-sized operators. They’re united by a concern about TV stations that “cannot lawfully merge under the FCC’s local television rules (but) are nonetheless consolidating their core operations, staff and news production.” The group says that in cities including Denver, Peoria, and Syracuse, “TV stations have consolidated their newsrooms and newsgathering by merging their facilities and laying off dozens of journalists, crew members and other staff. The resulting news product is essentially a re-run of stories produced by another station, which reduces content diversity in terms of viewpoints, substance and issue coverage.” The writers also complain about cases where TV stations cooperatively sell ads — and negotiate retransmission consent agreements. That troubles pay TV providers and “it is a prevalent practice with at least 36 pairs of separately-owned Big 4 affiliated stations in 33 different markets, actually engaging in coordinated negotiations through use of a single (retransmission consent) bargaining representative.” The group wants the FCC to “take account of how the reduction in local broadcast competition harms local communities and markets, and to ensure that the neither the substance nor the goals of the media ownership rules are thwarted.”

The National Association of Broadcasters issued a quick response: “Evidence shows that when a strong local TV station shares resources with another broadcaster, the result is the creation of more local news, weather and sports,” spokesman Dennis Wharton says. “The simple reality is that newsgathering and public affairs programming costs money, and that viewers benefit by more choice from a TV station that is free to the public. If the goal of Free Press is to eliminate competition that local broadcasters provide to pay TV conglomerates like Time Warner Cable and DISH, perhaps it should change its name to Pay Press.”

The FCC is also hearing from others who want more consolidation: It disclosed today that the Newspaper Association of America was in last week to lobby for “the need for relief” from rules limiting the ability of a company to own a newspaper and TV stations in the same market. The group that normally likes to talk up the newspaper business provided several charts showing how steeply ad sales are falling. It included a forecast from MagnaGlobal that says newspapers will have 8.2% of the ad market in 2016, down from 12.6% in 2011.