Comcast today submitted a 324-page response to critics of its purchase of Time Warner Cable, telling the Federal Communications Commission that there is no reason for people to be concerned about the merger.

In an accompanying blog post, Comcast Executive VP David Cohen claimed that “virtually all” people who submitted comments to the FCC support the merger whether they know it or not.

“Virtually all commenters recognize and concede—either explicitly or through their silence—that the transaction will deliver substantial consumer welfare and public interest benefits to residential and business customers and in the advertising marketplace,” Cohen wrote.

While Comcast has supporters, the FCC proceeding on the merger is also filled with people and organizations urging the commission to block it. Critics have said a larger Comcast would be more able to overcharge rival cable companies for programming, demand bigger network interconnection payments from companies like Netflix, and block rivals from entering its territory. Critics have also said that Comcast will likely force data caps (aka "usage-based billing") on Time Warner Cable customers, as it is doing with its own customer base.

But there isn't any credible opposition to the merger, Cohen further wrote:

The opposing commenters don’t cite any credible, specific facts that refute the extensive evidence of these transaction-specific benefits. Some of the commenters fail to account for the most important economic reality of these transactions—that Comcast, Time Warner Cable, and Charter [which is involved in a related transaction] do not compete in any market, which means that there will be no reduction in competition or consumer choice for any of the services we offer. Some commenters recycle the same old "big is bad" concerns that have been voiced for almost two decades, but they ignore the innovation, investments, and competition that have resulted in a vibrant and flourishing marketplace today. These commenters make the same apocalyptic warnings, around since the 1990s, which have been repeatedly rejected by the Commission and have been proven wrong time and time again by real world results in the market.

Despite Comcast not competing against Time Warner Cable, the second biggest cable company after itself, Comcast has also argued to the FCC that it already faces enough competition.

Cohen will hold a press-only call to discuss the filing and answer reporters' questions later this morning. We'll be back with a more in-depth report after the call and after digging through Comcast's gigantic reply. In the meantime, feel free to check the filing out yourself.