Sinclair Broadcast Group Inc. and Tribune Media Co. formally hit back against opposition to the companies' proposed $6.6 billion combination, arguing that the transaction would serve the public interest by injecting sorely needed financial resources into local broadcast stations facing more competition than ever for advertising dollars.

In a 173-page Aug. 22 regulatory filing, Sinclair and Tribune said today's broadcast industry is threatened by many of the same forces that earlier upended the newspaper industry. The local advertising revenues broadcasters rely on are increasingly "challenged" by competition from online platforms and fragmented audiences, they noted.

"If broadcast companies, with their distinctly local focus and presence, are going to be able to continue to serve their communities, they will need to grow in size and scale to have the resources to invest in local news and sports (among other programming) and to advance and leverage technological innovation," Sinclair and Tribune wrote.

As proposed, the Sinclair/Tribune deal would certainly lead to greater size and scale. The combined entity would own more than 200 full power TV stations nationwide, covering 72% of U.S. homes across 108 markets.

In urging the Federal Communications Commission to block the deal, American Cable Association President and CEO Matthew Polka said Aug. 15 that the combination of the two companies "would create a broadcasting behemoth with unprecedented control over both the national and local television markets, inflicting tremendous harm to competition and consumers." The association, which represents small and midsized cable operators, has joined together with DISH Network Corp. and a collection of independent cable networks and several public interest groups to form a coalition aimed at stopping the deal.

Sinclair and Tribune argue in their filing that while opponents of the deal object to the size of the combined company, increased size and scale will be necessary if broadcasters are to survive in the evolving media market.

"Petitioners ignore the reality of the television broadcasting business in 2017, with rapidly increasing competition and alternative video options for viewers that did not exist 20 or even 10 years ago," Sinclair and Tribune wrote, adding, "Scale is not the enemy of broadcasting, stagnation is."

FCC Chairman Ajit Pai and Commissioner Michael O'Rielly, both Republicans, have similarly argued that greater scale may be necessary for broadcasters going forward, adding that the historical rules that prevented station groups from growing in size may no longer make sense. In a recent interview for C-SPAN's "The Communicators" series, O'Rielly noted that when consumers think about video content, they do not think only about the major broadcast networks. "You have a much wider swath of material headed towards their palate and they are digesting so much more from different sources," he said, adding that he would like to see the commission's rules updated.

O'Rielly acknowledged this might lead to more consolidation. "If we are able to modernize our rules, I think you'll see some properties and some assets being transferred to reflect that the marketplace is not as singular as it once was. You are talking about a very global marketplace with a lot of new players that haven't been taken into account," O'Rielly said.

Among the possible rule changes that might help Sinclair and Tribune close their deal is the review of the FCC's media ownership rules. If allowed to combine, Sinclair/Tribune would own two top-four rated affiliates in 10 of the 14 markets where Sinclair and Tribune both operate. Currently, the FCC's local TV ownership rule limits a single entity from owning more than one top-four rated station in a single market.

Additionally, the national TV ownership rule prohibits a single broadcast station group from owning TV stations that together reach more than 39% of U.S. TV households. Although Sinclair and Tribune together would reach 72% of U.S. households, the UHF discount allows stations broadcasting in the UHF spectrum — or on channels 14 to 51 — to attribute only 50% of TV households in their designated market areas toward the overall national ownership cap. As such, a combined Sinclair and Tribune would only exceed the national audience reach cap by approximately 6.5%. Pai has said the current 39% limit, last set by Congress as part of a 2004 legislation package, should be reviewed.

But even without a rule change, Sinclair and Tribune argue their deal should be allowed to proceed, as they have "agreed to voluntarily divest as necessary to comply with the local and national ownership cap rules."

While O'Rielly and Pai have signaled their support for updated rules that give broadcasters more latitude, Democratic FCC Commissioner Mignon Clyburn has argued against rule changes that enable the largest station groups to grow even larger.

"Consolidation would limit programming options for viewers, and impact local news editorial operations," Clyburn said earlier this year in regards to an expected wave of broadcast M&A. She added that consumers benefit more from competition than consolidation.

Critics of the deal have argued that Sinclair has a history of dictating a top-down, partisan approach to news coverage, pointing to the company's policy of requiring local stations to run centrally produced conservative-leaning short commentary programs such as "Behind the Headlines with Mark Hyman" and "Bottom Line with Boris," which is hosted by former Trump White House official Boris Epshteyn.

Sinclair and Tribune, though, note these commentaries represent a small fraction of total programming on Sinclair stations, with total "must-run" news programming making up approximately 2.5% of the total average news minutes per week. "The remaining 97.5% of the news program time is devoted to local news," the companies said.