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Broadcasters and Advocates Present Final Arguments on Radio

As the possibility of deregulation increases, broadcasters, industry advocates, and the public are delivering their last statements regarding the FCC’s 2022 Quadrennial Review of local radio ownership regulations, revealing a variety of perspectives for the future.

Broadcaster coalitions and the National Association of Broadcasters (NAB) are united in their claim that long-standing ownership limits hinder radio’s ability to compete for audiences, advertising, and investment in an increasingly digital landscape. Conversely, some organizations are calling for caution.

In a joint filing, broadcasters from Connoisseur Media, Midwest Communications, Mid-West Family Broadcasting, Townsquare Media, Bonneville International, Legend Communications, and Frandsen Family Stations made a strong case for abolishing the Local Radio Ownership Rule. They argue that the current media environment is vastly different from when these rules were established, stating, “The empirical data… demonstrates that today’s media landscape is entirely different.” They highlight fierce competition from digital audio platforms as a significant challenge for radio broadcasters.

The broadcasters base their arguments on Section 202(h) of the Telecommunications Act of 1996, asserting that the FCC must adopt a deregulatory stance when competitive conditions change significantly. They contend that this section does not permit the Commission to tighten ownership regulations.

NAB echoes this sentiment, claiming that uneven regulations are stifling investment and creating a “vicious cycle” that hampers innovation. They point out that ownership limits hinder investment, which in turn restricts innovation and leads to audience and revenue losses.

Both NAB and the joint commenters emphasize that competition should be assessed across the entire audio and advertising market, not just traditional radio. They provide evidence showing that radio has lost more than half its audience since 2012, while digital audio consumption has surged.

In response to filings from musicFIRST Coalition, Future of Music Coalition, and the National Association of Black Owned Broadcasters, the broadcasters argue that these groups present inconsistent and economically unfounded claims. They critique musicFIRST’s stance against ownership reform while simultaneously advocating for a new terrestrial performance royalty, suggesting this would further weaken radio’s financial position.

The discussion around minority ownership is also contentious. NABOB claims that the Local Radio Ownership Rule is the FCC’s only tool to help Black-owned stations, but broadcasters counter that ownership limits do not solve the underlying issue of capital access in the industry.

Despite a surplus of available stations and low valuations, minority ownership remains stagnant, which the joint commenters attribute to regulatory barriers rather than consolidation.

Meanwhile, the National Religious Broadcasters (NRB) calls for a balanced approach, advocating for the removal of AM ownership caps while maintaining existing FM limits to protect localism and diversity in radio.

Salem Media Group suggests eliminating AM ownership caps completely while proposing a modest increase in FM ownership limits. They argue this will help maintain AM station viability and provide mid-sized broadcasters with the scale needed to compete against unregulated digital platforms.

As the FCC reviews these submissions, it is clear that nearly all broadcasting stakeholders agree that the primary competitive challenge for radio now comes from the unregulated digital ecosystem.

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