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CBA to FCC: Rethink Broadcast Market Definitions

“Digital revolution has expanded the competitive marketplace”

Broadcasters are continuing to share their thoughts when it comes to the changes being proposed as part of the upcoming 2018 Quadrennial Review.

The California Broadcasters Association filed comments with the Federal Communications Commission saying that the time has come to rethink the walls that have traditionally defined broadcast markets. Members of the CBA told Commissioner Michael O’Rielly and members from the other commissioners’ offices that the time had come to make a change.

[Read: NJBA Concerned About Portions of Translator Complaint Process]

“Broadcast television and broadcast radio are no longer markets unto themselves,”  wrote Gregg Skall with the firm Womble Bond Dickinson. “The commission and all government authorities must be cognizant that the digital revolution has expanded the competitive marketplace.”

Now, the CBA said, broadcast radio and television are competing with multiple forms of audio and video delivery to consumers; in some cases they are even competing with their own programming, the letter said.

It’s particularly important that the commission understand this issue when reviewing radio subcaps as part of the Quadrennial Review. Over the last few months, a number of broadcasters have weighed in on the elimination of those subcaps. For the CBA, the priority is to discard AM subcaps and AM subcaps only. “Such a revision could be critical to the survival and revitalization of AM radio,” Skall wrote.

The broadcast association was responding specifically to the call for comments in the official Notice of Proposed Rulemaking about whether AM/FM subcaps should be retained or modified and whether they are still necessary to facilitate AM revitalization. The debate is part of the every-four-years Quadrennial Review that reviews broadcast ownership rules and is used to determine whether current rules continue to be in the public interest. In this go-round, three rules are subject to review: the local radio ownership rule, the local television ownership rule and the dual network rule.

The FCC is looking for comments on the current NPRM and how the commission should retain, modify or eliminate any specific rules. Those comments are being accepted through the ECFS database using Docket Number 18-349 through April 29, 2019.

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