Radio World has been publishing excerpts of various comments about radio ownership rules that have been filed in the FCC’s quadrennial review process.
The MusicFirst Coalition and the Future of Music Coalition say assertions about program diversity by the National Association of Broadcasters do not support the loosening of local radio ownership limits.
In joint comments filed earlier this year, they said the FCC should retain its limits on the number of FM stations that one entity can own per geographic market, “to protect and promote viewpoint diversity, localism and competition between local AM/FM radio broadcasters.”
These are excerpts from their comments about program diversity.
The NAB asks the commission to believe that there is a direct cause and effect relationship between AM/FM ownership consolidation and increased “program variety.” The NAB cites a 2007 study … that indicated that “more concentrated markets have fewer stations with the same format categories, and therefore more format diversity; that ‘large national radio owners offer more formats’; and that ‘common ownership results in more diversity in actual programs aired.’”
However, the Future of Music Coalition provided data in the commission’s 2006 Quadrennial Review that showed that programmatic diversity was greatest in station groups that were below their local ownership market caps. At that time, FMC found that among owners of smaller commercial radio clusters, religious format stations and Spanish-format stations were more common, as were Classical and Smooth Jazz stations.
2010 comments by FMC explained: “It appears that a wider variety of programming comes from the relatively small station groups and not the large station groups that resulted from the FCC’s signal-contour market definition. This finding casts doubt on any potential claims that larger station groups will offer the public a wider variety of programming” and supports the notion that the local radio ownership caps should not be loosened or eliminated.
The NAB commissioned a 2025 Radio Programming Study by BIA Advisory Systems that it cites to purportedly support its assertions:
“[R]adio stations continue to provide more varied programming to their local communities than they did in 1996, prior to the increase in common ownership permitted by the 1996 Act. But BIA’s new study also shows that since 2006 increases in the variety of programming have slowed down substantially, flattened or even in some cases reversed, as the 1996 local radio ownership rules have not kept pace with profound changes in the marketplace.”
The NAB goes on to assert that the sole cause of a decrease in program diversity is the commission electing to maintain the Local Radio Ownership Rule:
“These data reconfirm that the 1996 Act’s relaxation of the radio ownership restrictions and subsequent increases in common ownership of stations benefitted consumers by leading to greater programming variety in local markets. But radio broadcasters’ ability to grow any further under the three-decades-old local ownership rules constrain them from continuing to expand their programming options. This result impedes the ability of local radio broadcasters to compete for audiences and advertisers and to offer consumers more varied programming free over-the-air.”
We, as longtime observers of an AM/FM radio industry that relies heavily on recorded music as the content that it uses to draw audiences and advertisers, wholeheartedly object to the NAB’s assertion that post-2006 decreases in diversity of programming are solely attributable to the commission’s election to maintain the Local Radio Ownership Rule. …
NAB points to the commissioned BIA study showing that the number of radio formats (e.g. Adult Contemporary, Rock, Country, Contemporary Hit Radio/Top 40, etc.) available to consumers increased from 1996–2006, but that there has been a slowdown of formats offered since that time, and somehow the cause is attributable to the FCC’s local radio ownership caps, while ignoring other possible explanations … Certainly one contributing factor was that several conglomerates quickly bought up radio properties and markedly grew their holdings following 1996 deregulation, but over-leveraged themselves with self-inflicted debt in their desire to expand, leading to subsequent contraction, layoffs and a significant reduction in the numbers of programming employees.
The only thing the NAB’s data shows is that there has been an increase in the number of labels for radio format categories as reported by station personnel. It does nothing to demonstrate that, in the wake of post-1996 consolidation, there were quantitative increases in the number and variety of distinct artists or songs played on commercial radio within those formats. Nor does the commissioned BIA study address anything having to do with promoting localism in either music or news/information, or promoting viewpoint diversity in the form of music lyrics and/or culture through either song or spoken word.
Music format labels can be useful — as the NAB states in their comments, Ranchero and Tejano are distinct genres of Mexican music. But how can we measure and articulate how different Adult Contemporary is from “Hot AC”? While certainly there are distinctions and outliers within each category, artists like Adele or Sam Smith could apply to multiple formats. Adjacent formats can have a great many artists and songs in common, and crossover of hit tracks between multiple formats is highly likely.
The NAB … asks the commission to leapfrog to the conclusion that a numerical increase in categories necessarily means more programming variety for radio listeners.
We submit that these are simply labels obscuring the fact that the diversity of music, viewpoints (through music and spoken word), and local voices has decreased since 1996 radio ownership deregulation. …
A vast number of developments have transpired since 2006 to negatively affect what commercial radio listeners have the ability to hear on commercial radio airwaves. For example, in our 2023 joint comments in this docket, musicFIRST and FMC noted that several of the largest, most consolidated radio companies who had chosen to acquire high debt loads when acquiring a high volume of radio stations, namely iHeart, Audacy, Cumulus, Cox and Summit had collectively cut over 1,000 jobs in the preceding several years.
Recall that iHeart, the largest of those companies, has argued in the current and preceding Quadrennial Reviews that the local numeric caps on FM ownership should not be loosened and that such action is not the remedy that the radio industry needs in order to serve listeners with better programming.
To the extent that larger radio broadcast entities complain about their profit levels, it is important for the commission to recognize that several of these large companies with significant AM/FM holdings are spending much of their available cash servicing debt that they acquired in the wake of the last time that the ownership caps were loosened.
In the wake of the elimination of the Main Studio Rule in 2017, many stations that used to be staffed by local personnel are now, at least part-time, programmed and/or voiced remotely in order to cut costs further, thereby further diminishing the local connection that AM/FM listeners appreciate. …
Recall that FMC had noted in its 2010 comments that, at that moment in history, religious format stations, Spanish-format stations, Classical stations and Smooth Jazz stations were more prevalent among owners of smaller commercial radio clusters rather than those that were maxed out under current ownership limits.
But since then, the noncommercial Educational Media Foundation, which now owns over 1,000 broadcast signals across all 50 states, has nearly monopolized, and homogenized on a nationwide basis, the Christian Music radio airwaves, including making it so that listeners of Christian music in any given city are likely listening to exactly the same playlists and shows as Christian music listeners in another city with completely different local needs. …
Moreover, because local radio ownership caps do not apply to noncommercial stations, EMF can own more stations than its commercial counterparts are allowed to own in several markets. For example, EMF acquired eight FM frequencies including translators in the San Jose area, which also blocks out other entities who would like to be on the air from acquiring signals. Meanwhile, the commercial radio industry voluntarily elected to virtually eliminate an entire music format from the FM airwaves, namely the Smooth Jazz format that had served diverse mature audiences in large, medium and small markets for several decades.
You can read the full comments and other public filings in the Quadrennial Review at www.fcc.gov/ecfs/search/search-filings, enter 22-459 in the Proceedings field.
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