The National Association of Broadcasters filed comments yesterday with the FCC regarding media ownership reform. In their filing the NAB characterizes the proposed reforms as modest changes. What is at stake is the rule that currently bans or limits cross ownership between the newspaper-broadcast and radio-television cross-ownership rules. The NAB wants these rules eliminated. In addition the broadcasting lobby group seeks reform of the television duopoly rule.

Broadcasters "must have the flexibility to form competitively viable ownership structures," today's filing read. "Ownership rules that limit the ways broadcasters can compete in a digital, multichannel environment adversely affect stations' abilities to serve their diverse audiences and local communities."

Specifically the NAB noted that local broadcasters' more prominent competitors "enjoy dual revenue streams of both subscriber fees and advertising revenues" and are not subject to local or national ownership restrictions. "Existing ownership restrictions are not needed to ensure programming, viewpoint, source or outlet diversity in the 21st century media marketplace," the filing said.

"Today, the information market is vastly broader, including satellite television and radio and the almost infinite resources of the Internet. Consumers today easily access numerous sources and platforms for
entertainment, information and news, including political news. Simply put, it is untenable to maintain broadcast-only restrictions on the assumption that common ownership of stations could somehow reduce the ability of consumers to access diverse information or harm competition in the information marketplace.Simply put, it is untenable to maintain broadcast-only restrictions on the assumption that common ownership of stations could somehow reduce the ability of consumers to access diverse information or harm competition in the information marketplace."

While what the NAB states may seem logical at face value, the worry of cross-ownership that developed the current rules centered around a single entity essentially controlling all of the news that citizens get. The irony of the NAB stance is that they say that the competitive landscape is healthy. Two years ago the NAB argued that a merger of satellite radio would disrupt the competitive landscape. It would be interesting to see if the NAB would be in favor of allowing satellite radio to carry local advertising.

The filing is full of references to satellite radio as well as the merger between Sirius and XM. Interestingly, a lot of the NAB argument is helpful to satellite radio when the comment period about the ability to increase prices opens with the FCC this Fall. The key will be for Sirius XM to get out from under the authority of the FCC when it comes to price. The competitive landscape may not making raising prices easy, but Sirius XM would certainly like the latitude to have total control over the situation.

The entire 193 page filing can be viewed and downloaded in PDF format here.

Position - Long Sirius XM Radio