Somewhat confused arguments, in that they address local ownership caps and
national caps, without clear distinction, it seems.
"The NAB added, 'Due to digital technologies' transformation of the delivery of
media content and the sale of advertising, the FCC must reevaluate how it
defines the markets in which broadcast TV stations compete for audiences and
advertisers... The local TV rule therefore must reflect that stations today
compete for audiences in a market including, at the least, terrestrial
broadcasters, pay-TV providers and providers of video programming over the
internet and to mobile devices...'"
Okay, and relaxing local ownership caps would also cause consolidation of TV
stations in individual markets. Fewer voices heard on local TV, which some
broadcasters insist, is a major source of news for TV markets. Although it's
true that there are plenty of other sources available, these days. So, if
broadcasters really want to reduce their importance, local consolidation like
they want could easily allow that to happen. People would find it easier to
dismiss all local stations, if they thought they were all made to report the
news the same way, or transmit programs with the same political bias.
"The FCC's ownership rules prevent TV stations-but not their competitors-from
achieving needed economies of scale," the NAB continued. "Without regulatory
relief, the FCC places at risk the new and other locally-oriented services
offered by broadcast TV stations that it professes to value."
That economies of scale argument works best in the national cap debate, not the
local cap debate. And the "localism" angle doesn't work at all in either
debate. I'm not sure why they even brought it up. "Locally oriented" services
would be in jeopardy whenever the news medium consolidates too much, as would
"diversity of ownership," which can easily be argued to be essential for any
sort of "localism." (I continue to believe that "localism" is one of those
empty buzzwords people throw out, no matter what they are trying to argue.
Especially the FCC Chairman, who then always does his best to make sure that
his actions go precisely against his words.)
"ACA Connects-a collection of cable, phone and fiber-to-the-home
operators-meanwhile, looked at the possible rule changes in terms of
retransmission and potential harm that could come from rule changes to the
national cap, or to mergers that would result in national consolidation.
'Relaxing the cap will cause significant consumer harm-harm that would have to
be outweighed by corresponding consumer benefits,' ACA's comments read."
As long as the local caps are enforced, I don't see what great harm relaxed
national caps could have. Back to the old "let's pretend" game broadcasters
play. Let's pretend that all of the TV network content, especially the high
value content that makes people want to tune in, is produced and owned by
individual local broadcast stations. As if. The national caps, if anything, are
the farce here. National caps, at 39%, mean nothing. People watch the same ABC,
CBS, NBC, or Fox content, nationwide, and have been, for decades.
"To address this, ACA Connects suggested in its comments that the FCC obtain
retransmission consent data and have the Office of Economics and Analytics
conduct an econometric analysis to balance the harms and benefits of relaxing
the national cap."
Proving my point. Retransmission consent works only because the local MVPDs
want high value content from the TV networks. Let's not fool ourselves, for
heaven's sake. Retrans consent data proves nothing about "harm of relaxing
national cap." It is merely a scheme whereby local broadcasters are allowed to
behave as the local gatekeepers, for national TV network content. What do they
expect retrans consent data to show?
Bert
-------------------------------------------------
https://www.tvtechnology.com/news/broadcasters-to-fcc-bring-local-tv-ownership-into-the-21st-century
Broadcasters to FCC: Bring Local TV Ownership into the 21st Century
Modern media marketplace makes current rules outdated.
Michael Balderston 9 hours ago
WASHINGTON-Broadcasters' chief lobbyist reminded the FCC this week that the
current media landscape has rendered the commission's TV ownership rules
obsolete.
"Given the rapidly evolving marketplace, the current version of the local TV
ownership rule is no longer necessary in the public interest as the result of
competition," the National Association of Broadcasters told the FCC in comments
to the FCC's 2018 Quadrennial Review on broadcast ownership rules. The comment
window closed on Monday, April 29, and those filed by broadcasters and other
organizations often cite a key consideration for any regulations of the
ownership rules: competition.
The NAB added, "Due to digital technologies' transformation of the delivery of
media content and the sale of advertising, the FCC must reevaluate how it
defines the markets in which broadcast TV stations compete for audiences and
advertisers... The local TV rule therefore must reflect that stations today
compete for audiences in a market including, at the least, terrestrial
broadcasters, pay-TV providers and providers of video programming over the
internet and to mobile devices... Counting only broadcast TV stations as
relevant competitors would define the market as if it were still 1940, when the
FCC prohibited common ownership of two TV stations in 'substantially the same
service area.'
"The FCC's ownership rules prevent TV stations-but not their competitors-from
achieving needed economies of scale," the NAB continued. "Without regulatory
relief, the FCC places at risk the new and other locally-oriented services
offered by broadcast TV stations that it professes to value."
Broadcasting company TEGNA Inc. shares the NAB's viewpoint and stated as such
in its filed comments following meetings with FCC Chairman Ajit Pai. TEGNA
wrote that the new competition facing broadcasters must be taken into account
as to whether "the unique ownership restrictions imposed on broadcasters can
continue to be justified as serving the public interest."
However, there are some that believe the removal of ownership restrictions
could impact not just competition but the ownership diversity.
"The FCC has consistently failed to examine race and gender diversity when it
comes to broadcast ownership," said Yosef Getachew, director of Media and
Democracy Program for Commons Cause. "Without properly assessing the impact of
ownership diversity, the FCC has abandoned many of its media ownership rules,
which will result in more consolidation and fewer diverse and independent
voices in the marketplace. The elimination of media ownership rules will also
harm localism and competition-values the Commission is statutorily obligated to
uphold."
ACA Connects-a collection of cable, phone and fiber-to-the-home
operators-meanwhile, looked at the possible rule changes in terms of
retransmission and potential harm that could come from rule changes to the
national cap, or to mergers that would result in national consolidation.
"Relaxing the cap will cause significant consumer harm-harm that would have to
be outweighed by corresponding consumer benefits," ACA's comments read.
To address this, ACA Connects suggested in its comments that the FCC obtain
retransmission consent data and have the Office of Economics and Analytics
conduct an econometric analysis to balance the harms and benefits of relaxing
the national cap. They also suggest it should be the broadcasters'
responsibility to provide the necessary data as the proponents of the rule
change. "We continue to believe that the Commission cannot rationally or
lawfully approve significant additional national consolidation without taking
such steps."
To read all of the comments filed in relation to the 2018 Quadrennial Review,
search the ECFS database using Docket Number 18-349.
----------------------------------------------------------------------
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