In its comments on the FCC's proposed ownership reform filed today, the  National Association of Broadcasters emphasized that the commission "has a clear duty … to reevaluate the broadcast ownership rules to ensure they still serve the public interest in a rapidly changing media marketplace."

In doing so, NAB argues, the FCC "must recognize the continuing proliferation of media

outlets accessible to American consumers and the profound impact such proliferation has had on the broadcast industry and the need for continued ownership regulation."

Technological advancements, the growth of multichannel video and audio outlets and the Internet, and an expansion in the number of broadcast outlets in the past several decades have altered the media marketplace in two fundamental ways, NAB said.

First, consumers nationally and in local markets of all sizes now have access to a vast array of information and entertainment from broadcast and nonbroadcast outlets. Second, NAB said, "due to this explosion of outlets, as the commission found even four years ago, traditional broadcasters are struggling to maintain their audience and advertising shares in a sea of competition" with exponentially increasing sources for information, opinion and entertainment, which have also created "new and growing competitors for the advertising support that is crucial to free over-the-air media."

NAB says the current rules do not serve the public and offered suggestions for change:

• "The commission should reform the television duopoly rule to reflect the current competitive television marketplace and allow more freely the formation of duopolies in markets of all sizes. Freely permitting local television duopolies is necessary to preserve and enhance television broadcasters' ability to serve their viewers and communities in markets of all sizes."
• "As NAB has previously shown, the case for repealing the anachronistic ban on joint ownership of newspapers and broadcast outlets is clear and compelling. The ban inhibits the development of new innovative media services, especially on-line and digital services, and precludes struggling broadcast and newspaper entities, particularly those in smaller markets, from joining together to improve, or at least maintain, existing local news operations."
• "The radio/television cross-ownership rule similarly does nothing to advance the public interest under current marketplace conditions. The rule is no longer needed to ensure diversity in local markets, but in its current form primarily serves to limit radio station ownership arbitrarily. With television and radio broadcasters facing unprecedented competition from cable, satellite television and radio, and audio and video Internet applications, a cross-ownership rule applicable only to local radio and television broadcast stations is inequitable and outdated."
• "In response to the commission's request for comment on proposals to foster ownership of broadcast outlets by minorities, women and small businesses, NAB reiterates its long-held belief that the commission should pursue constitutionally sustainable programs to further opportunities for such groups. NAB recognizes that improving access to capital is key to this effort and suggests ways to achieve this goal, including reform of attribution and auction rules."

To read the NAB's complete comments, click here.