On Friday, November 15, the National Association of Broadcasters (NAB)
released a response to our study, which had not yet been released. The
NAB’s so-called fact sheet contains a skewed version of the state
of the radio industry. Here we present our rebuttal to the NAB’s
claims.
Findings by other researchers
The NAB fact sheet directs journalists to a series of reports with a
perspective differing from ours. We encourage reporters to read these
studies – while noticing the questions that are absent from the analysis
contained in them. These studies never engage the public policy issues
that have emerged from radio deregulation.
Furthermore, we would encourage reporters to read the studies of the
radio industry by organizations and writers that the NAB failed to cite.
In particular, we would recommend the FCC’s recently-released study
“Radio Industry Review 2002: Trends in Ownership, Format, and Finance.”
You’ll find that our statistical findings about the extreme consolidation
now present in the radio industry are consistent with the FCC’s.
Unlike the FCC reports, however, our report does not stop short of making
policy conclusions. In our report we connect the dots between all the
facts we discovered about radio after deregulation.
To make their case, the NAB cites reports by an industry consulting firm,
an industry survey firm, and an investment bank. In the wake of Enron
and Worldcom, we know we need not caution journalists to read critically
when reading the reports of investment bankers.
Listenership HAS decreased: even according to an industry-owned business
The NAB claims that consumers are not dissatisfied with radio and that
listenership is still high. It’s difficult for us to determine exactly
which industry-conducted studies the NAB is citing to support this claim
in their fact sheet, even after a thorough search of both Arbitron and
Edison’s list of collaborative reports.
But we have determined that a study by Arbitron/Edison contains some
of the findings to which the NAB refers. However, as in other surveys
conducted by Arbitron/Edison, this study did not use a “random sample.”
Instead, it used a random sample of Arbitron diary keepers. But selections
from a truly random sample must be uncorrelated with anything else to
meet that definition. In the case of this study, survey respondents were
selected based on whether they fill out Arbitron ratings surveys. This
means that some demographic groups may have been underrepresented in the
survey samples.
We would also note that it’s not surprising that an industry-conducted
survey found results favorable to the industry. After all, Dr. Ed Cohen,
Arbitron’s Director of Domestic Radio Research, was most recently
employed as Vice President of Research for Clear Channel Communications.
What is surprising is that an industry-conducted survey – a different
one, cited in the FMC report – found results very unfavorable to
the industry. In September 2002, Duncan’s American Radio reported
listenership has hit a 27-year low. (Incidentally, Duncan’s is owned
by Clear Channel, by far the largest owner of radio stations in the U.S.
This makes it hard to claim its findings are biased against the industry.)
According to the Duncan’s study, radio listenership has fallen steadily,
dropping nearly 17 percent over the last 13 years.
Format variety is stagnant
The NAB cites our study’s finding that format variety increased
from 1996 to 2000. We do indeed report this result as a preface for our
next conclusion; that format variety is not a substitute for true measures
of format diversity. Our study puts this first finding into a broader
context. We point out that format variety has been stagnant over the last
two years. The other studies of format variety cited by the NAB overlook
or obscure the issue. The NAB never acknowledges or responds to this important
finding.
Format variety vs. programming diversity
Format variety is a surface measure. It measures the variety of labels
on programming – not the diversity of the actual programming content.
All the studies cited by the NAB equate variety of formats with diversity
of programming. This approach overlooks the major issue of format homogeneity
– the overlap between formats. These NAB-cited reports do not recognize
that slicing and dicing the same songs over and over again does not increase
diversity.
In our study, we focus on the incredibly high level of format homogeneity.
Some formats – like Urban and CHR/Rhythmic – overlap by as much
as 76 percent according to chart data from Radio and Records. We also
note that format homogeneity has either remained high or stayed the same,
depending on the formats in question. This finding is consistent with
another FCC report, cited by the NAB itself, “Radio Market Structure
and Music Diversity.”
The fact that format homogeneity is high and holding at a high level
is significant. It exposes the superficiality of using format variety
as a measure of programming diversity. What matters for listeners and
musicians is the diversity of songs played on the air.
Radio is an oligopoly
The NAB’s claim that radio is less consolidated than other industries
is a diversionary tactic. The term “oligopoly” refers to the
degree of concentration in a single industry. And according to that definition
radio is an oligopoly. Comparing radio to other, extremely concentrated
media industries is not an effective way to deflect scrutiny.
The NAB claims that the top 10 owners control only 49 percent of industry
revenue. We find that the top 10 firms control 67 percent of industry
revenue, based on data from BIA Financial Networks. Calculating market
share involves the simple mathematical operations of addition and division.
Anyone with the BIA database could reproduce our results. The burden lies
on the NAB to explain where their number comes from.
Furthermore, the NAB sites the 4,000 separate companies that own radio
stations without mentioning the fact that only 10 control 67 percent of
revenue. The number of owners does not counteract the dangerous implications
of this level of market concentration, nor does it address the local origins
of the medium. Section 307(b) of the Communications Act specifies that
radio stations are licensed to particular communities and are charged
with servicing those communities. In other words, principles of localism
are deeply embedded in the Communications Act. Therefore, any notion that
you can improve local service by regionalizing and nationalizing is in
many ways fundamentally at odds with one of the basic goals of the communications
licensing process.
Radio consolidation is MORE worrisome because other media are more
consolidated
The NAB lamely attempts to assuage any worries about radio consolidation
because other media are even more consolidated. What the broader media
context really tells us is that horizontal consolidation across
media has become a pressing problem. Three examples of the Top 10 radio
companies – Clear Channel, Viacom, and Disney/ABC Radio – have
major holdings in other media and other industries as well. These holdings
include network television, cable television, motion picture studios,
music recordings, billboard advertising, etc. Horizontal consolidation
reduces diversity even further.
Furthermore, many of these other industries do not rely on public spectrum
to operate. Haphazardly comparing radio to these other, very different
industries blurs the important issue of radio’s democratic ownership.
The spectrum belongs to the public, making the consolidated control of
spectrum a uniquely public concern.
Not all minorities are well-served by radio
The NAB mentions that more Spanish-language stations exist than existed
in 1996. True as that may be, this does not prove that highly consolidated
industries serve all customers well. Radio might serve some minority ethnic
groups in some ways. But many groups that are in the minority are
not being served: those who prefer classical music, those who prefer jazz,
those who prefer world music, those who prefer a multiplicity of news
sources, and so on.
Our analysis asks the right questions
We asked two objective questions: (1) how has radio consolidation affected
consumers? (2) How has radio consolidation affected musicians? If the
radio broadcasters don't wish these questions to be asked and don't wish
these questions to be answered by anyone besides them, one can understand
that – given the overwhelming evidence against their claims. We urge
reporters and citizens to inform themselves fully, and not be distracted
by industry propaganda.
We used the industry’s own numbers to conduct our research. We played
ball on their home field. That the industry’s own data sources implicate
radio as an increasingly consolidated and less diverse medium lends even
more credence to our claims.
The NAB has claimed that we did “shoddy” analysis and have
an “activist” agenda that biased our research. Our study contains
extensive in-text and footnotes explanations of its methodology. The report
is written so that anyone can re-create and check its results. We stand
behind our work.
Public Enemy Frontman, Production Team and Insiders Discuss Landmark Album On July 17, FMC and Pitchfork Music Festival will host a free discussion about Public Enemy's It Takes a Nation of Millions to Hold Us Back at Chicago's Cultural Center, featuring Chuck D, members of PE's production team and music media experts.
July 8, 2008 Press release | Event Page
FMC Files Brief to Protect Creative Expression
FMC and the Center for Creative Voices in Media filed a brief at the Second Circuit Court of Appeals, arguing that the FCC's indecency policy has a chilling effect on creativity and expression and deprives the public of access to protected speech.
July 2, 2008 Press release | Indecency amicus brief (PDF)
Wilco, Bright Eyes, Aimee Mann & more "Rock the Net" on Compilation CD
Thirsty Ear Recordings to release album on July 29 to benefit FMC's "Rock the Net" campaign for net neutrality.
June 2, 2008 Press release | Rock the Net
Musicians Get the Hint About Health Insurance
Two Raleigh concerts in memory of musician Drew Glackin; proceeds go to Glackin’s family and Future of Music Coalition’s Health Insurance Navigation Tool
April 10, 2008 Press release FMC's HINT program
New York State Music Education Events Examine Crucial Issues Facing Artists Forums in Rochester (April 28), Syracuse (April 29) and Albany (April 30) to focus on music, media, technology and policy issues for songwriters, composers and performers from all genres.
March 25, 2008 Event details | RSVP
Pop Rockers OK Go "Tour" Congress in Support of Net Neutrality
Damian Kulash and Andy Ross discuss the importance of open Internet structures to musicians; Kulash testifies before House Judiciary Committee.
March 13, 2008 Press release
Spoken testimony
Written testimony
Rock the Net
New York State Music Education Events Examine Crucial Issues Facing Artists Kick-off forum in Buffalo on April 2 to focus on music, media, technology and policy issues for songwriters, composers and performers from all genres. March 7, 2008 | Event details
Philly Bands Rocking for Net Neutrality February 23 Sugar Town show at Tritone in Philadelphia will showcase lady rockers and DJs, as well as musicians' support for net neutrality. February 15, 2008
OK Go and Bonerama Rocked DC for New Orleans Musicians Bands also champion FMC's "Rock the Net" campaign for net neutrality February 2 benefit show at DC's 9:30 Club raised over $8,000 for New Orleans musicians. Bands played cuts off their new benefit EP, You're Not Alone, available on iTunes on February 5. February 4, 2008
Upcoming Washington, DC show and benefit EP from OK Go & Bonerama
On February 2, OK Go and Bonerama will play a benefit at D.C.'s 9:30 Club in support of You're Not Alone - an EP to support Sweet Home New Orleans and Al "Carnival Time" Johnson. January 21, 2008
Successful New Orleans Concerts Aid Big Easy Musicians
Last week, two benefit concerts raised over $6,000 for Sweet Home New Orleans - a coalition of non-profit organizations that helps find affordable housing and provides rental assistance for the city's musicians - and Big Easy music legend Al "Carnival Time" Johnson.
January 15, 2008 Press release | Event details
Ann Chaitovitz Appointed
FMC's New Executive Director A proven leader in musician and public policy issues, Chaitovitz replaces founding Executive Director Jenny Toomey January 3, 2008
Concerts for New Orleans Musicians Bring Artists Together Two New Orleans shows and upcoming benefit CD from OK Go and Bonerama January 2, 2008
FMC's Jenny Toomey Appointed Program Officer for Ford Foundation
Kristin Thomson to Serve as FMC’s Interim Executive Director Michael Bracy to Chair FMC Board of Directors November 26, 2007
Seattle "Rocked the Net" Rep. Jay Inslee advocated network neutrality;
joined by rocker Matt Nathanson, Reclaim the Media, FMC and local music business representatives October 31, 2007
Rock the Net: Campaign for Net Neutrality Rocks Seattle
Teleconference with Rep Jay Inslee on Tuesday, Oct 30. Matt Nathanson performs at Seattle’s Crocodile Café on Tuesday, Oct. 30 October 26, 2007
Future of Music Policy Summit to Tackle Critical Issues at the Intersection of Music, Law, Technology and Policy Sen. Byron Dorgan and Sen. Ron Wyden to Deliver Keynote Addresses
Mac McCaughan, Bob Mould, Marybeth Peters of the U.S. Copyright Office and More Than 90 Other Panelists Confirmed. September 10, 2007 Summit home page Press Credentialing
AT&T's muting of bands points toward a pattern of silencing political speech Content monitor did not edit out 20 instances of curse words during Pearl Jam webcast, despite AT&T claim it hires monitors to block "excessive profanity". August 13, 2007
Top musicians, lawyers, technologists confirmed for FMC's 7th annual Policy Summit August 13, 2007 Press Release Summit home page Press Credentialing
FMC Statement on AT&T Silencing Pearl Jam's lyrics during Lollapalooza webcast August 9, 2007
FMC Statement on Federal Trade Commission Report on Net Neutrality June 29, 2007
FMC files testimony with House Small Business Committee on CRB Webcasting Rates June 27, 2007 Press Release | Testimony
Clear Channel strips local, independent artists of digital performance royalties
FMC has discovered that Clear Channel's online application for local and independent artists to submit their music for airplay on each of its stations requires the artist to approve a licensing agreement that does away with their digital performance right. June 22, 2007
Low Power Radio Gets New Push in Congress
Congress introduces bills to create hundreds of new low power FM radio stations to cities and suburbs across the country. June 22, 2007
FMC Announces Dates for 7th annual Policy Summit
September 17-18, 2007
GWU Betts Theatre, Washington, DC June 11, 2007
FMC Organizes "Musicians Bringing Musicians Home II"
A Benefit Concert on May 27 at New Orleans' Tipitina's for Sweet Home New Orleans featuring: Indigo Girls, Damian Kulash of OK Go, Jim James of My Morning Jacket, Matt Nathanson, Pamela Z...and special guests
May 23, 2007 Press Release | Details
Congressman Mike Doyle to address conference on music, law and technology
May 2 event will bring together leading experts from worlds of music, law, technology and policy. April 25, 2007
A2IM Endorses Rock the Net Campaign
American Association of Independent Music urges its label members to join the campaign for network neutrality. April 17, 2007
Music Mashes with Policy at upcoming Technology and IP Policy Day
May 2 event will bring together leading experts from worlds of music, law, technology and policy. April 16, 2007
FMC Applauds FCC's Payola Settlement
Payola agreement by FCC and big broadcast chains represents a major - but tentative - step toward once again opening the nation's airwaves to local music and voices. April 13, 2007
Rep. Edward Markey, Ted Leo kick off "Rock the Net"
Nearly 150 artists and labels have already signed onto campaign for net neutrality
March 27, 2007 Press Release | Rock the Net
Major Artists To Join Launch of Rock the Net Campaign for Net Neutrality March 23, 2007
FMC Statement on FCC's "Rules of Engagement" On Payola March 5, 2007
FMC Files Reply Comments in FCC Media Ownership Proceeding January 16, 2007
FMC Statement on FCC Payola Settlement
FMC's statement on FCC's reported consent decree with the broadcast industry in regards to payola. January 16, 2007
Radio Station Ownership Consolidation Shown to Harm Musicians and the Public
FMC study shows that the rapid consolidation of the commercial radio industry that followed the Telecommunications Act of 1996 has led to a loss of localism, less competition, fewer viewpoints and less diversity in radio programming in media markets across the country.
December 13, 2006 Press release Report details
FMC Organizes Musicians Bringing Musicians Home Benefit concert at New Orleans' Tipitina's on November 6th featuring Steve Earle, Mike Mills, Allison Moorer, Tom Morello, Boots Riley, Corin Tucker and special guests.
October 23, 2006 Read press release Read press coverage
Job
Losses Associated with Radio Consolidation Undermine Localism and Diversity FMC, Newspaper Guild and Consumers Union urge FCC to take employment effects
of their policies into account during upcoming review of media ownership rules August 9, 2006
FMC Releases Research on Employment and Wage Effects of Radio Consolidaton August 9, 2006
FMC on Preserving the Dynamism of the Internet Opinion Piece on ABC News June 29, 2006
FMC Statement on Senate Commerce Committee Vote in Support of LPFM June 28, 2006
FMC Statement on FCC Media Ownership Proceeding June 21, 2006
Indie-rock revolution, fueled by net neutrality Op-ed by FMC's Jenny Toomey and Michael Bracy June 13, 2006
Pearl Jam Donation To Help Musicians Help Themselves Proceeds From Washington, DC Appearance to be Donated to FMC Artist Research
Council May 25, 2006 Press Release
FMC signs on letter to preserve net neutrality May 17, 2006
FMC Announces Dates for Sixth Annual Future of Music Policy Summit
October 5-7, 2006 Media Advisory May 15, 2006
FMC Statement on Release of Feingold's Radio and Concert Disclosure
and Competition Act of 2005 November 18, 2005
FMC Sends Letter to Senate Commerce Committee in Support of a
Public Performance Right for Sound Recordings October 19, 2005
Top Names in Music, Law, Technology and Policy Return to Debate Critical
Issues at Fifth Annual Future of Music Policy Summit
September 6, 2005 Media Advisory | Policy
Summit home page
FMC Announces Health Insurance Navigation Tool
August 9, 2005 HINT Home Page
FMC Press Release: Music Mashes with Policy at DC Policy Day April 8, 2005
FMC's Michael Bracy Testifies in front
of House Judiciary Committee on "Digital Music Interoperability" April 6, 2005
FMC files comments at US Copyright Office on "Orphan
Works"
Comments also ask Copyright
Office to consider status of out-of-print recordings March 25, 2005
FMC Sends Letter to Senate Stating Concerns about S 193, Broadcast Decency Enforcement
Act March
10, 2005
FMC and artist groups file joint reply comments at FCC on localism in broadcasting,
MB Docket 04-233
January
3, 2005 PDF of document
