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WASHINGTON -- On Monday, Free Press filed comments with the Federal Communications Commission about a Minority Media Telecommunications Council study purporting to examine the impact of cross-ownership on women- and minority-owned broadcast stations. Free Press found the study’s methodology to be severely flawed and raised questions about the study’s conclusions.

Former FCC Chairman Julius Genachowski backed the proposal for the study before leaving the agency in May. Numerous public interest and civil rights groups opposed the agency’s effort under Genachowski to loosen its media ownership rules without first studying the impact on female and minority owners. However, the MMTC study does not satisfy those calls, nor the order from the U.S. Court of Appeals for the 3rd Circuit that the FCC first collect and analyze the proper data before making any changes to media ownership rules.

Free Press Research Director S. Derek Turner made the following statement:

“The glaring problems with this study render it utterly useless as the FCC evaluates its media ownership rules. The record in this proceeding already shows that cross-ownership, along with other forms of media consolidation, negatively impacts minority and women owners and raises barriers to entry. And MMTC has provided no evidence to contradict, let alone refute, those conclusions.

“The FCC simply cannot consider the MMTC study as a sound basis for informed policymaking. The study comes nowhere close to satisfying the 3rd Circuit's mandate that the FCC collect the data necessary to fully consider the effects of its rules on ownership diversity. 

"Given the fact that the coming incentive auction will drastically shift the local broadcasting landscape, the FCC should refrain from making any changes to its rules that would further harm ownership diversity. The FCC should conduct analysis that meets the Court's standards, and should not use this deeply flawed MMTC study to justify implementing former Chairman Genachowski's problematic media consolidation plans."

The study’s flaws, detailed in Free Press' filing, include the following:

  • The study fails to adequately describe its sample. Such a description is required of any research that seeks to draw broad and generalizable conclusions. This is a critical omission, particularly for a study with such a small sample size.
     
  • The study fails to examine the perceived impact of cross-ownership on broadcast radio station owners separately from the impact on broadcast television station owners. The study also fails to distinguish between the impact on female owners and the impact on minority owners.
     
  • Though the study’s survey instrument focuses on the radio market, the study nonetheless draws conclusions about the impact of cross-ownership on television station owners.
     
  • The study’s reliance on online survey responses is not appropriate for a study that claims to employ an "unaided recall methodology."
     
  • The study identifies owners who perceive cross-ownership as negatively impacting their businesses, but concludes that cross-ownership has "no material impact."
     
  • MMTC claims the study was peer-reviewed, yet it failed to submit any written reviews or provide any indication of the reviewers’ opinions of the study. 


To read the filing, go to: http://www.freepress.net/sites/default/files/resources/Free_Press_MMTC_Study_Comments.pdf.

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