With a likelihood of deregulatory action growing, broadcasters, industry advocates, and the general public are getting in their final words on the FCC’s 2022 Quadrennial Review of local radio ownership rules, with plenty of differing visions for the future.
Broadcaster coalitions and the National Association of Broadcasters are aligned in arguing that decades-old ownership limits are actively impairing radio’s ability to compete for audiences, advertising, and capital in a digital-dominated marketplace. At the same time, some groups are urging restraint.
In joint reply comments filed by Connoisseur Media, Midwest Communications, Mid-West Family Broadcasting, Townsquare Media, Bonneville International, Legend Communications, and Frandsen Family Stations, broadcasters made their most comprehensive case yet for eliminating the Local Radio Ownership Rule altogether.
“The empirical data submitted by the Joint Commenters… demonstrates that today’s media landscape is entirely different than that which existed when the Local Radio Ownership Rule was adopted,” they write. “In today’s media marketplace, radio broadcasters face fierce competition from digital audio platforms for both audience and advertising revenues.”
The broadcasters anchor their argument in Section 202(h) of the Telecommunications Act of 1996, contending that the FCC is required to take a deregulatory posture once competitive conditions materially change. “Section 202(h) mandates that the Commission take a deregulatory perspective in determining whether the Local Radio Ownership Rule remains necessary as a result of competition,” the filing states, adding that the statute “does not allow the Commission to strengthen its ownership rules.”
That interpretation mirrors the position advanced by the NAB, which has repeatedly argued that asymmetric regulation is choking investment. In its own filings, NAB warns that broadcasters are trapped in what it calls a “vicious cycle,” where ownership limits suppress investment, reduced investment limits innovation, and weaker innovation accelerates audience and revenue loss.
“[A]symmetric ownership rules… reduce investment in stations that then struggle to fund any innovation or invest in more attractive programming to gain audiences (and thus advertising revenues), which in turn further reduces the attractiveness of station groups to investors,” NAB writes.
Both NAB and the joint commenters insist that competition must be evaluated across the full audio and advertising ecosystem, not confined to over-the-air radio. Audience data, they argue, shows clear substitution. Citing Edison Research, the broadcasters note that “since 2012, radio has lost more than half of its listening,” while digital audio consumption has doubled.
Advertising data reinforces the point. Referencing Borrell Associates, the filing notes that local digital advertising revenue has grown from $24.7 billion in 2013 to a projected $107 billion in 2025, while radio has declined from $11.4 billion to $6.5 billion.
Against that backdrop, the joint commenters push back forcefully against filings from musicFIRST Coalition, Future of Music Coalition, and the National Association of Black Owned Broadcasters, arguing that those groups advance internally inconsistent and economically unsupported claims.
musicFIRST and FMC, they note, argue that consolidation has made radio playlists “too predictable,” driving listener dissatisfaction, while simultaneously insisting that preserving current ownership caps is necessary to maintain “vibrant competitive local radio.” The broadcasters argue those claims cannot be reconciled. If consolidation under existing rules has already produced stagnation, they ask, how does maintaining those same rules restore vitality?
The broadcasters also accuse musicFIRST of pursuing a policy agenda that actively penalizes radio. While opposing ownership reform in the name of competition and diversity, musicFIRST continues to press for a new terrestrial performance royalty. Broadcasters argue that combination of new mandatory costs paired with structural limits on scale amounts to a deliberate effort to weaken radio’s economic position rather than strengthen it.
The minority ownership debate is similarly contested. NABOB argues that the Local Radio Ownership Rule is the FCC’s “only direct tool available” to slow the decline of Black-owned stations. The broadcasters reject that premise, arguing that ownership limits do nothing to address the root cause: lack of capital flowing into broadcasting.
According to the joint commenters, station inventory is plentiful and valuations are historically low, conditions that would normally support new entry. Yet minority ownership has not increased. They argue that the deterrent is not consolidation, but regulatory asymmetry that suppresses mergers, limits exit opportunities, and discourages investment across the entire sector.
NAB echoes that view, arguing that broadcasters cannot access capital in a market where “already scarce capital… flows to less regulated industries,” while digital platforms face no comparable ownership or service obligations. In that environment, NAB argues, repealing ownership limits is a prerequisite to attracting the investment needed to sustain local journalism, emergency coverage, and community service.
The National Religious Broadcasters offers a different assessment. Representing more than 1,100 Christian broadcasters, NRB urges the Commission to resist broad deregulation in favor of a hybrid approach. NRB supports eliminating ownership caps for AM radio, citing “well-documented technical, economic, and competitive challenges,” but urges the FCC to retain existing FM limits. Relaxing those caps, NRB warns, would “risk accelerating consolidation in precisely the segment of radio where localism and viewpoint diversity remain most vibrant, and most vulnerable.”
Salem Media Group occupies a middle ground. In its reply comments, Salem calls for complete elimination of AM ownership caps, while proposing a limited increase in FM ownership to eight stations per licensee in Nielsen markets 1–75. Salem frames the proposal as a way to preserve AM viability while giving mid-sized and mission-driven broadcasters enough scale to compete against unregulated digital platforms.
As the FCC weighs these filings, nearly all broadcast parties agree that radio’s greatest competitive threat no longer comes from within broadcasting, but from a digital ecosystem that continues to expand without comparable limits, costs, or public-interest obligations.
The writing is on the wall. Without deregulation there will be no broadcast radio to speak of in the next two decades. The decline and demise is a certainly. Dumping the ownership caps is the only chance we have to stave off the inevitable. Anyone who endorses keeping any kind of cap in place doesn’t understand the obvious economic dynamic.
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