It only affects two markets, New York and Washington DC, however it’s important enough to Connoisseur Media CEO Jeff Warshaw that he’s been providing the FCC with data, meeting with FCC staff, and has now written a letter asking the Commission to change its rules regarding embedded markets. The embedded market rule lumps stations in a market like Long Island in with New York City. So Warshaw would have to comply with the FCC’s ownership limits in both markets and that might prevent him from purchasing stations in other embedded markets in New York. Warshaw says it’s a dumb rule, nobody is objecting to having it changed, and he’d like this FCC to fix it.
Again, there are only two markets the rule impacts. Both New York and Washington have multiple embedded markets that operate close to the “parent city.” Owners in one embedded market could be prohibited from owning stations in another embedded market. Warshaw says this makes no sense because they don’t even compete with each other. The rule does affect Connoisseur in New York, where the company owns stations on Long Island, which is an embedded market to New York City.
Warshaw says there should be, at least, a presumptive waiver of the current policies that require that the acquisition of a radio station located in an “embedded market” be analyzed not only for multiple ownership compliance with the ownership limits in the embedded market to which the station is “home,” but also for compliance in the greater parent market in which the station’s home market is embedded. The time is now for the FCC to act on that proposal.
Warshaw is concerned the FCC will not act on his request so he’s trying to ratchet up the heat again and get this issue on their radar. “Given the clear and convincing nature of the information provided by Connoisseur, and the fact that this proposal is unopposed, Connoisseur cannot understand why the Commission would further defer its consideration, and the benefits it brings to the competitive situation of stations in embedded markets, for some later proceeding.”
In its letter to the FCC, Connoisseur says it has amply demonstrated that the current policy regarding embedded market stations does not make any sense. “This dual multiple ownership analysis was meant to prevent owners of central city stations from acquiring additional stations in the embedded markets — where the central city stations do compete for revenue and ratings. But, the rule has the perverse effect of preventing an owner of stations located solely in embedded markets from competing for regional and national advertising dollars by acquiring stations in multiple embedded markets as, once an owner has acquired the maximum number of stations allowed in one embedded market, they likely cannot acquire stations in another embedded market because they will be over the ownership limits in the parent market in which these embedded markets are considered to be a part, even though these stations are not competitive factors in that overall parent market.”
Given the geography of Greater New York, it is possible under this proposal that an owner in the Long Island market who acquires stations in the Monmouth-Ocean market might find some synergy, even to the elimination of the main studio in one market or the other if the FCC goes ahead with eliminating the main studio rule.
Stations with transmitters near the south shore of Long Island can easily be heard along the New Jersey coast and vice versa. Whether they could be viewed as competing would be a matter of which market(s) is(are) the intended target of a given station.
I’m not aware of a situation where any stations along either coast direct any programming to the other but it could happen.
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