Prometheus Radio Project, et al., v. FCC
1222ReplyComments.pdf | 122.2 KB
December 22, 2003
The fundamental substantive error shared by the FCC and the Deregulatory Petitioners is their reliance on the conceit that an “abundance” of media choices makes intra-service concentration rules (e.g., radio ownership, local TV ownership, etc.) and inter-service limits (e.g., newspaper-broadcast cross-ownership) are no longer relevant in this age of so-called media plenty. The agency and the industry look to the wrong data and ask the wrong questions. For purposes of media concentration, it is not dispositive that there are now more outlets (stations, networks, programmers, etc.); what matters most is that there are fewer owners.
Glenn B. Manishin, Stephanie A. Joyce, et al.