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The National Association of Broadcasters is testifying on behalf of over-the-air broadcasters who would like to see the Federal Communications Commission’s radio and television station ownership caps eliminated. In lengthy testimony regarding the 2022 Quadrennial Regulatory Review – Review of the Commission’s Broadcast Ownership Rules and Other Rules Adopted  Pursuant to Section 202 of the Telecommunications Act of 1996, NAB says that, unlike those arguing to keep or even strengthen ownership caps, those asking for their removal are providing real-world testimony. The NAB writes, “They documented in detail the vast competition local radio stations today face for audiences and vital advertising revenues from online and satellite content providers and digital ad platforms not subject to any comparable restrictions on their scale and scope; the dire negative effects that consumer and advertiser substitution of competing digital audio content and advertising for traditional radio has had on the listenership and advertising revenues garnered by local radio stations, including in mid-sized and small markets; and how the retention of asymmetric ownership restrictions has prevented radio broadcasters from gaining local scale to take advantage of important economic efficiencies, obtain investment capital, and better compete for audiences and advertising revenues, and thus enhance – or even maintain – their provision of news, emergency information, and valued entertainment and sports programming in local communities across the country at no cost to the public.”  Responding to testimony from musicFirst Coalition and the Future of Music Coalition – referred to as the Coalitions – NAB writes, “First, the fact that the Coalitions continue to hold themselves out as protectors of small, local independent broadcasters not just borders on the absurd but crosses over into full-blown absurdity. The Coalitions represent the interests of the music industry, which is dominated by three consolidated international record labels. Compared to even the largest radio station groups, the giant record labels are the 800-pound gorillas of the music world. Those three labels earn billions more in revenue than the approximately 11,000 full-power commercial AM/FM stations combined. As NAB earlier reported, the three major music companies jointly generated about $2.9 million per hour in 2023. In remarkable contrast, in 2023 and 2024 the vast majority of radio stations garnered less – and often much less – than $2.9 million per year in advertising revenues. Needless to say, the Coalitions have never explained how local radio stations earning such low levels of revenue (and even lower, if any, profits) are supposed to keep talented employees and provide high quality programming, including popular music, sports, and informational programming, such as weather updates and emergency information, OTA and free to the public without achieving increased local scale, greater economic efficiencies, and more robust ad revenues. See the NAB’s complete testimony here.