On Wednesday, December 13, Future of Music Coalition released a quantitative, 152-page report of the history of radio consolidation called False Premises, False Promises. In honor of the occasion, the National Association of Broadcasters (NAB) attempted to discredit the release of an independent analysis—that is, one not written by the industry or its consultants—of the radio industry by distributing a pre-emptive press release that called our research “questionable” and filled with “dubious data”.

Future of Music Coalition, on the other hand, believes that a better understanding of what radio industry data tell us will come through public discussion, with both industry and public-interest voices heard.

The NAB composed their press release in the future tense, telling the public what Future of Music Coalition “will claim” minutes after we published our report. In contrast, we have actually read and studied the points NAB offered in its pre-emptive rebuttal.Note that the NAB has not disputed our comprehensive account of the consolidation of radio ownership (Chapter 1 of our study) and the intense concentration in local radio markets (Chapter 2). But we would like to respond to their criticisms of our analysis of radio programming (Chapter 3), complete with citations to our new study, now available at http://www.futureofmusic.org/article/research/false-premises-false-promises

First, it is commendable that the NAB celebrates increases in Spanish- and Asian-language programming.Of course, they did not offer arguments on behalf of what the Adult Contemporary, Smooth Jazz, and commercial Country formats are doing for programming diversity.Nor did the NAB mention that Classic Rock, Adult Standards, and Oldies grew more between 1996 and 2005 than any ethnically focused or urban-focused format.(See FMC Report, Table 3-1, p. 89.)This provides important context for their claims about enhanced diversity.

The NAB cites research in its press release that urges people to “‘dig deeper’” into the data.(Scare quotes in original—can’t say why.)So, when they trumpet the increases in ethnically focused programming, we will follow their lead and ask: okay, what kinds of station groups are offering those Spanish and Asian formats, small or large?The answer appears in Table 3-4 on p. 97 of our report:

• As a percentage of airtime, small station groups offer three to four times as much Spanish-language programming than large station groups that are over or exactly at the local ownership cap.

• 89 percent of Spanish-format programming is offered by small station groups (i.e. those strictly below the cap).

• 75 percent of programming in the Asian, Korean, or Japanese formats is offered by small station groups.

If radio programming is offering more diverse programming, large station groups are not offering it—rather, the small station groups are doing so.So the NAB’s policy argument has it exactly backwards.Why raise the caps to let companies get bigger if the smaller station groups are the only ones offering programming to be proud of?To encourage more ethnically focused programming for local communities, the FCC should foster small and noncommercial station groups.

The NAB itself admits that one of the top-ten markets in the U.S. by percentage of Asian-American population doesn’t even have one station focused on Asian-language programming or Asian-community public affairs.That in and of itself is an indictment of consolidated, commercial radio’s ability to serve the public.Looks like the Asian-Americans in Stockton, CA—who make up 12.7 percent of the population there—are just out of luck.None of the 82 stations broadcasting in Stockton—the 12 stations based in Stockton and the 70 other stations that reach Stockton from other markets—can be bothered to offer an Asian format.

Second, the misinterpreted data in the NAB’s first three bullet points are based on their well-worn practice of simply counting up format names.Their analysis ignores an essential three-point argument for understanding how to measure the variety of radio programming formats accurately:

• The NAB’s faulty methodology treats the Rock/Classical/Jazz format as though it is a totally and completely different format from Rock/Jazz/Classical.Our methodology, on the other hand, breaks such formats into their component parts. (See pp. 85-86 of FMC report).

• Our analysis reveals the variety of format names on commercial radio was barely greater in 2005, with 96 different names, than in 1996, when there were 92 different format names.The growth in format names actually trails the growth in the number of licensed commercial stations—a tiny 4 percent increase in format names from 1996 to 2005.Compare that to the 9 percent increase (over the same time period) in the number of commercial AM and FM stations on which these formats are offered. (See FMC report Appendix F, pp. 148-150, for the format data and Figure 1-2 for the growth in licensed stations.)

• Moreover, as we have emphasized since our 2002 study, formats with different names often play very similar songs. Formats with different names, like Rock and Active Rock, can overlap by as much as 80 percent in terms of the songs played on them.(See FMC Report Table 3-5, p. 101.)So it is not informative to simply count the number of format names offered to the public and call that variety.

As for the NAB’s final bullet point about urban radio, we would like to discuss what is really going on with those “urban-focused” formats.These formats may have a variety of names.But we would emphasize, citing Figure 3-7 on p. 100 and Table 3-5 on p. 101, that:

• The Urban and CHR/Rhythmic formats overlap by 62 percent in terms of their top-30 most popular songs.

• The Urban and CHR Pop formats overlap by 30 percent.

• The Urban and Urban AC formats overlap by 27 percent.

Diversity doesn’t just mean offering “urban” programming to urban areas.It means offering a wide range of songs from diverse sources.Culling playlists for Urban stations from national pools of songs—as demonstrated in Table 3-7 on p. 105 of our report—has not translated into localism or diversity.

In closing, the NAB’s Vice President of Media Relations, Dennis Wharton, had this to say about Future of Music Coalition:

“FMC’s long history of producing questionable research and dubious data to fulfill its agenda-driven mission is apparent for all to see. As the BIA Financial Network study indicates, free local radio has more format diversity than at any time in its rich history. Moreover, with the advent of HD Radio, local radio will be providing more news, more music formats, and more public service for the 260 million people who tune in every week.”

In response, we would note the following, again citing our new study:

• If our data are “dubious,” that’s because we use data collected by, designed for, and purchased from the industry itself. Should the NAB, its members, or its consultants wish to begin making their expensive databases available to the public, to put industry researchers and public-interest researchers on the same footing, we would applaud such a development.(See our policy recommendations for improving public access to data on pp. 115-116.)

• We have explained above that the increase in “format diversity” has been trumped up by naive and uncritical analysis.The analysis cited by the NAB sidesteps the issue of the extensive overlap among programming formats with different names.(See pp. 82-86.)

• We welcome the improvements that may come with HD radio.But we predict that the real innovators with HD radio will be small station groups and noncommercial broadcasters.We say this based on our research of the past decade of programming, in which almost all the localism and diversity comes from smaller entities.(See pp. 93-98.)

Finally, we would note that the NAB has a “long history” of its own—a long history of refusing to debate neutral, independent researchers about radio consolidation in public.If the NAB or its representatives have questions about our research or would dispute our conclusions, we would be glad to debate them publicly, as we always have been.But we can say today that, based on our careful and thorough analysis of industry data, we have many reasons for concern about the effects of radio consolidation.Our new study, False Premises, False Promises documents them in detail.

Read FMC’s Full Report