Media Ownership: Economic Factors Influence the Number of Media Outlets in Local Markets, While Ownership by Minorities and Women Appears Limited and Is Difficult to Assess
Published: 2008-03-12T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The media industry plays an important role in educating and entertaining the public. While the media industry provides the public with many national choices, media outlets located in a local market are more likely to provide local programs that meet the needs of residents in the market compared to national outlets. This report reviews (1) the number and ownership of various media outlets; (2) the level of minority- and women-owned broadcast outlets; (3) the influence of economic, legal and regulatory, and technological factors on the number and ownership of media outlets; and (4) stakeholders' opinions on modifying certain media ownership laws and regulations. GAO conducted case studies of 16 randomly sampled markets, stratified by population. GAO also interviewed officials from the Federal Communications Commission (FCC), the Department of Commerce, trade associations, and the industry. Finally, GAO reviewed FCC's forms, processes, and reports.
section_title: What GAO Found
paragraphs: The numbers of media outlets and owners of media outlets generally increase with the size of the market; markets with large populations have more television and radio stations and newspapers than less populated markets. Additionally, diverse markets have more outlets operating in languages other than English, contributing to a greater number of outlets. Some companies participate in operating agreements wherein two or more media outlets might, for example, share content. As such, these agreements may suggest that the number of independently owned media outlets might not always be a good indicator of how many independently produced local news and other programs are available in a market. Finally, the Internet is expanding access to media content and competition. On a biennial basis, FCC collects data on the gender, race, and ethnicity of broadcast owners to, according to FCC, position itself and the Congress to assess the need for, and success of, programs to foster minority and women ownership. However, these data suffer from three weaknesses: (1) exemptions from filing for certain types of broadcast stations, (2) inadequate data quality procedures, and (3) problems with data storage and retrieval. These weaknesses limit the benefits of this data collection effort. While reliable government data are lacking, available evidence suggests that ownership of broadcast outlets by minorities and women is limited. Several barriers contribute to the limited levels of ownership by these groups, including a lack of easy access to sufficient capital. A variety of economic, legal and regulatory, and technological factors influence media ownership. Two economic factors--high fixed costs and the size of the market--appear to influence the number of media outlets in a market, the incentive to consolidate, and the prevalence of operating agreements. By limiting the number and types of media outlets that a company can own, various laws and regulations affect the ownership of media outlets. Technological factors, such as the emergence of the Internet, have facilitated entry for new companies, thereby increasing the amount of content and competition. Stakeholders expressed varied opinions on modifications to media ownership rules. Most business stakeholders expressing an opinion on various media ownership rules were more likely to report that the rules should be relaxed or repealed. In contrast, nonbusiness stakeholders who expressed an opinion on the rules were more likely to report that the rules should be left in place or strengthened. Both business and nonbusiness stakeholders who expressed an opinion on a previously repealed tax certificate program supported either reinstating or expanding the program to encourage the sale of broadcast outlets to minorities.

section_title: Letter
paragraphs: The media play an important role in educating and entertaining the public  and fostering an informed citizenry. Since the nation’s founding,  newspapers have gathered and disseminated the news of the day, thereby  helping citizens become informed voters. In the early 20th century, the  emergence of radio and television expanded the options for educating and  entertaining the public, and in the 21st century, the Internet delivers  information and entertainment from a virtually limitless supply of sources.  Whereas most citizens were formerly limited to a newspaper or  newspapers in their local area, citizens today with an Internet connection  can read publications from around the world.
Given the vital role of the media in American life, the ownership of media  outlets has been a long-standing concern of the Congress. The Federal  Communications Commission (FCC) regulates many aspects of the media  industry, including radio and television stations and cable and satellite  service. In the Telecommunications Act of 1996 (1996 Act), the Congress  required that FCC periodically review its broadcast ownership rules. In  2003, FCC released an order that altered its existing broadcast ownership  rules. This order generated significant public debate, and more than  500,000 comments were filed with FCC. The U.S. Court of Appeals for the  Third Circuit affirmed some of FCC’s rule changes while remanding others  for further justification or modification. In response to the court’s  decision and the congressional mandate for periodic review of its rules,  FCC opened another proceeding to assess its broadcast ownership rules.  This proceeding also attracted significant attention from both the public  and the Congress, with concerns arising about the level of consolidation in  the media industry. On February 4, 2008, FCC released a rule concluding  its latest review of the broadcast ownership rules.
While today’s media environment provides the public with numerous  programming choices from across the country, media outlets in local  markets remain a concern for policymakers. With cable and satellite  service, the public can receive programming from nationwide outlets, such  as CNN and FOX News, and television stations in adjacent markets.  However, media outlets located in a market are more likely to provide  local news, public affairs, and political programming addressing the needs  of residents in that market, such as coverage of local political campaigns,  compared to nationwide and adjacent-market outlets. Reflecting the  importance of local media outlets, localism is one of FCC’s three policy  goals for media ownership, along with competition and diversity.
You asked us to examine the current status of media ownership. On  December 14, 2007, we provided preliminary information on our review of  media ownership. This report discusses (1) the number and ownership of  various media outlets; (2) the level of minority- and women-owned  broadcast outlets; (3) the influence of economic, legal and regulatory, and  technological factors on the number and ownership of media outlets; and  (4) stakeholders’ opinions on modifying certain media ownership laws and  regulations.
To respond to the objectives of this report, we interviewed officials from  FCC, the National Telecommunications and Information Administration  (NTIA) of the Department of Commerce, and trade associations.  Additionally, we interviewed 102 industry officials and experts, selected  based on industry sector (radio and television stations, broadcast  networks, newspapers, cable, satellite, and Internet), geographic service  territory, size of the media outlet, and professional publications (for  experts). See appendix III for a complete list of individuals and  organizations that we interviewed. To assess the number and ownership of  media outlets, we conducted case studies in 16 Nielsen Designated Market  Areas (DMA). To select the 16 case study markets, we used a stratified  random sample methodology: we (1) randomly selected 4 case study  markets from each of 3 market strata (large, medium, and small), (2)  selected the 3 largest markets as a separate stratum, and (3) judgmentally  selected 1 market from the medium-size category to test our data  collection and structured interview methodology. The 16 markets that we  analyzed include approximately 20 percent of all television households in  the United States. In each case study market, we identified the number of  television and radio stations, newspapers (daily and weekly), and cable  and satellite television operators present in the central city of the DMA.  We also identified the number of owners of these outlets. We did not  identify low-power stations or local Web pages. See appendix I for a more  detailed discussion of our overall scope and methodology.
We conducted this performance audit from February 2007 through March  2008 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: FCC regulates many aspects of television and radio station ownership.  Laws and regulations limit the ownership of television stations, both  nationwide and locally, and limit the ownership of radio stations locally.  Since the 1970s, the number of media outlets has increased dramatically,  with large increases in the number of television and radio stations;  additionally, the number of broadcast networks has increased. More  recently however, some segments of the media industry have undergone  consolidation, with a few companies acquiring a significant number of  outlets.
subsections: section_title: Laws and Regulations
paragraphs: Through provisions in the Communications Act of 1934, as amended, FCC  regulates various aspects of television, radio, cable, and satellite service.  FCC has three policy goals for media ownership: competition, diversity,  and localism; in the case of diversity, FCC identified viewpoint, outlet,  program, source, and minority and female diversity. On December 18,  2007, FCC took action on a number of items impacting media ownership.  FCC revised its ban on the ownership of a newspaper and broadcast  station in the same market. FCC set a cap on the number of subscribers  that a cable operator can serve nationwide and sought comments on  vertical ownership limits and cable and broadcast attribution rules. FCC  also adopted rules to help new entrants and small businesses, including  minority- and women-owned businesses with access to financing, such as  modifying the commission’s construction permit deadlines, and adopted a  notice of proposed rule making that, among other things, sought comment  on how best to improve collection of data regarding the gender, race, and  ethnicity of broadcast licenses. Finally, FCC adopted a report on  broadcast localism and a notice of proposed rule making.
Six restrictions on the ownership of television stations, radio stations, and  broadcast networks follow:    National television ownership cap. A single entity can own any number  of television stations nationwide as long as the stations collectively reach  no more than 39 percent of national television households. For purposes  of calculating the 39 percent limit, ultra-high frequency (UHF) television  stations are attributed with 50 percent of the television households in their  market, which FCC refers to as the UHF discount.
Local television ownership limit. A single entity can own two television  stations in the same DMA if (1) the “Grade B” contours of the stations do  not overlap or (2) at least one of the stations is not ranked among the top  four stations in terms of audience share and at least eight independently  owned and operating full-power commercial or noncommercial television  stations would remain in the DMA.
Local radio ownership limit. A single entity can own up to 5 commercial  radio stations, not more than 3 of which are in the same service (that is,  AM or FM), in a market with 14 or fewer radio stations, except that an  entity can not own, operate, or control more than 50 percent of the  stations in a market; up to 6 commercial radio stations, not more than 4 of  which are in the same service, in a market with 15 to 29 radio stations; up  to 7 commercial radio stations, not more than 4 of which are in the same  service, in a market with 30 to 44 radio stations; and up to 8 commercial  radio stations, not more than 5 of which are in the same service, in a  market with 45 or more radio stations.
Newspaper-broadcast cross-ownership ban. Following the effective  date of a new approach released by FCC on February 4, 2008, the  commission will presume that a proposed newspaper-broadcast  transaction is in the public interest if it meets the following test: (1) the  market at issue is one of the 20 largest DMAs; (2) the transaction involves  the combination of only 1 major daily newspaper and only 1 television or  radio station; (3) if the transaction involves a television station, at least 8  independently owned and operating major media voices would remain in  the DMA following the transaction; and (4) if the transaction involves a  television station, that station is not among the top 4 ranked stations in the  DMA. All other proposed newspaper-broadcast transactions would be  presumed not in the public interest. This new approach will replace an  absolute ban, which prohibits a single entity from having common  ownership of a full-power television or radio station and a daily newspaper  if the television station’s “Grade A” contour or the radio station’s  principal community service area completely encompasses the  newspaper’s city of publication.
Television-radio cross-ownership limit. A single entity can own up to 2  television stations (if permitted under the local television multiple  ownership cap) and up to 6 radio stations (if permitted under the local  radio multiple ownership cap) or 1 television station and 7 radio stations  in a market with at least 20 independently owned media voices remaining  post merger; up to 2 television stations and up to 4 radio stations in a  market with at least 10 independently owned media voices remaining post  merger; and 1 television station and 1 radio station regardless of the  number of independently owned media voices.
Dual network rule. A single entity can own multiple broadcast networks,  but cannot own two or more of the top four networks (that is, ABC, CBS,  FOX, and NBC).
In its December 18, 2007, action, FCC adopted rules limiting the number of  subscribers that a cable operator can serve nationwide. While FCC first set  limits on the number of subscribers that a cable operator could serve in  1993 and later modified its rules in 1999, the Court of Appeals for the  District of Columbia Circuit reversed and remanded those rules. FCC’s  new rules set the number of subscribers that a cable operator can serve at  30 percent nationwide.
section_title: Trends in Media Outlets
paragraphs: Since the 1970s, the number of media outlets has increased dramatically,  with large increases in the number of television and radio stations. In the  case of television, the number of full-power television stations increased  from 875 in 1970 to 1,754 in 2006; this increase occurred in both  commercial and noncommercial educational television stations.  Moreover, the number of broadcast networks that supply programming to  stations across the country increased from three major networks (ABC,  CBS, and NBC) to four major networks (ABC, CBS, FOX, and NBC) and  several smaller networks, such as The CW Television Network, MY  Network TV, and ION Television Network. In the case of radio, the number  of full-power radio stations more than doubled, from 6,751 stations in 1970  to 13,793 stations in 2006, with increases in AM, FM, and FM educational  stations. Daily newspapers illustrate a different trend—decreasing from  1,763 in 1970 to 1,447 in 2006. While the number of morning newspapers  increased from 334 in 1970 to 833 in 2006, the number of evening  newspapers decreased by more than half, from 1,429 to 614. Table 1  illustrates the trends in television and radio stations and newspapers.
Since the 1970s, the number of households subscribing to a multichannel  video program distributor (MVPD) has increased significantly, thereby  increasing the programming options available to many households. The  two most prominent MVPD platforms are cable and direct broadcast  satellite (DBS) services. Since 1975, the number of households subscribing  to cable service has increased from approximately 10 million to nearly 66  million in 2006, and since 1995, the number of households subscribing to  DBS service has increased from 2.2 million to over 29 million in 2006.  Table 2 illustrates the number of cable and DBS subscribers. According to  FCC’s most recent report on cable industry prices, the average cable  operator provided over 70 channels of programming, thereby expanding  the programming options available to subscribers of these services.  These nonbroadcast networks include a variety of national outlets—such  as CNN, Discovery Channel, ESPN, and FOX News—as well as regional  outlets—such as the California Channel, Comcast SportsNet Chicago, and  New England Cable News.
section_title: Trends in Media Ownership
paragraphs: While the number of media outlets has increased, the ownership of outlets  has evolved. In 1995, FCC eliminated the Financial Interest and  Syndication Rules, which had limited the ability of broadcast networks to  have ownership interest in programming broadcast on their network.  Subsequently, the broadcast networks increasingly became affiliated with  companies providing program production services. The Walt Disney  Company acquired ABC, Viacom acquired CBS, and NBC joined forces  with Universal Pictures. News Corporation—which launched the Fox  Broadcasting Network in 1986—also owns several production studios,  including 20th Century Fox. Each of the four major broadcast networks  owns television stations that reach more than 20 percent of the nation’s  television households. Other significant owners of television stations  include ION Media Networks, Tribune Company, and Broadcasting Media  Partners, Inc. Following passage of the 1996 Act, several companies  acquired a large number of radio stations. Clear Channel owned over 1,000  radio stations throughout the United States, and Cumulus Broadcasting  and Citadel Communications each owned over 200 stations.
The cable industry also experienced evolution in the ownership of some  properties. Cable operators, who distribute programming to subscribers,  are pursuing a strategy of regional clustering; this strategy involves  acquiring the cable systems throughout a geographic region. In its most  recent report on video competition, FCC estimated that there were 118  clusters with approximately 51.5 million subscribers. Comcast and Time  Warner Cable have emerged as the largest cable operators, with 26.8 and  16.6 million subscribers, respectively. While cable operators provide  many nonbroadcast networks to their subscribers, many nonbroadcast  networks are owned by cable operators or broadcast networks. For  example, among the nonbroadcast networks with the most subscribers,  CNN and TNT are affiliated with Time Warner, ESPN is affiliated with  Disney, USA Network is affiliated with NBC-Universal, and Discovery  Channel is affiliated with Cox, a large cable operator. On December 18,  2007, FCC adopted a further notice that seeks comment on vertical  ownership limits and cable and broadcast attribution rules, including for  example, the extent to which vertical integration can lead to foreclosure of  entry by unaffiliated programmers.
In recent years, some companies have taken steps to sell assets. In 2005,  Viacom split into two separate companies: Viacom and CBS Corporation.  The new Viacom includes many of the cable networks, such as MTV and  Nickelodeon, and CBS Corporation includes the broadcast network and  CBS television and radio stations. In 2006, The McClatchy Company  acquired Knight Ridder, one of the nation’s largest newspaper companies,  and subsequently sold 12 former Knight Ridder newspapers. For example,  The Philadelphia Inquirer and Philadelphia Daily News, former Knight  Ridder newspapers, are currently owned by Philadelphia Media Holdings  LLC, a private company. Also in 2006, Clear Channel announced plans to  sell 448 radio stations, all in markets outside the top 100, and its entire  television station group. More recently, The New York Times Company  sold its television stations and one of its radio stations. Alternatively, the  two satellite radio companies—Sirius and XM—have proposed a merger  that, if approved, would leave one company providing satellite radio  service.
section_title: Numbers of Media Outlets and Owners Generally Increase with Market Size, Although Operating Agreements May Reduce the Effective Number of Independent Outlets
paragraphs: Markets with large populations have more television, radio, and  newspaper outlets than less populated markets. In more diverse markets,  we also observed more radio and television stations and newspapers  operating in languages other than English, which contributed to a greater  number of outlets. Some companies participate in agreements to share  content or agreements that allow one entity to produce programming or  sell advertising through two outlets, among other arrangements. In our  case study markets, these agreements were prevalent in a variety of  markets, but not in the top three markets—New York, Los Angeles, and  Chicago. Finally, we found that the Internet expands access to media  content; however, we observed few news Web sites in our case study  markets that were unaffiliated with traditional media outlets.
subsections: section_title: The Size of Markets Broadly Influences the Number of Media Outlets and Owners
paragraphs: Markets with large populations have more television, radio, and  newspaper outlets than less populated media markets. Additionally, the  presence of a large Hispanic population in the media market increases the  number of outlets, as owners seek to provide Spanish-language outlets in  addition to the full range of English-language outlets supported by the  population level.
subsections: section_title: Top Three Markets
paragraphs: The top three media markets—New York, New York (1); Los Angeles,  California (2); and Chicago, Illinois (3)—have several attributes that set  them apart from other markets. First, these markets have very large  populations. Each of these markets has more than 3 million households.  Second, these markets have very diverse populations. For example, New  York is the largest African-American media market and the second-largest  Asian and Hispanic media market, Los Angeles is the largest Asian and  Hispanic media market and the sixth-largest African-American media  market, and Chicago is the third-largest African-American media market  and the fifth-largest Asian and Hispanic media market. Third, these  markets generally have high average household disposable income; the  New York market ranks fourth highest in the United States, the Los  Angeles market ranks twenty-fourth, and the Chicago market ranks  seventh. Finally, these markets also are the production and distribution  points for much of the media content in the United States—from films,  television shows, and radio programs to magazines and periodicals.
The top three media markets differ qualitatively from other markets in the  large and varied number of media outlets present in these markets. The  combination of large populations and relatively high disposable income  helps produce substantial advertising revenues for the media outlets in  these markets. These markets have more television and radio stations and  more newspapers than other media markets, and competition for cable  service from overbuilders also is more likely in these markets. Since  these markets have diverse populations, each market has numerous  broadcast outlets that provide content in languages other than English.  While Spanish is the most common language for non-English media,  outlets for content in Chinese, Korean, and other languages are also  present. Table 3 indicates how many outlets are located in the top three  markets.
FCC’s rules allow greater group ownership of media outlets in these three  markets because of their size. There are four television duopolies— common ownership of two television stations—in New York, three  duopolies in Los Angeles, and three duopolies in Chicago. In addition,  several companies own multiple radio stations in these markets; FCC’s  rules allow for common ownership of eight radio stations, no more than  five of which can be in the same service (AM or FM) in these markets.  There are some jointly owned newspaper and television stations and  newspaper and radio stations in each of these markets. Even with the  allowance for group ownership, these three markets still possess a great  number of owners who each operate a single broadcast outlet in either  radio or television in the respective market. Appendix II provides a more  detailed description of the media ownership for all 16 case study markets.
section_title: Large Markets
paragraphs: Of the four large markets we studied—Miami/Fort Lauderdale, Florida  (16); Charlotte, North Carolina (26); Nashville, Tennessee (30); and Wilkes  Barre/Scranton, Pennsylvania (53)—the Miami/Fort Lauderdale market  has the most television stations and in this respect more closely resembles  the top three media markets than the other large media markets. This is  due to the large number of Spanish-language outlets present; the  Miami/Fort Lauderdale area is the third-largest Hispanic media market in  the United States. In addition to television stations, the Miami/Fort  Lauderdale market has three daily newspapers, two of which are in  Spanish. The other three media markets in this size category have fewer  television stations. Only the Miami/Fort Lauderdale market had  competition for cable service, which also is present in the top three  markets. The number of outlets decreased markedly between the three  larger markets in this category and Wilkes Barre/Scranton (the 53rd- largest market). We could not determine if this was due to a change in the  number of outlets that can be supported between the 30th-largest market  (Nashville) and the 53rd-largest market, the lack of a core urban area in  Wilkes Barre/Scranton, or the relatively weak economy prevalent in  Wilkes Barre/Scranton. See table 4 for the number of outlets in the large  case study markets.
The medium-size markets we analyzed are Tucson, Arizona (68);  Springfield, Missouri (76); Chattanooga, Tennessee (86); Cedar  Rapids/Waterloo/Iowa City/Dubuque, Iowa (89); and Myrtle  Beach/Florence, South Carolina (105). Similar to the Miami/Fort  Lauderdale market, the Tucson market has more television stations than  the other case study markets in its size category, mainly because of the  relatively large Hispanic population in this medium-size market. There are  eight English-language television stations in Tucson, which is similar to  the number in the other four medium-size markets. However, Tucson has a  relatively large Hispanic population and therefore possesses a larger  number of media outlets due to the presence of Spanish-language  television and radio stations. Television markets which lack a dominant  urban area and contain two or more large towns located some distance  apart are often split into smaller radio markets. The Cedar  Rapids/Waterloo/Iowa City/Dubuque DMA contains three Arbitron radio  markets and the Myrtle Beach/Florence DMA is split into two separate  Arbitron radio markets. See table 5 for the number of outlets in the  medium-size case-study markets.
The small markets we analyzed are Terre Haute, Indiana (151); Sherman,  Texas/Ada, Oklahoma (161); Jackson, Tennessee (174); and Harrisonburg,  Virginia (181). These small markets are characterized by significantly  fewer media outlets—television stations, radio stations, and newspapers— than the larger markets. Table 6 illustrates the number of outlets in the  small case study markets. Hence, for these markets, the conversion to  digital broadcasting offers the possibility to improve the free, over-the-air  choices to residents. Already, commercial television stations in  Sherman/Ada and Harrisonburg use a second digital channel to provide  the signal from a broadcast network that is not otherwise present in the  market. For example, WHSV in Harrisonburg, an ABC affiliate, broadcasts  the FOX network on one of the station’s digital channels.
section_title: Some Media Companies Participate in Operating Agreements
paragraphs: Some media companies participate in operating agreements that involve a  partnership between two or more outlets. For example, some media  companies participate in agreements to share content among several  outlets. Other media companies participate in agreements wherein one  company produces content or sells advertising through its own outlets and  another company’s outlets. These operating agreements are referred to,  either by industry participants or FCC’s rules, by a variety of names,  including joint sales agreements, local marketing agreements, and time  brokerage agreements. FCC’s attribution rules—which seek to identify  those interests in or relationships to licensees that have a realistic  potential to affect the programming decisions of licensees or other core  operating functions—apply to several types of operating agreements.  Additionally, the Newspaper Preservation Act of 1970 allows two  competing newspapers in one community to merge some operations to  help ensure the survival of both newspapers; the resulting arrangements  are referred to as joint operating agreements.
In our 16 case study markets, we found several instances of media  companies participating in operating agreements. We found these  agreements in a variety of markets but not in the top three markets,  suggesting that market size may influence the benefits that companies  realize through such agreements. We found television stations  participating in operating agreements in five markets—Nashville, Wilkes  Barre/Scranton, Springfield, Myrtle Beach/Florence, and Terre Haute. In  Springfield, there were two operating agreements between television  stations and in Wilkes Barre/Scranton there were three operating  agreements between television stations. We also found operating  agreements between radio stations in Harrisonburg and Nashville. Finally,  in Tucson, the two competing daily newspapers participate in a joint  operating agreement.
In addition to formal operating agreements, media companies in a market  often maintain informal content-sharing arrangements with each other.  These most often cross different types of media, rather than occurring  among competitors within the same industry segment. In our case study  markets, we found a newspaper sharing articles with a television station; a  newspaper sharing articles with a radio station in return for advertising  spots; and a newspaper sharing journalists with a television station. In  markets with common ownership of a radio or television station and a  newspaper, such sharing of content and journalism resources occurred as  a matter of course. We also found some contractual sharing of content  between media outlets of the same type. Most often, one television station  produced local news programs for other stations in the same market.
To some extent, these operating agreements may reduce the number of  independent outlets. For example, in Wilkes Barre/Scranton, we identified  eight television stations. However, one owner of two stations participated  in an agreement with a third station. Additionally, the remaining four  television stations participated in two separate agreements—each  agreement covering two stations. Thus, while there are eight television  stations and seven owners in Wilkes Barre/Scranton, there are three loose  commercial groupings in the market. Similarly, in Springfield, while there  are six television stations, four stations participate in two separate  agreements. This example suggests that the number of independently  owned outlets in a given market might not always be a good indicator of  how many independently produced local news or other programs are  available in a market.
section_title: The Internet Is Expanding Access to Media Content
paragraphs: The Internet delivers content from a virtually limitless supply of sources.  For example, while residents of New York can read The New York Times,  residents in Harrisonburg with access to the Internet also can read this  publication. Most of the traditional media outlets—newspapers, radio  stations, and television stations—in our case study markets maintain a  Web site. This provides another means for residents to access the content  of these outlets. However, we identified few news Web sites in our case  study markets that were unaffiliated with the traditional media outlets.  While there are many blogs and Web sites, when we spoke with  stakeholders about assessing the number of “voices” in a media market,  there was no consensus on how to count Internet outlets. Some  stakeholders said that audience size was less important than the existence  of many potential voices, while other stakeholders said that voices on the  Internet mattered only when they reached an audience above a certain  minimum size. Further, some stakeholders said that journalistic content  was important, such as that arising from news gathering and  investigations.
section_title: Ownership of Broadcast Outlets by Minorities and Women Appears Limited, but Comprehensive Data Are Lacking
paragraphs: While FCC collects data on the gender, race, and ethnicity of radio and  television station owners every 2 years through its Ownership Report for  Commercial Broadcast Stations, or Form 323, we found that these data  have several weaknesses that undermine their usefulness for tracking and  periodically reporting on the status of minority and women ownership.  These weaknesses include (1) exemptions from filing for certain types of  broadcast stations, such as noncommercial stations; (2) inadequate data  quality procedures; and (3) problematic data storage and retrieval.  Moreover, there are no other reliable government sources on the status of  minority and women ownership. Nevertheless, the available evidence from  industry stakeholders and experts we interviewed, as well as government  and nongovernment reports, suggests that ownership of broadcast outlets  by these groups is limited. We identified three primary barriers  contributing to the limited levels of ownership by minorities and women.
These barriers include (1) the large scale of ownership in the media  industry, (2) a lack of easy access to sufficient capital for financing the  purchases of stations, and (3) the repeal of the tax certificate program,  which provided financial incentives for incumbents to sell stations to  minorities.
subsections: section_title: FCC Lacks Comprehensive Data on Ownership of Broadcast Outlets by Minorities and Women
paragraphs: Diversity has been a long-standing policy goal of FCC, including ownership  by minorities and women. In 1998, FCC issued rules to collect data on the  gender, race, and ethnicity of broadcast licensees. FCC decided to collect  these data through its Annual Ownership Report, or Form 323. FCC noted  that it was appropriate to develop “precise information on minority and  female ownership of mass media facilities” and “annual information on the  state and progress of minority and female ownership,” thereby positioning  “both Congress and the Commission to assess the need for, and success of,  programs to foster opportunities for minorities and females to own  broadcast facilities.” FCC began collecting these data in 1999.
The Form 323 is the only mechanism through which FCC collects  information on the gender, race, and ethnicity of broadcast owners. FCC  requires all commercial AM and FM radio stations and television stations  to report the gender, race, and ethnicity of each owner with an attributable  interest on the Form 323. Owners and licensees must file the Form 323  every 2 years, whenever there is a transfer of control or assignment, or  after the grant of a construction permit for a new commercial broadcast  station.
As FCC’s only information source on owners’ gender, race, and ethnicity,  the Form 323 data potentially could be used to determine and periodically  report on the level of minority and women broadcast ownership. However,  we identified several weaknesses that limit the usefulness of the Form 323  data.
Filing exemptions. Sole proprietors, partnerships, and noncommercial  stations are not required to file the Form 323. Since the data from Form  323 do not include stations owned by sole proprietors, partnerships, or  noncommercial stations, it is not possible to use the Form 323 data to  identify either the full universe of broadcast stations owned by minorities  and women or the number of minority and women owners. FCC also does  not require the filing of the Form 323 for low-power stations.
Data quality procedures. According to FCC officials, FCC does not  verify or periodically review the gender, race, and ethnicity data submitted  on the Form 323. According to these officials, a staff person from FCC’s  Video Division reviews submitted Form 323s and this staff person focuses  on ensuring compliance with the commission’s multiple ownership and  citizen ownership rules. These officials told us that station owners were  responsible for determining the accuracy of their Form 323 submissions.  Should an error be found by the owner, FCC requires the owner to submit  an additional Form 323.
Data storage and retrieval. Companies must file the Form 323  electronically. However, FCC allows owners to provide attachments with  their electronic filing of the Form 323. These attachments may include the  gender, race, and ethnicity data. Since these data are not entered into the  database, the data are unavailable for electronic query. Of further concern,  the database retains all submitted Form 323s, even forms that contain  incorrect information and have since been updated with a corrected Form  323. Thus, any aggregation or summary of the Form 323 records through  electronic query is unreliable according to FCC officials.
FCC has taken some steps to address concerns with the Form 323 data,  but overall some weaknesses remain. According to FCC officials, FCC  added an amendment process to the Form 323 interface, thereby allowing  owners to modify information on a previously submitted Form 323. FCC  also put in place edit checks that preclude owners from skipping  questions, including questions on the owners’ gender, race, and ethnicity.  However, FCC still allows attachments for Form 323s to be submitted and  has no regular review mechanism for these attachments to determine if  the owners provided correct information biennially as required. Moreover,  there are no consequences for misfiling that would encourage accurate,  complete, and timely submission of the Form 323. On December 18, 2007,  FCC adopted a Notice of Proposed Rulemaking that seeks comment on  how the commission can best improve its collection of data regarding the  gender, race, and ethnicity of broadcast licensees.
section_title: Ownership of Broadcast Outlets by Minorities and Women Appears Limited
paragraphs: While reliable government data on ownership by minorities and women  are lacking, ownership of broadcast outlets by these groups appears  limited. According to the industry stakeholders and experts we  interviewed, the level of ownership by minorities and women is limited.  Recent studies generally support this conclusion. Three reports  commissioned by FCC as part of its broadcast ownership proceeding  found relatively limited levels of ownership of television and radio stations  by minorities and women. Further, in a 2006 report, Free Press found that  for full-power television stations, women and minority ownership was  about 5 percent and 3 percent, respectively. Specifically, the report noted  that women owned a majority stake in 67 of 1,349 full-power commercial  television stations and minorities owned 44 stations, 9 of which were  owned by one company. In another report, Free Press estimated that  women owned approximately 629 of 10,506 (or 6 percent) of full-power  radio stations and minorities owned 812 stations (or 8 percent) of full- power radio stations.
section_title: Minorities and Women Encounter a Variety of Barriers to Ownership of Broadcast Outlets
paragraphs: According to prior government reports and industry stakeholders and  experts we interviewed, three factors help explain the relatively small  percentages of minority and women broadcast owners.
Scale of ownership. In 2000, FCC and the National Telecommunications  and Information Administration (NTIA) released separate reports  suggesting that the current scale of ownership had been detrimental for  minority and women ownership of broadcast outlets. In 2000, FCC  commissioned a report that found industry deregulation in 1996 and the  resulting consolidation had produced significant barriers to new entry and  to the viability of small, minority- and women-owned companies. The  report cited inflated station prices and disparate advertising revenues.  NTIA’s report included similar observations about the impact of  consolidation on station prices and advertising revenue.
Industry representatives and experts we interviewed also identified the  scale of ownership as a barrier for minorities and women. Thirty-six of 56  interviewees who mentioned barriers to ownership reported that the  consolidation of broadcast ownership had been detrimental for minority  and women ownership. According to these industry representatives and  experts, the scale of current ownership mattered in several important  ways. First, few stations are made available for purchase, limiting  opportunities for the entry of new owners, such as minorities and women.  Second, incumbent owners may prefer to trade stations with other  incumbent owners rather than sell stations. Given the limited ownership  by minorities and women today, trading does little to expand their  ownership. Third, when stations become available for sale, investors and  other financing entities prefer multiple station purchases rather than  single station purchases in order to capture economies of scale. Like  trading, such transactions favor incumbent companies that are well- established over new entrants such as minorities and women. Lastly, the  scale of the industry affects the viability of current and prospective  minority and women owners, since these owners must often compete with  large conglomerate owners with sizable market share and greater  resources.
Access to capital. Both FCC’s and NTIA’s reports on minority and  women ownership also included discussion and findings on the role of  capital and the lack thereof for minorities and women. According to FCC’s  commissioned report, access to capital was the barrier most often cited by  study participants. The report found that banks often repeatedly rejected  minority broadcast owners as applicants for a variety of reasons, ranging  from racial discrimination to a lack of familiarity with the industry on the  part of the bank. Similarly, NTIA’s report noted the importance of access  to capital and described public and private sources of financing for  minorities and women. The report concluded that despite these sources,  access to capital continued to be a key concern.
Industry stakeholders and experts we interviewed also mentioned the  importance of access to capital and financing and the challenge it presents  to minority and women ownership. Thirty-five of 56 interviewees reported  that a lack of access to capital impeded greater entry by minorities and  women into the broadcast industry. In particular, these industry  representatives and experts described two ways in which the barrier  posed by a lack capital is compounded by the nature of station sales and  FCC rules. First, since stations generally do not advertise their properties  for sale, individuals and companies looking to purchase a station must  have cash on hand. Prospective buyers cannot wait for an announced sale  and then acquire financing. This is a challenge for minority and women  broadcasters, who often lack information on upcoming station sales and  generally have fewer financial resources. Second, sellers are deterred from  working with buyers who lack capital since any equity remaining in the  station would be considered attributable interest under FCC’s rules.  Retaining attributable interest in one property could make it difficult for  these owners to buy different properties in the same market, due to FCC’s  local ownership limits. Consequently, sellers would forgo working with  prospective buyers who lack readily available capital rather than assume  any risk to potential future acquisitions.
Repeal of the tax certificate program. From 1978 to 1995, FCC  operated a tax certificate program under section 1071 of the Internal  Revenue Code that provided for the seller of a broadcast station to defer  capital gains taxes on the sale if the station was sold to a minority-owned  company. In 1995, the Congress repealed this program. During this period,  FCC issued a total of 328 tax certificates for use in broadcast station  transactions (285 for radio station sales and 43 for television station sales).  Both FCC’s and NTIA’s reports on minority and women ownership cited  the importance of the tax certificate as an incentive for incumbent  broadcast owners to advertise and work with prospective minority buyers.  FCC’s commissioned report described the tax certificate program as the  “single most effective program in lowering market entry barriers and  providing opportunities for minorities to acquire broadcast licenses in the  secondary market.” NTIA’s report also found that the program fostered  minority ownership. Many experts we interviewed also agreed that this  program was important for promoting minority ownership. Twenty-five of  56 stakeholders we interviewed said that the elimination of the tax  certificate program was a factor in the current limited level of minority- owned broadcast stations.
section_title: A Variety of Economic, Legal and Regulatory, and Technical Factors Influence Media Ownership
paragraphs: Economic factors—including high fixed costs and the size of the market— influence the number of media outlets available in markets, the presence  of operating agreements between outlets, and incentives for firms to  consolidate their operations. Legal and regulatory factors appear to  influence ownership of media outlets as well, by constraining the number  and types of media outlets that a single entity can own. Lastly,  technological factors, such as the emergence of the Internet, appear to  facilitate entry by allowing entry with limited investment; however  stakeholders’ opinions varied on the significance of these entrants on  media markets.
subsections: section_title: High Fixed Costs and Local Market Size Are Important Economic Factors that Influence the Number and Ownership of Media Outlets
paragraphs: We found that fixed costs are prevalent in the media industry and are an  important economic factor influencing the number and ownership of  media outlets. Fixed costs refer to those costs that do not change with the  number of units produced or sold. Fifty-two of 102 stakeholders we  interviewed mentioned that high fixed costs are a factor influencing media  ownership, and the academic literature also highlighted the importance of  fixed costs. For example, in broadcast network television, two  stakeholders reported that the fixed costs of producing 1 hour of  programming range from $3 million to $5 million—regardless of how many  viewers the programming attracts. Similarly for newspapers, the costs of  purchasing a printing press and producing and editing news stories are not  very sensitive to the number of copies a newspaper produces or sells.  Stakeholders also reported high fixed costs for radio and television  stations, cable television, and DBS.
The size of the local market also is an important economic factor  influencing the number and ownership of media outlets, since market size  broadly determines an outlet’s potential for generating advertising  revenues. For example, several stakeholders reported that although the  costs of operating television and radio stations are similar regardless of  market size, smaller markets have smaller audiences and fewer local  advertisers for station operators to pursue. Accordingly, stakeholders  reported that owners are less likely to sell stations in large markets than in  smaller markets. According to data from Bear, Stearns and Company, Inc.,  4 of the 137 television station transactions announced in the first two  quarters of 2007 involved stations broadcasting in the top three markets.  Conversely, stakeholders representing a large radio group owner and a  national television broadcaster both reported that their companies are  currently selling stations in smaller markets.
Both high fixed costs and market size have implications for the number of  outlets in a given market, the presence of operating agreements between  outlets, and incentives for firms to consolidate their operations in local  and national markets.
Number of outlets. Market size and fixed costs influence the number of  outlets in a market. The size of the market broadly determines the  advertising revenues available to outlets in the market. In addition, costs  in the media industry do not vary considerably between large and small  markets. Therefore, large markets can generally support more outlets than  small markets. Twenty-six interviewed stakeholders mentioned that the  size of the market influences the number of outlets available, and 10  stakeholders reported that markets with larger populations and  advertising revenues can support more media outlets and owners than  smaller markets. For example, in New York—the largest market—we  identified 21 television stations and 15 separate owners for those stations.  In contrast, in Harrisonburg, Virginia—the smallest market in our review— we identified only 2 broadcast television stations and 2 separate owners,  one of which was a public television station. Similarly, in the newspaper  industry, several stakeholders reported that most newspaper markets can  support only one daily newspaper because of high fixed costs in the  industry. Accordingly, 9 of the 16 markets we evaluated had one daily  newspaper, and 4 markets supported two newspapers.
Operating agreements. The size of a local market and high fixed costs  produce incentives for media outlets to enter into operating agreements  with other local outlets. Specifically, we found that outlet owners in  markets with smaller advertising revenues have incentives to enter into  operating agreements with other outlets to spread fixed costs across  multiple outlets to maximize their profitability. Thirty interviewed  stakeholders reported that the size of the market can influence the need  for such operating agreements. In our case study analyses, we identified 9  operating agreements between 17 television stations in 5 markets.  We  found these arrangements in a variety of markets, but not in the top three  markets. It appears that medium-size markets are better suited to these  arrangements than small markets because they offer a larger pool of  potential outlet partners than would be available in smaller markets.  Furthermore, two stakeholders reported that these agreements may  increase the number of outlets available in a market by helping weaker  stations remain in operation and by bringing new broadcasting networks  into a market.
Local and national consolidation. The combination of high fixed costs  and market size also encourages media consolidation both within local  markets and nationwide. Because competition for advertising revenues  among radio and television broadcast stations occurs at the local level,  nine stakeholders representing television, radio, and newspaper  companies reported that their industries have incentives to consolidate  operations across multiple outlets to reduce their fixed costs and claim a  larger share of available advertising revenues. For example, six  stakeholders reported that owning multiple stations in a local market  allows a single owner to program its stations with diverse formats to reach  a larger share of local listeners and provide multiple channels for  advertisers. Media firms likewise have incentives to seek economies of  scale and consolidate their operations nationally. For example,  stakeholders reported that the cable industry has consolidated in recent  years to cluster local systems into wider regional networks to reach larger  audiences and serve a wider range of advertisers. Stakeholders also  reported that serving a wider network of subscribers gives cable operators  greater leverage in negotiating agreements to carry programming  produced by broadcast and cable television networks. In the newspaper  industry, one national newspaper company reported that it publishes  almost 1,000 nondaily newspapers across the country, which enables the  company to offer flexible advertising packages to national and local  advertisers.
section_title: Stakeholder Perspectives Vary on the Influence of Legal and Regulatory Factors on Media Ownership
paragraphs: In addition to economic factors, several legal and regulatory policies  appear to have influenced media ownership, including local television and  radio station ownership limits, the newspaper-broadcast cross ownership  ban, and the 1996 Act. However, stakeholder perspectives varied on the  extent to which the individual policies may have influenced current  ownership.
Local television and radio station ownership limits. FCC’s rules limit  the number of radio stations, television stations, and combinations of  radio and television stations that a single entity can own; as such, the rules  influence the ownership of these media outlets. Twenty-three of 29  industry stakeholders we spoke with cited either the local radio or  television limits as a factor influencing the ownership of media outlets.  Several stakeholders reported that the local television ownership limit— which permits ownership of two television stations in larger markets— allows over-the-air television stations to better compete with other media  outlets, including cable television and DBS providers, which have  significantly more channels and air time to sell advertising. Several other  stakeholders reported that this rule would be more beneficial if it were  permitted in smaller markets to preserve struggling outlets, rather than in  large markets where advertising revenues are greater. With regard to  radio, several industry stakeholders reported that the local ownership  caps limit consolidation in markets where companies were operating at  the ownership limits.
Newspaper-broadcast cross ownership ban. By limiting the markets  where a single entity can have common ownership of a daily newspaper  and a broadcast outlet, FCC’s rules affect the ownership of these media  outlets. Stakeholders from three companies with newspaper holdings  reported that the potential synergies and economic benefits to cross- ownership are overstated; two stakeholders reported that differences  between television and newspaper cultures and products limit  collaboration between the two platforms. On the other hand, three  companies owning both newspapers and television stations in the same  market reported that cross-ownership offers synergies such as improved  sharing of resources and information between outlets. Similarly,  stakeholders from two companies indicated that cross-ownership has  helped their outlets produce more in-depth, local news than they would  otherwise be able to provide.
Telecommunications Act of 1996. The 1996 Act loosened restrictions  on the ownership of radio stations—allowing greater ownership of local  radio stations and eliminating nationwide limits on ownership of radio  stations. Twenty of 45 nonbusiness stakeholders, such as academics,  industry associations, and think tanks, identified the 1996 Act as a factor  influencing media ownership; 9 of 57 business stakeholders similarly  identified the 1996 Act. Three stakeholders reported that the changes in  the 1996 Act brought capital, business expertise, and content diversity to  the radio industry, as new entrants sought to invest in underfunded radio  stations. Alternatively, several other stakeholders reported that the 1996  Act resulted in overconsolidation in the radio industry, as many small  operators were bought out by conglomerate owners.
section_title: Technological Factors Appear to Facilitate New Entry
paragraphs: New technologies appear to facilitate entry, thereby promoting new  content and competition. In particular, the Internet provides new  opportunities for individual citizens and companies to produce their own  Internet publications with little investment. For example, individuals and  companies no longer need to acquire a broadcast license and invest in  broadcast facilities to distribute content to a wide audience. Forty-four  stakeholders told us that the Internet creates an abundance of outlets,  while only 17 disagreed. The Pew Internet & American Life Project, an  Internet-focused research center, found that in 2003, “more than 53 million  American adults had used the Internet to publish their thoughts, respond  to others, post pictures, share files and otherwise contribute to the  explosion of content available online.” Additionally, 67 of 102 stakeholders  mentioned competition from new entrants from the Internet or new  telecommunications services as a factor influencing media ownership. For  example, six newspaper industry stakeholders reported that industry  revenues have suffered from the availability of low-cost or free classified  advertising services available on the Internet.
While many stakeholders reported that the Internet creates an abundance  of outlets, opinions varied as to the significance of these outlets. For  example, several stakeholders cited increases in the number of outlets  available on the Internet, such as blogs, but said there is little evidence  that these outlets are widely read or are journalistic substitutes for  newspapers. Similarly, several other stakeholders estimated that a  significant portion of the content available on these Web sites originates  from large, established media firms such as newspapers.
section_title: Stakeholders’ Opinions Varied on Modifications to Media Ownership Rules, but Business Stakeholders Were More Likely to Favor Deregulation
paragraphs: The stakeholders we interviewed seldom agreed on proposed  modifications to media ownership rules. However, most business  stakeholders expressing opinions on these rules were more likely to report  that they should be relaxed or repealed. In contrast, nonbusiness  stakeholders who expressed opinions on the rules were more likely to  report that the rules should be left in place or strengthened. Both business  and nonbusiness stakeholders who expressed an opinion on the previously  repealed tax certificate program supported either reinstating or expanding  the program to encourage the sale of broadcast outlets to minorities.
Newspaper-broadcast cross-ownership ban. As mentioned earlier, on  December 18, 2007, FCC modified its rules to permit common ownership  of a daily newspaper and broadcast outlet in some markets. Prior to FCC’s  action, the stakeholders we spoke with were fairly evenly divided on  whether FCC should modify its rule prohibiting cross-ownership of  newspapers and broadcast outlets in the same local area. Of the 50  stakeholders expressing an opinion on the matter, 27 reported that the  rule should be repealed and 23 said that the rule should either be left as is  or strengthened. However, among business and nonbusiness stakeholders  interviewed, there were clear differences in opinion on this issue.  Fourteen of 20 nonbusiness stakeholders were in favor of strengthening or  leaving the rule in place. In contrast, 21 of 30 business stakeholders were  in favor of repealing the regulation. For example, 13 of 14 stakeholders  from multisector media companies stated the rule should be repealed.
Local television and radio ownership limits. Stakeholders were fairly  evenly divided on whether FCC should alter rules limiting the number of  broadcast television and radio stations a single entity can own in a local  market. Of the 50 stakeholders expressing an opinion on the matter, 27  said that the rules should be repealed and 23 said that the rule should  either be left as is or strengthened. However, opinions within stakeholder  segments were more consistent. Fourteen of 19 nonbusiness stakeholders  were in favor of strengthening or leaving the rules in place, while 22 of 31  business stakeholders were in favor of repealing the regulations.
National television ownership cap. The majority (65 of 102) of  stakeholders expressed no opinion on this issue. Of the 37 who did  express an opinion, 22 said that the cap should be left as is or lowered,  further restricting ownership, while 15 favored raising or repealing the  cap. But these results differed for nonbusiness and business stakeholders.  Whereas 11 of 15 nonbusiness stakeholders stated that the cap should be  left as is or lowered, further restricting ownership, 11 of 22 business  stakeholders indicated that the cap should raised or repealed.
Reinstitution of minority tax certificate program. Of the 102  stakeholders interviewed, most (72) expressed no opinion as to whether  the minority tax certificate program should be reinstated. However, among  the 30 stakeholders who mentioned this issue, there was broad consensus  in favor of reinstating some version of this program. Twenty-eight of these  30 stakeholders indicated that the program should be either reintroduced  without changes or expanded, and 2 said that the program was not needed  and should not be reinstated.
section_title: Conclusion
paragraphs: The media serve an important function in American life through their role  in disseminating news, information, and entertainment. Though media  options vary by local market, the overall growth in the communications  industry and the emergence of the Internet have provided unprecedented  levels of media choices to the American public. At the same time,  economic forces appear to encourage local and national consolidation and  operating agreements that reduce the number of independent voices.  Moreover, though smaller owners, including minorities and women, have  opportunities to enter the media industry by way of Internet-based and  niche publications, these groups continue to face long-standing challenges  to the ownership of radio and television stations. Since 1999, FCC has  collected data on the gender, race, and ethnicity of radio and television  station owners. In undertaking this effort, FCC noted that it was  appropriate to develop “precise information on minority and female  ownership of mass media facilities” and “annual information on the state  and progress of minority and female ownership,” thereby positioning “both  Congress and the Commission to assess the need for, and success of,  programs to foster opportunities for minorities and females to own  broadcast facilities.” Yet, data weaknesses stemming from how the data  are collected, verified, and stored limit the benefits of this effort. Further,  more accurate and reliable data would allow FCC to better assess the  impact of its rules and regulations and would enable the Congress to make  more informed legislative decisions about issues such as whether to  reinstate the tax certificate program. While FCC recently adopted a Notice  of Proposed Rulemaking regarding its data on broadcaster licensee  gender, race, and ethnicity, this process has only recently begun and its  outcome is unclear.
section_title: Recommendation for Executive Action
paragraphs: To more effectively monitor and report on the ownership of broadcast  outlets by minorities and women, we recommend that the Chairman, FCC,  identify processes and procedures to improve the reliability of FCC’s data  on gender, race, and ethnicity so that these data can be readily used to  accurately depict the level, nature, and trends in minority and women  ownership, thereby enabling FCC and the Congress to determine how well  FCC is meeting its policy goal of diversity in media ownership.
section_title: Agency Comments
paragraphs: We provided a draft of this report to FCC for its review and comment. FCC  provided technical comments that we incorporated where appropriate.  FCC did not provide comments on our recommendation. FCC’s written  comments appear in appendix IV.
As agreed with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  date of this letter. At that time, we will send copies of this report to the  appropriate congressional committees and to the Chairman of the Federal  Communications Commission. We will also make copies available to  others upon request. In addition, the report will be available at no charge  on the GAO Web site at http://www.gao.gov.
If you or your staff have any questions about this report, please contact me  at (202) 512-2834 or heckerj@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. Contact information and major contributors to this report  are listed in appendix V.
section_title: Appendix I: Scope and Methodology
paragraphs: To assess the current ownership of media outlets, we used a case study  methodology. The case studies consisted of the largest city in 16 Nielsen  Designated Market Areas (DMA). To select the case study DMAs, we used  a stratified random sample. We obtained the 2007 list of DMAs from the  Nielsen Media Research Web site. We stratified the DMAs by size and  randomly selected four large, four medium-size, and four small markets for  the case study analysis. We defined large markets as those with 500,000 to  3 million households; medium-size markets as those with 150,000 to  499,999 households; and small markets as those with fewer than 150,000  households. In addition to the 12 random selections, we selected the top  three markets (New York, Los Angeles, Chicago) as a separate take-all  stratum and selected Tucson as a test market in which to count outlets  because of its large Hispanic population.
Within each market, we counted the number of television stations, radio  stations, newspapers, and multichannel video programming distributors  (MVPD) and the owners of these outlets. We considered outlets available  to residents in the largest city to avoid counting multiple outlets not  present throughout the market; outlets not counted primarily consist of  weekly suburban newspapers not published in the largest city. Below we  discuss our approach to counting television stations, radio stations,  newspapers, and multichannel video programming distributors.
Television stations. We used the Warren Television and Cable Factbook:  Online to count the number of full-power television stations located in  each market. We included both commercial and noncommercial full-power  television stations in our count of stations. We used company Web sites  and ownership data that stations filed with the Federal Communications  Commission (FCC) through its Form 323 to determine the ownership of  the station. For commercial stations, we counted the owner as the  ultimate legal entity on whose behalf the ownership was registered with  FCC. This provided an accurate count of group ownership, as well as  identified any multiple station ownership within a single market.
Radio stations. We first determined the largest city located within each  television market. Some selected case study markets had multiple core  cities; we used Miami for the Miami/Fort Lauderdale DMA, Scranton for  the Wilkes Barre/Scranton DMA, Florence for the Myrtle Beach/Florence  DMA, and Cedar Rapids for the Cedar Rapids/Waterloo/Iowa City/Dubuque  DMA. We used FCC data to determine the number of full-power  commercial and noncommercial radio stations located within close  listening distance of the city. Due to its large geographic area and sparse  population, we identified the four most populous counties in the  Sherman/Ada DMA and determined the number of radio stations located  within 20 miles of the largest town in each county. We adopted this  approach because the market is too small to have an Arbitron radio  market. The Sherman/Ada market also is located between the Oklahoma  City and Dallas/Fort Worth markets, so we used an atlas to ensure that the  radio stations located within 20 miles of Ada, Oklahoma, and Sherman,  Texas, both located on the geographical edge of the DMA, were physically  located inside the Sherman/Ada DMA.
Our methodology produced counts of radio stations that may not match  the actual number of full-power radio stations located in a DMA for one or  both of the following reasons. First, the DMA may contain more than one  Arbitron radio market, such as in the Cedar Rapids/Waterloo/Iowa  City/Dubuque DMA and we counted radio stations from only one radio  market. Second, the DMA is geographically large and the number of full- power commercial and noncommercial radio stations located within close  listening distance of the core city does not capture all of the radio stations.
Newspapers. We used Bowker’s News Media Directory to identify the  daily, weekly, ethnic, religious, and special interest publications whose  area of dominant influence included the core urban area. We counted daily  and weekly newspapers separately and combined the ethnic, religious, and  special interest publications into the “other” category. We also surveyed  Web sites of the major daily newspapers in the core urban area of each of  our case study markets to determine if there were any additional  publications not contained in Bowker’s News Media Directory. We also  used the directory from the New American Media organization to identify  additional ethnic publications available in New York, Los Angeles,  Chicago, Miami, Charlotte, Nashville, and Chattanooga. This source did  not list publications for the other case study markets. Fieldwork in the  Nashville and Tucson markets turned up additional publications that were  missing in our data source. Our data sources likely undercount small local  weeklies and other types of independent journals.
Multichannel video programming distributors. We obtained the list of  cable operators in each state from FCC’s database of registered cable  operators (http://www.fcc.gov/mb/engineering/liststate.html). We used the  Warren Television and Cable Factbook to verify that a cable company  listed in the FCC database provided service in the core urban area. If the  market contained more than one urban area, we used the largest city (e.g.,  Miami). In addition to cable companies, we included both direct broadcast  satellite companies (DirecTV and EchoStar). The minimum MVPD count a  market could have with this methodology is three. Any number greater  than three reflects the presence of a cable overbuilder or a  telecommunications company that is offering subscription television  services in the core urban area of the DMA.
In addition to case studies, we reviewed the relevant literature and  conducted interviews to assess the current ownership of media outlets.  We identified studies through a general literature review. We interviewed  agency officials at FCC and the National Telecommunications and  Information Administration (NTIA) about media ownership policies. We  also identified 102 stakeholders in academia, think tanks, nonprofits, and  media companies and interviewed them to obtain their views on FCC’s  ownership policies and issues affecting media ownership. We used the  same structured interview for all interviewees and analyzed the content of  the interview responses. To ensure consistent analysis of the interview  responses, we had two reviewers independently apply the content analysis  tool to each interview write-up and standardized the coding to ensure  reliability. We cross-tabulated the interview content to determine patterns  in responses and the extent to which interview subjects supported  particular positions.
To identify the economic, legal and regulatory, and technological factors  affecting media ownership, we reviewed the relevant literature, studies,  and regulations and conducted interviews. We obtained and analyzed data  on the radio and television industries from Bear, Stearns and Company,  Inc. We obtained data from the Census Bureau’s 2006 American  Community Survey to study the economic and demographic  characteristics of households in the metropolitan statistical area around  the central city in each case study DMA. We obtained data on the average  household effective buying income for each DMA from the Television  Bureau of Advertising for all 210 DMAs; we also obtained the list of top 25  Hispanic, African-American, and Asian media markets from the bureau.  We reviewed the relevant economic literature and studies on media  ownership. We reviewed relevant legislation and FCC notices, orders, and  reports to assess legal factors. We also obtained information on economic,  legal and regulatory, and technological factors from industry stakeholders  as part of the structured interview process.
To describe the levels of minority and women ownership of broadcast  outlets, to identify factors that help explain these levels, and to assess  FCC’s data collection efforts, we reviewed relevant reports, interviewed  agency officials and industry stakeholders, and analyzed FCC’s forms and  processes. To describe the levels of minority and women ownership of  broadcast outlets, and factors affecting their ownership, we interviewed  industry stakeholders, FCC and NTIA officials, and members of FCC’s  Advisory Committee on Diversity for Communications in the Digital Age.  We also reviewed relevant reports prepared by or for FCC, NTIA, and  nongovernment organizations (such as Free Press). To determine FCC’s  data collection efforts, we reviewed the relevant regulatory forms (such as  FCC’s Form 323), and FCC documents and commissioned reports.  Additionally, we interviewed FCC officials responsible for collecting the  Commission’s data on broadcast ownership about the completeness and  quality of the information in their databases. Because of inadequacies in  the FCC ownership data, evidence suggesting limited ownership of media  outlets by minorities and women comes from stakeholder opinions, as  well as studies commissioned by FCC and prepared by NTIA and  nongovernment organizations.
We conducted this performance audit from February 2007 through March  2008 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
section_title: Appendix II: Results from Case Study Locations
paragraphs: To study the nature and level of media ownership, we randomly selected  12 case study markets, including 4 from each of three market strata— large, medium, and small. In addition, we selected the three largest  markets as a separate stratum and judgmentally selected an extra market  from the medium stratum (Tucson) to test our methodology for data  collection and structured interviews. Information about the markets we  selected for case study analysis appears in table 7. These media markets  account for about 20 percent of all television households in the United  States. For information about our methodology for counting outlets in  each media market, see appendix I.
subsections: section_title: The Three Largest Media Markets
subsections: section_title: New York, New York (1)
paragraphs: The New York City designated market area (DMA) is the largest media  market in the United States, with over 7 million households. This media  market comprises 13 counties in northern New Jersey, 1 county in  southwest Connecticut, 1 county in northeastern Pennsylvania, and 14  counties in New York, including all those on Long Island and the five  boroughs. The New York City DMA is the largest African-American media  market, the second-largest Asian media market, and the second-largest  Hispanic media market in the United States. In terms of average household  disposable income, the New York City DMA ranks fourth highest in the  United States, making it a very attractive market for a broadcast media  outlet.
The four major networks (ABC, CBS, FOX, and NBC) own and operate  their local broadcast television affiliates in New York. (In smaller  television markets, the major networks are less likely to own and operate  their local affiliates.) One company owns three television stations, all of  which broadcast in Spanish. There are seven noncommercial Public  Broadcasting Service (PBS) affiliates, several independent stations, and  three Spanish-language network affiliates among the remaining broadcast  television stations.
The owners of radio outlets in the New York media market include several  large national media companies with five or six outlets each and 28  entities with a single outlet in the market. Therefore, about two-thirds of  the owners in the New York City DMA are operating a single radio outlet.  The majority of the radio stations in this market broadcast in English,  several broadcast in Spanish, and one broadcasts in Cantonese. In the  aggregate, the 73 radio stations in the New York media market provide  listeners with a wide variety of content.
There is more cross-ownership of newspapers and broadcast outlets in the  New York market than in other media markets, but there is also more  diversity in specialty publications. News Corporation owns The Wall Street  Journal, The New York Post, and two broadcast television stations  (WWOR and WNYW); The New York Times Company owns The New York  Times daily newspaper and a radio station (WQXR); and Tribune  Company owns one Spanish-language daily newspaper (Hoy) and one  television station (WPIX). New York is the center of the publishing  industry in the United States and far more specialty publications are  located here than in other media markets.
The Los Angeles DMA is the second-largest media market in the United  States, with over 5.6 million households. It includes eight counties in  southern California and stretches from the Pacific Coast east to Nevada.  The Los Angeles DMA is the largest Hispanic media market, the largest  Asian media market, and the sixth-largest African-American media market  in the United States. This media market ranks 24th in the nation for  average household disposable income, the lowest ranking among the three  largest media markets.
The four major networks (ABC, CBS, FOX, and NBC) own and operate  their local broadcast television affiliates in the Los Angeles DMA, just as  they do in the New York City DMA. One of these networks owns three  stations in this market while two other networks each own two stations.  Los Angeles has more broadcast television stations than New York; more  stations broadcast in Spanish and there are two Asian-language stations in  Los Angeles.
The Los Angeles DMA is the largest radio market in the country. According  to advertising data for 2005, radio stations in the Los Angeles DMA  competed for over $1 billion of advertising revenue, exceeding the  advertising revenue for the next largest (New York) and the third-largest  (Chicago) radio advertising markets by over $200 million and about $500  million, respectively. The Los Angeles DMA is somewhat more  concentrated: one owner has reached the FCC cap of eight stations and  another is close to the cap with seven stations. By contrast, no radio  station owner in New York has reached the eight-station cap. Fewer  stations are operated by a single owner in Los Angeles (20) than in New  York (28), yet over half the Los Angeles station owners (about 59 percent)  operate a single station. The large number of radio stations in Los Angeles  provides a wide variety of content, and about a quarter of the stations  broadcast in a language other than English, including 13 in Spanish, 3 in  Korean, and 2 in Chinese. Stations located in Mexico and in neighboring  U.S. media markets can also be heard in all or portions of the Los Angeles  DMA, enhancing the market’s diversity.
Fewer newspapers are located in Los Angeles than in the New York DMA,  yet the number is still large compared with other media markets. There is  one instance of cross-ownership: Tribune Company owns the Los Angeles  Times and a broadcast television station (KTLA) in this market.
The Chicago DMA is the third-largest media market in the United States,  with over 3.4 million households. It contains 11 counties in northern  Illinois and 5 counties in northwest Indiana. Chicago is the third-largest  African-American media market, the fifth-largest Asian market, and the  fifth-largest Hispanic media market in the United States. The Chicago DMA  has the seventh-highest average household income in the nation.
The Chicago DMA has eight fewer broadcast television stations than the  Los Angeles DMA; there are four fewer Spanish-language, no Asian- language, and three fewer independent English-language stations in  Chicago. The Chicago DMA also has five fewer television stations than the  New York DMA. Radio outlet ownership is similar to that in Los Angeles— there are 2 owners that operate seven stations each in this market. Radio  ownership is characterized by a few companies operating near the FCC  ownership limit while 27 of the 38 owners (or 71 percent) own and operate  a single radio station.
Chicago has one instance of cross-ownership—under a waiver from FCC,  Tribune Company owns two daily newspapers, the Chicago Tribune and  Hoy, a Spanish-language daily; a television station, WGN; and a radio  station, WGN-AM, in this media market.
section_title: Large Media Markets
paragraphs: After the top three markets, we defined large media markets as those with  between 500,000 and 3 million households. There are 59 media markets in  this size category, ranging from Philadelphia (4) to Tulsa (62). We  randomly selected four of these markets for case study analysis.
subsections: section_title: Miami/Fort Lauderdale, Florida (16)
paragraphs: The Miami/Fort-Lauderdale DMA includes 1.5 million households, making  it the 16th-largest media market in the nation. It is the 3rd-largest Hispanic  media market in the United States, after New York and Los Angeles; the  10th-largest African-American media market; and the 23rd-largest Asian  media market. The average household disposable income for the DMA  ranks 33rd in the nation, yet the advertising revenue for radio ranks 11th.
Although the Miami/Fort Lauderdale DMA has about 2 million fewer  households than the Chicago DMA, both markets support 16 broadcast  television outlets. In Miami, these include affiliates of the eight primary  English-language commercial networks, five Spanish-language stations,  and three public television stations. Three of the English-language  affiliates are owned and operated by two of the four major television  networks. Commercial television stations that are owned and operated by  the major networks are characteristic of our large case study media  markets. Sixteen, or two-thirds, of the radio station owners operate a  single outlet in the Miami/Fort Lauderdale DMA—the same proportion as  in the New York City DMA. One company owns seven radio stations.
This city supports two Spanish-language daily newspapers in addition to  the English-language newspaper. Among the other newspapers available to  residents are several Spanish-language weeklies and an African-American- focused weekly.
Charlotte is the 26th-largest media market in the United States, with over 1  million households. It is the 16th-largest African-American media market,  but is not among the top 25 Hispanic or Asian media markets in the United  States.
The broadcast television market here includes a higher percentage of  noncommercial stations and more duopolies—one company owning two  stations—than do the case study media markets described thus far.  Specifically, 4 of the DMA’s 12 broadcast television stations, or 33 percent,  are noncommercial and are affiliated with PBS. Among the 8 commercial  television stations, there are two duopolies, and 2 of the noncommercial  PBS stations have one owner, a local university. All of the commercial  stations broadcast in English, meaning that residents in this DMA who  desire media content in languages other than English must subscribe to a  cable or satellite television service.
In terms of radio advertising revenue, Charlotte is the 29th-largest market.  Fewer radio stations are located within listening distance of the core city  limits than in Miami or Nashville. Ownership of radio outlets is more  concentrated in Charlotte than in the larger markets. There are 17 owners,  including 1 large national media company that owns 7 radio stations in this  market and 10 commercial and noncommercial owners that each operates  a single station in the market.
The Nashville DMA is the 30th-largest media market in the United States,  with over 940,000 households. Covering 49 counties in Tennessee and  Kentucky, this DMA covers a wide geographic area. Nashville is not among  the top 25 media markets for African Americans, Asians, or Hispanics. In  terms of average household disposable income, the DMA ranks 43rd  among all media markets in the United States, and it ranks lower for  television advertising revenue than for population size.
Two of the Nashville DMA’s 12 broadcast television stations are  noncommercial public television stations. One company owns 2 of the  commercial broadcast television stations and has a local service  agreement to run a third station with another outlet owner. All 12  television stations broadcast in English.
With 52 radio outlets, Nashville has more radio stations than Miami,  Charlotte, and Wilkes Barre/Scranton, the other three case study media  markets in our large-size category, and radio ownership is much less  concentrated. Twenty-four, or 69 percent, of the station owners operate a  single station in this market; two companies own five stations each and  the remaining nine companies own the rest. One of the group owners with  five radio stations also has a joint sales agreement with a radio station  owned by another company in Nashville.
The Wilkes Barre/Scranton DMA covers 17 counties in northeastern  Pennsylvania and is the 53rd-largest media market in the country, with  over 590,000 households. This DMA is unusual in that it has no large core  city, but rather a series of large- and medium-size towns located in the  valleys of this mountainous region. The DMA ranks 148th in the nation for  average household disposable income.
With about 350,000 fewer households than the Nashville DMA, the Wilkes  Barre/Scranton DMA also has fewer broadcast television stations and  radio stations. The DMA contains seven commercial stations, all of which  are broadcast network affiliates, and one PBS affiliate. There are no full- power independent television stations in this media market. Difficulties in  the local economy—and a television advertising market that, according to  industry sources we spoke with, is smaller than warranted for a DMA of its  population size—have encouraged cost-sharing arrangements between the  commercial broadcast television stations. Two of the stations have a single  owner, and this owner has a local service agreement with a third station.  Two other stations have a local service agreement under which they share  everything except programming and finances. The remaining two  commercial television stations have a joint sales agreement. Thus, the  seven commercial television stations in this DMA operate in three loose  commercial groupings.
Ten of the 14 owners of radio outlets in the Wilkes Barre/Scranton DMA,  or 71 percent, own and operate a single radio station in the market. One  company owns five stations, another owns four stations, and two  companies own the remaining five stations. Because of the mountainous  terrain in this DMA, rebroadcasting of other stations’ signals occurs  frequently.
section_title: Medium-Size Media Markets
paragraphs: After the top three markets and large markets, we defined medium-size  media markets as those containing from 150,000 to 499,999 households.  There are 86 media markets in this size category, ranging from Lexington  (63) to Salisbury (148). We randomly selected 4 of these markets for case  study analysis. In addition, before making our random selection, we  judgmentally selected the Tucson, Arizona, DMA as a test market for our  data collection and structured interview methodology because of its large  Hispanic population.
subsections: section_title: Tucson, Arizona (70)
paragraphs: The Tucson DMA is the 70th-largest media market in the United States,  containing over 433,000 households. It is also the 25th-largest Hispanic  media market in the United States, with over 115,000 Hispanic households.  This DMA ranks 74th for average household disposable income.
The Tucson DMA includes six commercial television stations affiliated  with English-language networks, three commercial television stations  affiliated with Spanish-language networks, and two public television  stations. There are two duopoly owners of commercial stations—one of  English-language stations and one of Spanish-language stations.
Radio outlet ownership is relatively concentrated in Tucson, with one  media company operating six radio stations in this market and two media  companies operating five stations each. In total, 7 owners operate more  than one station and 10 owners, or 59 percent, operate a single station in  the market.
The Tucson DMA has two daily newspapers, the Arizona Daily Star and  the Tucson Citizen. They operate together under a joint operating  agreement allowed by the Newspaper Preservation Act of 1970.
The Springfield, Missouri, DMA includes 31 counties in Missouri and  Arkansas and is the 76th-largest media market in the country, with just  over 402,000 households. In terms of average household disposable  income, this DMA ranked 183rd out of 210 media markets in the United  States.
Five commercial television broadcasting stations and one public  broadcasting television station serve this DMA. Two of the commercial  television stations have a local service agreement under which they share  everything in their business operations except programming and finances,  and another two commercial stations operate together under a shared  service agreement.
Five companies own 20 radio outlets, including two companies with 5  radio stations each. Six owners each operate a single radio station in this  market. One company controls the primary daily newspaper in the DMA  and one of the weeklies in Springfield itself.
The Chattanooga DMA covers 17 counties in Tennessee, Georgia, and  North Carolina; includes over 347,000 households; and is the 86th-largest  media market in the United States. This market supports six commercial  television broadcasting stations, all affiliated with a commercial network,  and two public television broadcasting stations. Five radio outlet owners  control 17 radio stations, including two owners that control 4 stations  each. Fifteen owners, or 75 percent, each operate a single station. There is  no cable overbuilder in this DMA.
The Cedar Rapids/Waterloo/Iowa City/Dubuque DMA includes 21 counties  in Iowa, contains over 333,000 households, and is the 89th-largest media  market in the country. Like the Wilkes Barre/Scranton DMA, the Cedar  Rapids/Waterloo/Iowa City/Dubuque DMA does not contain a single core  urban area. However, unlike the Wilkes Barre/Scranton DMA, this DMA is  subdivided among three radio markets. To ensure comparability with  other case study media markets, we counted stations located in the Cedar  Rapids radio market because Cedar Rapids has the largest population of  the four towns.
The Cedar Rapids/Waterloo/Iowa City/Dubuque DMA supports more  broadcast television outlets than comparably populated media markets.  There are six affiliates of national broadcast networks, two public  television stations, and one independent television station, all of which  broadcast in English. Two large national radio companies own 6 radio  stations each, and 6 of the 11 radio outlet owners in the DMA, or 55  percent, each operate a single radio station. There is one daily newspaper  in Cedar Rapids.
The Myrtle Beach/Florence DMA consists of eight counties in South  Carolina and southeastern North Carolina. With over 272,000 households,  this DMA is the 105th-largest media market in the United States, and in  terms of average household disposable income, it ranks 176th out of 210  media markets. This television market DMA contains two medium-size  towns that are geographically separated. Florence is the more populous of  the two, so we counted the radio stations and newspapers located in this  town.
The Myrtle Beach/Florence media market has six broadcast television  outlets and five owners. The duopoly owner is an educational association  that operates two public television stations. Two commercial television  stations operate under a local marketing agreement that enables them to  share fixed operating costs.
In the Florence radio market (the larger of the two radio markets in the  Myrtle Beach/Florence DMA), there are four owners of a single station and  two group owners. One group station owner controls five stations in this  market, while the other controls four stations.
section_title: Small Media Markets
paragraphs: The smallest media markets are those with fewer than 150,000 households.  There are 61 media markets in this size category, ranging from Palm  Springs, California (149), to Glendive, Montana (210). We randomly  selected 4 of these markets for case study analysis.
subsections: section_title: Terre Haute, Indiana (151)
paragraphs: The Terre Haute DMA includes five counties in eastern Illinois and nine  counties in western Indiana. There are fewer than 145,000 households in  this market, making it the 151st-largest media market, and in terms of  average household disposable income, it ranks 174th out of 210 media  markets.
Three commercial television stations and two public television stations  operate in this market. Two of the commercial stations operate under a  joint operating agreement that allows them to share operating costs. As  noted, cost-sharing arrangements also existed in the other four case study  markets where we found a large difference between the population rank  and the average household disposable income rank. Three owners operate  10 radio stations in this market, including two owners that operate 4  stations each, and eight owners each operate a single radio station in this  market.
The Sherman/Ada DMA contains 10 counties in southern Oklahoma and 1  county in northern Texas. Sherman is the largest community within this  media market, with about 37,000 residents. This media market contains  just over 124,000 households and is the 161st-largest media market. This  market contains a higher proportion of Native American residents than  any of our other case study markets.
Although there are two broadcast television stations in this market, there  is no public television station. The two commercial stations are local  affiliates of two different major broadcast networks, and one of these  stations carries a third major broadcast network on its second digital  signal. Residents of this DMA who own a digital television thus have free  access to three of the four major broadcast networks.
While a distinct television market, the Sherman/Ada DMA does not  constitute a separate radio market. Six owners operate more than one  radio station in this market, including one owner that operates four  stations and two owners (one of whom is the Chickasaw Nation) that  operate three stations each. Seven owners each operate a single radio  station in this market.
The Jackson DMA includes the town of Jackson and six counties in  Tennessee to the east and northeast of Memphis. With just over 95,000  households, this media market is the 174th-largest in the nation. The DMA  has two commercial broadcast television stations, both of which are local  affiliates of major networks, and one public television station. Neither of  the two commercial television stations broadcasts a second major  network on its second digital signal. Five radio station owners operate  more than one station, including two companies that operate four stations  each and another that operates three stations in this market. Six owners  each operate a single radio station in this market.
With just over 87,000 households, the Harrisonburg DMA is the smallest  media market we selected for case study analysis. Located northwest of  Richmond, this DMA is the 181st-largest media market in the country and  comprises two counties in Virginia and one county in West Virginia. This  market contains one commercial television station and one public  television station. The commercial television station is an affiliate of a  major broadcast network for its analog signal, but it broadcasts  programming from two other broadcast networks and its analog affiliate  on its digital signals. Residents of this DMA who have a digital television  thus have free access to the programming of three broadcast networks.  Four radio station owners operate more than one station, including one  company that operates five stations and another that operates four  stations in this media market. Three owners each operate a single station  in this market.
section_title: Appendix III: Organizations and Individuals Interviewed
paragraphs: We conducted interviews with the following individuals and  representatives from the following organizations.
section_title: Appendix IV: Comments from the Federal Communications Commission
section_title: Appendix V: GAO Contact and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: Individuals making key contributions to this report include Michael  Clements (Assistant Director), Carl Barden, Matt Barranca, Steve Brown,  Ted Burik, Elizabeth Eisenstadt, Brandon Haller, Madhav Panwar,  Friendly Vang-Johnson, and Mindi Weisenbloom.