Comments on Docket 18-349 (submitted May 15, 2019)

I wish to comment against further deregulation of radio and television ownership limits. We have been on this slippery slope for far too long already, and what we have seen is consolidation through mergers and acquisitions of not only individual stations but of entire multiple-market media companies. Each time we allow this, we lessen the number of individual voices provided by smaller, locally-focused station owner/operators.

In recent years, we have seen bankruptcies by such consolidated entities as iHeart (formerly Clear Channel), Cumulus (which is selling major-market stations in an attempt to regain some semblance of profitability), Citadel (whose bankruptcy was in part responsible for Cumulus' rapid growth). If the concept of owning more than one AM/FM combination per market is to enhance financial viability, it has proven to be a failure often enough to prove otherwise, since the above mentioned media companies are major-market operators. If owning multiple stations in New York or Los Angeles doesn't turn a profit, why can we expect it to work in Duluth or Peoria?

Further, the consolidation results in fewer choices for listeners. When only a handful of companies own all or most of the stations in a market, they will "cleverly" program those stations so as not to cannibalize each station's audience in favor of another in their cluster. This stifles any kind of a truly competitive situation, since the number of specific or near-specific formats in any given market is essentially limited to the number of multiple-station operators in said market.

If the trend of shaky financial results from consolidation continues, there may well be a need for the Commission to revisit the issue in 2022 not for the purpose of considering further reductions of ownership caps, but to begin a process to transition back to lower caps in order to both restore profitability and create more diversity in ownership. Allowing higher caps now will only make that possible future action much more difficult.

Respectfully submitted for the Commission's consideration,
K.M. Richards