REC comments on definition of rural radio markets

MB Docket 03-130: Definition of Radio Markets Outside Arbitron Radio Survey Areas

Even though the media concentration rules of the FCC have been overturned, that order did spawn a Notice of Proposed Rulemaking to inquire on how markets will be defined in areas outside the areas surveyed by Arbitron.

In our comments, we rebutted the FCC's proposal to use county boundaries to define media markets. REC counterproposed markets that actually reflect the coverage of clusters of stations that serve the same area.

REC defines specific market areas in Southern California and Arizona.

REC feels that if the "county" approach is used, then stations that are licensed to rural counties but with programming and advertising directed towards the metro area will allow a single company to have an extensive number of stations in the metro area and have more stations in the adjacent rural county that serve the same area.

REC offers a plan where if a station licensed to a rural county is able to achieve a minimum 1.0 share in the metropolitan area's book, then the station would be placed in the metropolitan market. REC used an example of a station that is licensed to Pahrump, NV in the very rural Nye County and how it programs significantly to the metropolitan Las Vegas area. Using the county methodology, this station could be considered a rural station. Using REC's methodology, it would be considered a metro station subject to any FM ownership rules that may be approved in the future.

Even with our filing of comments in this docket, we remain opposed to the Media Concentration rules in MM Docket 02-277. These rules have been suspended by a court.

REC supports ownership limits of rural broadcast stations.