If consolidation of media ownership is such a bad thing, there should be empirical evidence of the harm, said the National Association of Broadcasters in comments filed with the FCC. In fact, it argues, relaxed rules that allow broadcasters to more effectively compete with nationally-targeted competitors support the goal of localism.
NAB notes that "the Commission’s studies generally demonstrate the lack of harm, and, indeed, the benefits that would be gained, from allowing local broadcasters to adopt more economically viable ownership structures," noting that this particularly applied to newspaper/broadcast combinations. The true challenge for local broadcast companies, argues NAB, is to "…maintain their economic vibrancy in the face of multichannel and other competitors that are not constrained by restrictions on local ownership structure." Broadcasters must be able to rely on solid local advertising revenues to continue providing local service.
NAB also agrees with numerous watchdog organizations that the FCC should "… address the under-representation of minorities and women in the broadcast industry through public/private partnerships and market-based stimulants, including tax incentives, which will promote entry and long-term viability of minority and female entrants into a competitively vibrant broadcast industry."
In summary, NAB asks that cross-ownership restrictions be repealed; that small-market television duopoly rules be eased; and although it does not ask for higher local caps for radio groups, it argues against reducing current local caps.