Deadlines set for PPM comments

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If you plan to file comments on whether the FCC should investigate Arbitron’s PPM – and/or whether it has any legal authority to do so – the deadlines have now been set. Formal comments are due July 1 and reply comments July 31. Meanwhile, we see that Arbitron was busy lobbying the Commission right up to when the decision was made to issue the Notice of Inquiry (NOI).


As of Wednesday, no comments had been posted since May 18th when the FCC released the NOI and designated it Media Bureau (MB) Docket No. 08-187. All previous comments and presentations, however, are now listed in that proceeding.

As recently as May 13th Arbitron was still making its case to the Commissioners before the NOI was adopted. Arbitron CEO Michael Skarzynski, several other company officials, and Radio One CEO Alfred Liggins met on May 13th with Commissioner Jonathan Adelstein and his Legal Advisor for Media Issues, Rudy Brioche.

The meeting description filed by Abitron’s attorney said they discussed Arbitron’s continuous improvement program for PPM, its meetings with broadcasters on further enhancements, the accreditation of PPM in the Riverside-San Bernardino market and Arbitron’s commitment to seek accreditation from the MRC in all PPM markets.

As for Liggins’ participation in the meeting, the synopsis said the meeting presented “the experience of Radio One, as the largest African-American-owned radio broadcast company in the United States, in using Radio First to learn more about radio station audience listening behaviors and to adjust Radio One’s stations’ programming accordingly, which has helped Radio One’s stations to compete more effectively for audience share against the legacy stations offering urban programming formats in Radio One’s stations’ markets.”

The NOI was a foregone conclusion by the time of the meeting. Indeed, Adelstein had been the Commissioner pushing hard for it. The company’s filing about the meeting said they discussed “Arbitron’s expectation that the Commission’s forthcoming Notice of
Inquiry proceeding will afford all parties, including Arbitron, an opportunity to exchange information, to become better educated with respect to the issues related to Radio First and its advantages over the diary-based system, and to understand why a passive, electronics-based audience measurement service such as Radio First is a necessary tool for the radio broadcast industry in the 21st century.”

RBR/TVBR observation: We wait and wait for someone to show us the statute that gives the FCC any authority over media ratings. We wait…and wait…