For all the political hubbub about whether Arbitron’s PPM undercounts minorities, the FCC’s docket proceeding on whether it should investigate has drawn a scant three comments thus far – and one of those blank – with today the deadline for submitting comments.
The joint request for the investigation came from the National Association of Black Owned Broadcasters, the Spanish Radio Association, the Association of Hispanic Advertising Agencies, and five radio group owners: Border Media, Entravision, Univision, SBS and Inner City. They charged that the methodology that Arbitron is using for all markets since Houston "dramatically undercounts and misrepresents the listening habits of minorities – so much so that the continuing viability of minority radio stations is seriously threatened."
In the only substantial filing on the PPM docket, Bob Michaels, President of Bob Michaels’ MediaSense LLC, notes his expertise as the first VP of Radio and PPM Programming Services at Arbitron, having left the company in 2006. He leaves it to others to argue the issue of whether the FCC has jurisdiction to investigate PPM. But he insists that PPM data proves that minority-focused stations can be just as competitive under PPM as anybody else.
“While it is true that Black and Hispanic stations have generally seen larger drops than non?Black and non?Hispanic stations in PPM (referred to as “Other” in the Arbitron software), some Black and Hispanic stations initially and subsequently have ranked higher in PPM than diary. This proves that the AQH estimates are the function and result of the programming provided by these radio stations. Radio broadcasters with Black and Hispanic stations in both Houston and Philadelphia have educated themselves on the way in which the Average Quarter Hour audiences are built (primarily with building their TSL) and have addressed those issues and have been performing as well if not better PPM than with the diary service. Radio One in Houston is a perfect example of this with KMJQ and KBXX. While they initially performed poorly when the PPM was first released (I addressed their sales and programming staffs on this issue), they have consistently been back in the top 3 for nearly a year. Again, this proves that you can control your ratings destiny,” Michaels wrote.
The other filing (besides the blank) came from veteran broadcaster Richard Downes: “As an interested, but non-affiliated observer, unless Arbitron should purchase or operate a broadcast facility licensed by FCC, it is my opinion that FCC has no jurisdiction over Arbitron in the above (or any other) matter. I have a hypothesis regarding the minority sample, but again, it does not fall within FCC purview. Thank you for asking for public comment on this matter, I appreciate the opportunity.”
RBR/TVBR observation: It seems the media activist groups that generate thousands of filings from across the country on any FCC proceeding dealing with ownership issues have not gotten involved in the PPM controversy. Of course, before the FCC really gets into the merits, it still has to determine whether it even has jurisdiction. We’ll be looking for arguments from the various legal beagles on that count.