~nitcd ~t9tcs ~Cn(ltc WASHINGTON, DC 20510 November 14, 2011 'nlC Honorable Julius Gcnachowski Chairman Federal Cotnlllunic:l.tions Commission 445 12th St, S\V' Washington, D.C. 2051 S Dear Chairman Gcnachowski: W/c urge the r:ederal Communicltions Commission fO pursue its current comprehensive review of mccu:\ ownership rules with a dcrcgubtory approach, as intended in the Telecommunications Act of 1996. As you are well aware, Section 20201) of that act requires the Conunission to dcrcnnine "whether any of such rules arc necessary in the public interest as a result of competition." It further St:HCS, "[rlhe Commission shall rcpeal or modify any rcgubcion it determines to be no longer in the public interest." \'\le feel [h:II:1ll honest assessment of {he growdl of competition, market e"olution dri"cn by the Intcrnet, :lIld increased consumer empowennem should compel the FCC [Q repeal or, :It least, modify its restrictions on local radio ownership, newspaper/broadcast cross-ownership, and radio/telc"ision cross-owncrship. The media marketplace has changcd dramatically since the Commission and Congress laSt substantively addresscd media ownership relief. In 1996, local radio stacions simply competed against other local radio stations, consumcrs did not h:lYe:lIl Inrernet to deliver the news of the day, :lOd over-dIe-air television faced relativcl}' few competitive programming options. Today's market is far more complex, with all fomls of media - :llldio, print, and video - dclivcred directly to consumcrs via wireline, tcrrestrial wLreless, and satellite platforms, and by rapidly e\'olving fi.xed and mobile Internct delivery alternatives. The growtll in competition and consumer empowerment within the medi:1 marketplace must be considered by tlle Commission. To highlight one component, the FCC's own press documents show tllere are nearly 20% more radio st:aions opcrating today than existed in 1996. And while local radio stations still compete a~nsc one another, tllCy also compete ag.tinst a myriad of other platforms that were either not availablc or in their infancy 15 ycars ago. In 1996, only a h:ll1dful of Internet radio operators existed. Today, Internet radio reaches marc th:1I1 70 million listeners each month. In 2004, therc were a mere 4 million subscribers to satellite radio services. In November oflast year, .XM-Sirius announced it had exceeded 20 million subsnibers. In 2001, Apple introduced its irod device, enabling consumers to time-shift and space-shift and practice editorial control over thcir audio consumption. Tod:ty, a majority of Amc.ricans ovcr the age of twelve own a portable audio device. The story is simibr in the prim and video markets. This explosion of new mcdia options and tools, while disnlptive, has benefited consumers, competition, and the economy. Competition is hcalthicst, howevcr, ,vhen laws and regulations provide a level pbying ground fOf both new and legacy platforms to compete. Local f:ldio and telcvision st:ltions now attempt to compcle in a growing matketplace while strapped with regulations that do llot apply to thc other competitors. 1580 Prim media is struggling to adapt :l leg-Ic)' business model to the new market realities of an online world. The Commission should act proaccivcly now to ensure that legacy audio, print, and video voices arc nor spccifically disadvantagcd. Currcnt media ownership rcgubcions arc anciquared and have comc to provide strucnual imb:tbnce in the markctpbcc. Our govcmmcnr policies should not have the effect of picking winncrs :tnd losers, bur rathcr providc thc faircst compctitivc cnvironment. By modcrnizing media ownersh.ip rules, the Commission can ensure that local media maintains a fair chance to succced in dIe Digital Age. We appreciate yom consideration, and look forward to hcaring from you soon. Sincerely.