	Introduction and Background

The Federal Communications Commission (FCC or Commission) has released for public comment 10 economic research studies on media ownership that it had commissioned to provide data and analysis to support the policy debate on what ownership limitations are in the public interest. These studies also provide data and analysis useful to the on-going policy debates on how best to foster minority ownership of broadcast stations and on tiered vs. à la carte pricing of multichannel video program distribution (MVPD) services, such as cable and satellite television. On October 22, 2007, Consumers Union, Consumer Federation of America, and Free Press (Consumer Commenters) submitted to the FCC very detailed comments on the 10 FCC-commissioned media ownership studies. The Consumer Commenters identify a number of alleged specification errors—some raised by the peer reviewers, some by the Consumer Commenters themselves—in the major statistical studies commissioned by the FCC, and then present statistical results from re-running the models in those studies, applying the same empirical data to models revised to correct for the alleged specification errors. Despite the lack of consensus on many issues, it appears that the following general statements can be made about the status of the data collection and analysis available to policy makers. Large, systematic, detailed, and accurate data sets on media ownership characteristics, viewer/listener preferences, and programming are now available for analysts and policy makers. But several gaps remain in data collection. Most significantly the databases on minority and female ownership of broadcast and telecommunications properties are incomplete and/or inaccurate, and statistical analysis based on those data would not be reliable. Although the 10 FCC-commissioned studies present a large number of statistical findings, many of these relationships are not statistically significant across alternative model specifications. This has led the researchers and peer reviewers to offer disclaimers that the findings are not robust and where they find statistical relationships they demonstrate correlation, not causality. The peer reviewers and the Consumer Commenters identified a number of possible technical problems in the econometric analyses performed in the 10 studies. The potentially most noteworthy criticism appears to be that all but one of the studies addressed the impact of media ownership characteristics on the programming provided by individual cross-owned stations, not on the total programming available to consumers in the local market, which arguably is the key public policy concern. No process is in place to determine whether the criticisms are valid and/or whether the study results are reliable. The Consumer Commenters claim that, when they modified the FCC-commissioned studies to take into account these criticisms, they obtained robust results demonstrating that loosening the media ownership limits harmed the public interest, though their results were not always consistent across model specifications.
The Federal Communications Commission (FCC or Commission) has released for public comment 10 economic research studies on media ownership that it had commissioned to provide data and analysis to support the policy debate on what ownership limitations are in the public interest. These studies also provide data and analysis useful to the on-going policy debates on how best to foster minority ownership of broadcast stations and on tiered vs. à la carte pricing of multichannel video program distribution (MVPD) services, such as cable and satellite television. The FCC also has released peer reviews of these studies that are required by the Office of Management and Budget. In addition, Consumers Union, Consumer Federation of America, and Free Press (Consumer Commenters) jointly submitted to the FCC very detailed comments on the 10 FCC-commissioned studies that included statistical results from re-running the models in those studies, applying the same empirical data to models revised to correct for alleged specification errors. Despite the lack of consensus on many issues, it appears that the following general statements can be made about the status of the data collection and analysis available to policy makers:
Large, systematic, detailed, and accurate data sets on media ownership characteristics, viewer/listener preferences, and programming are now available for analysts and policy makers. Several gaps remain in data collection, however. Most significantly the databases on minority and female ownership of broadcast and telecommunications properties are incomplete and inaccurate, and statistical analysis based on those data would not be reliable. Although the 10 FCC-commissioned studies present a large number of statistical findings, many of these relationships are not statistically significant across alternative model specifications. This has led the researchers and peer reviewers to offer disclaimers that the findings are not robust and where they find statistical relationships they demonstrate correlation, not causality. The peer reviewers and the Consumer Commenters identified a number of possible technical problems in the econometric analyses performed in the 10 studies. The potentially most noteworthy criticism appears to be that all but one of the studies addressed the impact of media ownership characteristics on the programming provided by individual cross-owned stations, not on the total programming available to consumers in the local market, which arguably is the key public policy concern. It has not yet been determined whether the criticisms are valid and/or whether the study results are reliable. The Consumer Commenters claim that when they modified the FCC-commissioned studies to take into account these criticisms, they obtained robust results demonstrating that loosening the media ownership limits harmed the public interest, though their results were not always consistent across model specifications. Their modified studies have not yet been subject to full review by others.