musicFIRST and the Future of Music Coalition have jointly filed comments focused on the status of competition in the marketplace for delivery of audio programming with the Federal Communication Commission’s (FCC) Media Bureau. The comments relate to FCC Docket No. 18-227 and will help facilitate the FCC’s goal of providing a Communications Marketplace Report to Congress. The filing can be found here.

The comments to the commission, completed on behalf of music creators and a wide array of music industry stakeholders, come as broadcasters are aggressively lobbying the FCC to loosen Local Radio Station Ownership Caps in its upcoming Quadrennial Review. In the filing, musicFIRST and the Future of Music Coalition called the potential loosening of these ownership caps “disastrous” for “the public interest and music creators.”

While the comments acknowledge that music streaming, in-home speakers, podcasts and satellite radio are exploding in popularity, the coalitions say that “AM/FM radio is still healthy notwithstanding the fact that they have more competition from newer and more innovative audio platforms. Any demands to drop local ownership caps in order to improve AM/FM radio’s competitive position in the music delivery marketplace based on the relative strength of its more innovative competitors is entirely misplaced.”

“AM/FM radio already enjoys a competitive advantage over their audio competitors—they don’t pay music creators while every other platform playing sound recordings does,” said Chris Israel, musicFIRST’s Executive Director. “Congress’ unanimous passage of the Music Modernization Act demonstrates that updating old laws, leveling playing fields and fairly compensating music creators will win the day over anti-competitive practices.”

“Musicians and listeners benefit from a healthy competitive marketplace, with diverse voices serving diverse communities,” said Kevin Erickson, Director of the Future of Music Coalition. “Unfortunately, the push towards deregulation and consolidated ownership in broadcast radio has left too many listeners stuck with repetitive cookie-cutter playlists and formats, while local musicians lack access to the airwaves.”

In the filing, the two organizations “respectfully request that when the Commission makes its report to Congress, and also when it analyzes the Local Radio Station Ownership Caps in its upcoming Quadrennial Review, that it understands that AM/FM already has a substantial advantage over its competitors insofar as it does not yet have to pay to use sound recordings.”

AFM is a member of musicFIRST—a a national coalition of the music community representing artists and record labels that supports paying music creators when their work is played on any platform. The Future of Music Coalition is a national nonprofit education, research, and advocacy organization supporting a musical ecosystem where diverse artists flourish and are compensated fairly and transparently for their work.