NAB suggests extending UHF discount to all TV stations

The National Association of Broadcasters is suggesting the FCC keep the 39% national audience reach cap where it is for TV broadcasters, and extend the 50% discount for UHF stations to all TV stations.

As defined by current FCC regulations, UHF stations count as 50% toward the cap while VHF stations count as 100%. Under the NAB’s proposal, the extension of the UHF discount would effectively put the national audience reach cap at 78%.

In a filing, the NAB argues that “even comparatively large TV station groups are dwarfed by a number of pay-TV/broadband companies and online video providers, let alone the social media giants,” but that none of those competitors are subject to the same audience reach limitations.

“Competition for audiences and advertisers between over-the-air (OTA) stations, multichannel video programming distributors (MVPDs), internet-delivered “virtual” pay TV services like Sling TV and PlayStation Vue, subscription video on demand (SVOD) services such as Netflix and Amazon Prime and social media platforms is fierce and flourishing,” the NAB wrote. “The FCC’s traditional concern with localism, moreover, is effectively enhanced by local, not national, competition, and is more directly promoted by other FCC rules, such as those permitting efficient enforcement of TV stations’ local program exclusivity arrangements and those ensuring market-based negotiation of retransmission consent agreements.”

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