The National Association of Broadcasters is telling the Federal Communications Commission the modern radio marketplace bears little resemblance to the one that existed when today’s ownership rules were written, arguing broadcasters are now fighting for listeners and ad dollars against streaming services and giant digital platforms rather than simply competing with one another.
In comments filed in the FCC’s biennial communications marketplace review (GN Docket No. 26-78), NAB says radio stations are operating on a “playing field fundamentally tilted against them” because broadcasters remain bound by ownership restrictions and other regulations while competing against largely unregulated tech and streaming companies. It urges the Commission to modernize local radio ownership caps as a way to even things out.
The center of the argument is that fundamental technological and market changes have affected the competitive position of ad-supported broadcasting. NAB says the Commissions has in the past “clung to the outmoded notion” that broadcast radio competes only against other radio stations to justify retention of “outdated and harmful structural ownership restriction.” It says the recent decision to allow Nexstar to buy Tegna finally took a “more realistic” look at competition — and the report to Congress on competition should follow the TV merger’s conclusions.
The trade group argues radio is increasingly competing inside a blended audio-video ecosystem where consumers move freely between different services. NAB backs its argument with a collection of industry data showing how rapidly listener behavior has shifted. Citing Edison Research data, the filing says 61% of all audio listening now occurs through digital devices, while 28% happens through AM/FM receivers.
“The mere fact that AM/FM radio offers services free to audiences cannot justify disparate regulation — particularly retention of burdensome caps and subcaps on ownership of broadcast radio stations alone,” NAB says.
Connoisseur Media makes a similar argument in its own filing, telling the FCC the radio marketplace “is not an island unto itself, but is instead in daily, direct competition with digital media.” The company, which owns roughly 190 stations, says the Commission must conclude that the current local radio ownership rules are a “relic of another age, and should be repealed in their entirety.”
Connoisseur says Edison data also shows podcast listening surpassed broadcast radio for spoken-word listening time in 2025 for the first time ever.
“This statistic is yet another measurement of how the listening habits of Americans have drastically changed,” Connoisseur writes, arguing the FCC “can no longer downplay” digital competition “as an insignificant threat to radio’s dominance in the audio marketplace.”
At the same time, NAB says radio’s revenue foundation continues to erode as local advertising dollars migrate toward digital. The filing cites Borrell Associates estimates showing local digital advertising now accounts for roughly 70% of all local ad spending. NAB says most of that money flows to companies like Google and Meta.
The filing argues the financial consequences for radio has been severe. According to the filing, the number of AM stations has fallen by 480 since 2009, while commercial FM station totals have declined by nearly 200 since 2019.
Using BIA data, NAB says total radio advertising revenue — including over-the-air and digital revenue — has fallen 30.1% since 2007.
By federal law, the FCC must consider all forms of competition every two years, including what comes from “new and emergent communications services” like the digital services that are impacting radio. The current proceeding could help the FCC tailor its pending quadrennial review of media ownership rules.
The NAB argues radio’s financial realities undermine the FCC’s continued justification for maintaining strict radio ownership caps. NAB says broadcasters need additional scale and investment flexibility if they are expected to compete. “To date, the Commission has failed to reckon with how that robust competition impacts broadcast stations and their ability to offer over-the-air services free to the public,” it says.